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WESTROCK ADVISORS, INC CRD No. 114338 ("Respondent")
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ORDER TO CEASE AND DESIST NOTICE OF INTENT TO REVOKE AND NOTICE OF RIGHT TO HEARING DOCKET NO. RCF-10-7887-S |
I. PRELIMINARY STATEMENT
| 1. | The Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), and the regulations promulgated thereunder (Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies) (“Regulations”). |
| 2. | Pursuant to Section 36b-26(a) of the Act, as amended by Public Act 10-141, the Commissioner, through the Securities and Business Investments Division (“Division”) of the Department of Banking, has conducted an investigation into the activities of Respondent to determine if Respondent has violated, is violating or is about to violate provisions of the Act or Regulations or any order thereunder (“Investigation”). |
| 3. |
As a result of the Investigation, the Commissioner has reason to believe that Respondent has violated certain provisions of the Act and Regulations and an order thereunder. |
| 4. | As a result of the Investigation, the Commissioner has the authority to issue a cease and desist order against Respondent pursuant to Section 36b-27(a) of the 2010 Supplement to the General Statutes (“2010 Supplement”), as amended by Public Act 10-141. |
| 5. |
As a result of the Investigation, the Commissioner brings this administrative action pursuant to Section 36b-15 of the 2010 Supplement, as amended by Public Act 10-141, and Section 4-182(c) of the General Statutes of Connecticut to revoke the broker-dealer registration of Respondent in Connecticut.
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| 6. |
As a result of the Investigation, the Commissioner has the authority to impose a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended by Public Act 10-141. |
II. RESPONDENT
| 7. |
Respondent is a New York corporation with its principal place of business at 230 Park Avenue, New York, New York 10169. |
III. STATEMENT OF FACTS
| 8. | From April 24, 2002 to the present, Respondent has been registered in Connecticut under the Act as a broker-dealer. |
| 9. | On September 4, 2008, the Commissioner entered a consent order (No. CO-2008-7530-S) with respect to Respondent (“2008 Consent Order”), pursuant to Section 36b-31 of the Act and Section 4 177(c) of the General Statutes of Connecticut, which 2008 Consent Order is incorporated by reference herein. |
| 10. | Respondent, through its execution of the 2008 Consent Order, voluntarily consented to the Commissioner issuing an order imposing on it, inter alia, the following sanctions:
1. [Respondent] . . . , its representatives, agents, employees, affiliates, assigns, successors in interest, and those persons in active concert or participation with them shall cease and desist from engaging in conduct constituting or which would constitute a violation of the Act or any regulation or order under the Act, either directly or through any organizational or other device; . . . 3. Commencing on the date this Consent Order is entered by the Commissioner and continuing for a period of three years thereafter, the securities business of . . . [Respondent] in Connecticut shall be exclusively limited to the purchase, sale, and redemption of securities issued by investment companies regulated under the Investment Company Act of 1940; securities issued or guaranteed by the United States government, any state, any political subdivision of a state, or any agency or corporate or other instrumentality of the foregoing; exchange-listed options; and securities listed on the New York Stock Exchange, the American Stock Exchange, the NASDAQ Global Select Market, the NASDAQ Global Market, and the NASDAQ Capital Market. During such period . . . [Respondent] shall not offer or sell in or from Connecticut securities trading on the NASDAQ Bulletin Board or listed for quotation on the Pink Sheets. [Respondent] . . . is not precluded from effecting liquidating sale transactions for its existing accounts in securities trading on the NASDAQ Bulletin Board or listed for quotation on the Pink Sheets for its Connecticut clients; . . . 4. Commencing on the date this Consent Order is entered by the Commissioner and continuing for a period of three years thereafter . . . [Respondent] shall not open any new account approved for options trading for any Connecticut customer unless that Connecticut customer is an “accredited investor” as defined in Rule 501(a) of Regulation D promulgated under the Securities Act of 1933; . . . 8. [Respondent] . . . shall reimburse the Department of Banking for the costs associated with one or more future examinations of any of . . . [Respondent’s] offices to be conducted by the Division within twenty-four (24) months following the Commissioner’s entry of this Consent Order, such amount not to exceed three thousand five hundred dollars ($3,500) in total. Amounts due under this paragraph shall be remitted to the Commissioner via check, payable to “Treasurer, State of Connecticut,” within thirty (30) days following the completion of the examination(s). |
| 11. | On or about August 25, 26 and 27, 2010, pursuant to 2008 Consent Order, and as part of the Investigation, the Division conducted an examination of Respondent’s books and records at Respondent’s branch office located at 201 Old Country Road, Suite 206, Melville, New York 11747 (“Examination”). |
| 12. | Through the Investigation, the Division ascertained that in or about July 2008, Respondent, through its agents, offered and sold in Connecticut to at least one client securities listed for quotation on the Toronto Stock Exchange/Pink Sheets (“Pink Sheet Securities”). |
| 13. | The Pink Sheet Securities offered and sold in Connecticut by Respondent in or about July 2008 were never registered in Connecticut under Section 36b-16 of the Act, as amended by Public Act 10-141, nor were they exempt from registration under Section 36b-21 of the 2010 Supplement, as amended by Public Act 10-141, nor were they covered securities. |
| 14. | Through the Investigation, the Division also ascertained that in or about February 2009, Respondent, through its agents, opened a new account approved for options trading for at least one Connecticut customer who was not an accredited investor. |
| 15. | On September 28, 2010, an invoice was sent to Respondent requesting reimbursement of the Division’s Examination cost of Three Thousand Five Hundred Dollars ($3,500). To date, no reimbursement has been received by the Department. |
| 16. |
On or about August 25, 26 and 27, 2010, as part of the Investigation, the Division requested from Respondent the most recent Financial Industry Regulatory Authority (“FINRA”) exam report for review and the correspondence sent to FINRA and received from FINRA related to FINRA’s latest exam of Respondent. During September and October of 2010, the Division repeatedly requested that the Respondent provide the FINRA exam report and related correspondence. Respondent has failed to provide the FINRA exam report and related documents to the Division. |
| 17. | Respondent was required by Securities and Exchange Commission (”SEC”) Rule 15c3-1, 17 C.F.R. §240.15c3-1, and Section 36b-31-9b(a) of the Regulations to have and maintain certain minimum net capital. |
| 18. | On or about September 24, 2010, during a telephone conversation with Division staff, Respondent’s Chief Compliance Officer indicated that Respondent was not maintaining the minimum net capital required by SEC Rule 15c3-1 and Section 36b 31-9b(a) of the Regulations. |
| 19. | At no time did Respondent, or any agent of Respondent, give written notice to the Commissioner of the net capital deficiency, as described in paragraph 18, or file with the Commissioner an up-to-date statement of financial condition and such supplemental schedules and reports which were reasonably necessary to accurately reflect the total financial position of Respondent, as required by Sections 36b-31-9b(b) and 36b-31-9b(c) of the Regulations, nor did the Commissioner exempt Respondent from such net capital requirement under Section 36b-31-9b(d) of the Regulations. |
| 20. | On or about October 20, 2010, the Division requested from Respondent the complete FINRA exam report; an electronic copy of Respondent’s compliance manual; copies of Respondent’s August and/or September FOCUS Reports; an explanation of Respondent’s net capital deficiency which should include the date Respondent became net capital deficient; if Respondent resolved its net capital deficiency the date of such resolution; and an update of Respondent’s current financial situation. To date, Respondent has failed to provide any of the requested information to the Division. |
| 21. | During the Examination, the Division discovered sales scripts in the possession of Respondent’s agents that had not been previously approved by Respondent. |
| 22. | Respondent’s supervisory principals failed to monitor the scripts in the possession of individuals under their supervision and failed to ensure that no unapproved scripts were being utilized. |
| 23. | On October 22, 2010, the Commissioner gave Respondent written notice pursuant to Section 4-182(c) of the General Statutes of Connecticut that Respondent may have engaged in conduct which, if proven, would constitute a basis for the suspension or revocation of Respondent’s broker-dealer registration in Connecticut, and gave Respondent the opportunity to show compliance with all lawful requirements for the retention of its registration as a broker-dealer in Connecticut. To date, Respondent has failed to respond to the October 22, 2010, notice. |
IV. STATUTORY AND REGULATORY BASIS FOR
ORDER TO CEASE AND DESIST,
REVOCATION OF REGISTRATION AS BROKER-DEALER
AND ORDER IMPOSING FINE
a. Violation of a Consent Order
| 24. | Paragraphs 1 through 23, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 25. |
Respondent’s offer and sale of the Pink Sheet Securities in Connecticut to at least one client, as more fully described in paragraph 12, constitutes a wilful violation of the 2008 Consent Order, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s offer and sale of the Pink Sheet Securities in Connecticut to at least one client in violation of the 2008 Consent Order as more fully described in paragraph 12 also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
| 26. | Respondent’s opening a new account approved for options trading for at least one Connecticut customer who was not an accredited investor, as more fully described in paragraph 14, constitutes a wilful violation of the 2008 Consent Order, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of the 2008 Consent Order as described in this paragraph and in paragraph 14 also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
| 27. | Respondent’s failure to reimburse the Department for the Division’s Examination costs, as more fully described in paragraph 15, constitutes a wilful violation of the 2008 Consent Order, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of the 2008 Consent Order as described in this paragraph and in paragraph 15 also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
| 28. | Respondent’s failure to ensure that its representatives, agents, employees, affiliates, assigns, successors in interest, and those persons in active concert or participation with them ceased and desisted from engaging in conduct constituting or which would constitute a violation of the Act or any regulation or order under the Act, as more fully described in paragraphs 12 through 22, inclusive, constitutes a wilful violation of the 2008 Consent Order, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of the 2008 Consent Order as described in this paragraph also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
b. Violation of Section 36b-16 of the Act –
Offer and Sale of Unregistered Securities
| 29. | Paragraphs 1 through 28, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 30. |
Respondent offered and sold Pink Sheet Securities in Connecticut to at least one client, as more fully described in paragraph 12, which securities were not registered in Connecticut under the Act, as more fully described in paragraph 13. The offer and sale of such securities absent registration constitutes a wilful violation of Section 36b-16 of the Act, as amended, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s offer and sale of Pink Sheet Securities in violation of Section 36b-16 of the Act, as described in this paragraph and in paragraphs 12 and 13, also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
c. Violation of Section 36b-31-14f of the Regulations –
Failure to Provide Records When So Requested
| 31. | Paragraphs 1 through 30, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 32. |
Respondent’s failure to provide the material records requested by the Division, as more fully described in paragraphs 16 and 20, constitutes a wilful violation of Section 36b-14(d) of the Act and Section 36b-31-14f of the Regulations, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-14(d) of the Act and Section 36b-31-14f of the Regulations, as more fully described in paragraphs 16 and 20, also forms a basis for the imposition of a fine against Respondent under Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
| 33. | Respondent’s failure to provide the material records requested by the Division, as more fully described in paragraphs 16 and 20, also forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(L) of the 2010 Supplement, as amended. |
d. Violation of Section 36b-31-9b(a) of the Regulations –
Failure to Maintain Minimum Net Capital Requirement
| 34. | Paragraphs 1 through 33, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 35. |
Respondent’s failure to have and maintain the minimum net capital prescribed by law, as more fully described in paragraphs 17 through 19, inclusive, constitutes a wilful violation of Section 36b-31-9b(a) of the Regulations, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-31-9b(a) of the Regulations also forms a basis for the imposition of a fine against Respondent under Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
e. Violations of Sections 36b-31-9b(b) and 36b-31-9b(c) of the Regulations –
Failure to Provide Written Notice of Failure to Maintain Minimum Net Capital and
Failure to File Up-to-Date Statement of Financial Condition
| 36. | Paragraphs 1 through 35, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 37. |
Respondent’s failure to provide the Commissioner with written notice of its failure to maintain the minimum net capital and Respondent’s failure to file with the Commissioner an up-to-date statement of its financial condition, as more fully described in paragraphs 17 through 19, inclusive, constitutes a wilful violation of Sections 36b-31-9b(b) and 36b-31-9b(c) of the Regulations, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Sections 36b-31-9b(b) and 36b-31-9b(c) of the Regulations also forms a basis for the imposition of a fine against Respondent under Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. |
f. Failure to Enforce and Maintain Adequate Supervisory Procedures
| 38. | Paragraphs 1 through 37, inclusive, are incorporated and made a part hereof as if more fully set forth herein. |
| 39. |
Respondent’s failure to monitor the use of scripts by individuals directly under its supervision to ensure that such scripts were in compliance with all regulatory requirements, as more fully described in paragraphs 21 and 22, constitutes a wilful violation of Section 36b-31-6f of the Regulations, which forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-31-6f of the Regulations also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. Respondent’s failure to monitor the use of scripts by individuals directly under its supervision to ensure that such scripts were in compliance with all regulatory requirements, as more fully described in paragraphs 21 and 22, also forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(K) of the 2010 Supplement, as amended. |
| 40. | Respondent’s failure to ensure that its agents did not offer or sell Pink Sheet Securities in or from Connecticut and that the Pink Sheet Securities the agents did offer and sell were appropriately registered, as more fully described in paragraphs 12 and 13, constitutes a violation of Section 36b-31-6f of the Regulations. A wilful violation of Section 36b-31-6f of the Regulations forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-31-6f of the Regulations also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. Respondent’s failure to ensure that its agents did not offer or sell Pink Sheet Securities in or from Connecticut and that the Pink Sheet Securities the agents did offer and sell were appropriately registered, as more fully described in paragraphs 12 and 13, also forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(K) of the 2010 Supplement, as amended. |
| 41. | Respondent’s failure to ensure that its agents did not open any new account approved for options trading for any Connecticut customer unless that Connecticut customer was an “accredited investor”, as more fully described in paragraph 14, constitutes a violation of Section 36b-31-6f of the Regulations. A wilful violation of Section 36b-31-6f of the Regulations forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-31-6f of the Regulations also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended. Respondent’s failure to ensure that its agents did not open any new account approved for options trading for any Connecticut customer unless that Connecticut customer was an “accredited investor”, as more fully described in paragraph 14, also forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(K) of the 2010 Supplement, as amended. |
| 42. | Respondent’s failure to ensure that its representatives, agents, employees, affiliates, assigns, successors in interest, and those persons in active concert or participation with them ceased and desisted from engaging in conduct constituting or which would constitute a violation of the Act or any regulation or order under the Act, including the 2008 Consent Order, as more fully described in paragraphs 12 through 22, inclusive, constitutes a violation of Section 36b-31-6f of the Regulations. A wilful violation of Section 36b-31-6f of the Regulations forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended. Respondent’s violation of Section 36b-31-6f of the Regulations also forms a basis for the imposition of a fine against Respondent pursuant to Section 36b-27(d) of the 2010 Supplement, as amended, and for an order to cease and desist against Respondent under Section 36b-27(a) of the 2010 Supplement, as amended.. Respondent’s failure to ensure that its representatives, agents, employees, affiliates, assigns, successors in interest, and those persons in active concert or participation with them ceased and desisted from engaging in conduct constituting or which would constitute a violation of the Act or any regulation or order under the Act, as more fully described in paragraphs 12 through 22, also forms a basis for the revocation of Respondent’s registration as a broker-dealer in Connecticut pursuant to Section 36b-15(a)(2)(K) of the 2010 Supplement, as amended. |
V. ORDER TO CEASE AND DESIST, NOTICE OF INTENT TO REVOKE
REGISTRATION AS BROKER-DEALER, NOTICE OF INTENT TO FINE
AND NOTICE OF RIGHT TO HEARING
WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Respondent violated the 2008 Consent Order, has committed at least one violation of Section 36b-16 of the Act, as amended, at least one violation of Section 36b-14(d) of the Act, at least one violation of Section 36b-31-14f of the Regulations, one violation of Section 36b-31-9b(a) of the Regulations, one violation of Section 36b-31-9b(b) of the Regulations, one violation of Section 36b-31-9b(c) of the Regulations, and at least one violation of Section 36b-31-6f of the Regulations;
WHEREAS, the Commissioner has reason to believe that Respondent has engaged in acts or conduct that, pursuant to Section 36b-15 of the 2010 Supplement, as amended, constitute grounds for revoking Respondent’s registration as a broker-dealer in Connecticut;
WHEREAS, the Commissioner further finds that the issuance of this Order to Cease and Desist, the issuance of an order revoking Respondent’s registration as a broker-dealer in Connecticut, and the imposition of a fine against Respondent is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policies and provisions of the Act;
WHEREAS, notice is hereby given to Respondent that its registration as a broker-dealer in Connecticut shall be revoked, subject to Respondent’s right to request a hearing on the allegations set forth above;
WHEREAS, notice is hereby given to Respondent that the Commissioner intends to impose a maximum fine not to exceed One Hundred Thousand Dollars ($100,000) per violation;
WHEREAS, the Commissioner ORDERS that Respondent CEASE AND DESIST from directly or indirectly violating the provisions of the Act, Regulations and orders adopted or issued under the Act, including without limitation: (1) violating the 2008 Consent Order, (2) offering and/or selling unregistered securities, (3) failing to provide records requested by the Division, (4) failing to maintain minimum net capital, (5) failing to provide the Commissioner with written notice of its failure to maintain the minimum net capital prescribed by law and to file with the Commissioner an up-to-date statement of its financial condition, and (6) failing to enforce and maintain adequate supervisory procedures;
AND WHEREAS, pursuant to Sections 36b-15(f) and 36b-27 of the 2010 Supplement, as amended, Respondent will be afforded an opportunity for a hearing on the allegations set forth above.
THE COMMISSIONER FURTHER ORDERS that a hearing will be granted to Respondent if a written request for a hearing is received by the Department of Banking, Securities Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following Respondent’s receipt of this Order. The enclosed Appearance and Request for Hearing Form must be completed and mailed to the above address. If Respondent will not be represented by an attorney at the hearing, please complete the Appearance and Request for Hearing Form as “pro se”. Once a written request for a hearing is received, the Commissioner may issue a notification of hearing and designation of hearing officer that acknowledges receipt of a request for a hearing, designates a presiding officer and sets the date of the hearing in accordance with Section 4-177 of the General Statutes of Connecticut and Section 36a-1-21 of the Regulations of Connecticut State Agencies. If a hearing is requested, the hearing will be held on January 19, 2011, at 10 a.m., at the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut.
The hearing will be held in accordance with the provisions of Chapter 54 of the General Statutes of Connecticut. At such hearing, Respondent will have the right to appear and present evidence, rebuttal evidence and argument on all issues of fact and law to be considered by the Commissioner.
This Order to Cease and Desist shall remain in effect and become permanent against Respondent if Respondent fails to request a hearing within the prescribed time period or fails to appear at any such hearing.
The Commissioner shall issue an order revoking Respondent’s registration as a broker-dealer in Connecticut if Respondent fails to request a hearing within the prescribed time period or fails to appear at any such hearing.
The Commissioner may order that the maximum fine be imposed upon Respondent if Respondent fails to request a hearing within the prescribed time period or fails to appear at any such hearing.
| Dated at Hartford, Connecticut, | ________/s/________ | |
| this 8th day of December 2010. | Howard F. Pitkin | |
| Banking Commissioner |
CERTIFICATION
I hereby certify that on this 9th day of December 2010, the foregoing Order to Cease and Desist, Notice of Intent to Revoke Registration as Broker-dealer, Notice of Intent to Fine and Notice of Right to Hearing was sent by certified mail, return receipt requested, to Westrock Advisors, Inc., 230 Park Avenue, New York, New York 10169, certified mail no. 7010 0290 0002 7489 9994.
____/s/___________
Paul A. Bobruff
Prosecuting Attorney