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This profile was last updated on 9/16/12  and contains information from public web pages.

Rooney A. Sahai

Wrong Rooney A. Sahai?

Limited Representative

Local Address: New York, United States
The Key Group , Inc.
 
Background

Employment History

Board Memberships and Affiliations

  • Registered limited representative
6 Total References
Web References
RRBDLAW.com 917-520-2836: SEC Appeal Rooney A. Sahai Forgery Rule 8210 Unauthorized Trades NASD
www.rrbdlaw.com, 15 April 2005 [cached]
Case Analysis:  SEC Appeal of Rooney A. Sahai (NASD) RRBDLAW.com 917-520-2836: SEC Appeal Rooney A. Sahai Forgery Rule 8210 Unauthorized Trades NASD
...
In the Matter of the Application of Rooney A. Sahai
...
Rooney A. Sahai entered the securities industry in 1986, and became associated with The Key Group, Inc. ("Key Group") in 1999, during which time he worked out of his home. In 1999 and 2000, Sahai was registered with Key Group as a limited representative - investment company and variable contracts products representative.
Customer Malcolm Coblentz
In 1998 or early 1999, Malcolm Coblentz, a physician, purchased health insurance from Sahai.
...
Thereafter, Sahai visited Coblentz's office from time to time to discuss various investment products.
...
On December 3, 1999, Coblentz and his wife met with Sahai, and the doctor requested that Sahai liquidate the MIIX stock and use the proceeds to establish an IRA account . Coblentz agreed with Sahai's recommendation that the stock certificate proceeds be invested in American Skandia mutual funds.
...
Coblentz's wife telephoned Bear Stearns to inquire about the delay and was informed that the firm had waited until Coblentz had signed and returned to Bear Stearns an IRS Form W-9 , which had been sent to Sahai.
...
Sahai said he either had "no role" or minimal involvement with paperwork and that his clerical staff was responsible for processing paperwork, obtaining customer signatures, and other administrative tasks. During this period, he employed part-time high school and college students who remained with his office for only short periods of time. Sahai was the only registered representative in his office.
...
Sahai denied that he had signed Note Two but was not sure whether his handwriting appeared on Note Two --- he admitted that the language authorizing the transaction was in his handwriting.
...
Ikonomou asked Coblentz and his wife for the name of someone to reinvest the funds held in the retirement account, and they recommended Sahai.
...
In January 2000, Ikonomou received from American Skandia a copy of a letter, dated January 18, 2000, that was addressed to Sahai.
...
Although Sahai initially stated that an American Skandia annuity was purchased with Ikonomou's knowledge and consent, he subsequently admitted that the transaction had been a "mistake" and a "clear error" resulting from a rush to comply with Ikonomou's wish for re-investment by year-end 1999. Sahai admitted that the annuity had been unsuitable for Ikonomu, but noted that he would have earned between $300 to $300 in commission on either the mutual fund or annuity (suggesting he had no economic incentive for the latter purchase).
Sahai admitted that his handwriting appears in the "Investment Dealer" section of the 2000 Mutual Fund Application, but denied signing Ikonomou's signature on the document or authorizing anyone else to do so. Sahai admitted also that it is "likely" that he wrote "The Key Group" on the Annuity Application.
NASD Investigation
On February 15, 2001, NASD sent Sahai a Rule 8210 written request for, among other things, the names and addresses of the employees that had been working for him at Key Group. At the request of Steven Mannion, who represented Sahai during the investigation, NASD extended the response date from March 1 to March 16, 2001.
...
Sahai failed to respond by the extended deadline to NASD's request for information.
On March 19, 2001, NASD sent Sahai a second letter informing Sahai that NASD had not received a response to its prior request and sought his reply. The March 19 letter further advised Sahai that, if he failed to respond, he could be subject to disciplinary action.
...
The letter repeated that the former employees had been terminated because Sahai "was generally not satisfied" with their performance.
On March 29, 2001 , NASD staff sent a third request to Sahai informing him that they had received a partial response to its prior requests and again requested, among other things, the addresses of the former employees. The March 29 request also informed Sahai that he had an unconditional obligation to respond could not determine what information requested would be material to the investigation. The response date for this request was April 9, 2001. On April 3, 2001, Sahai's counsel responded that Sahai had provided all documents contained in his personal files and would continue to search for additional records, and that, if any were found, Sahai would produce them. The response also stated that "[u]ntil that time the response tendered is complete. The April 3 response did not include, among other things, the requested addresses of Sahai's former employees. On April 18, 2001, Sahai's counsel sent an additional response, stating that Sahai "is seeking that his former accountant voluntarily produce [the addresses and possibly telephone numbers of the employees] from the payroll records."
On April 23, 2001, NASD sent Sahai a fourth request, again seeking the addresses of his former employees. On April 25, 2001, Sahai's counsel provided the last known address for Haas in Ridgefield, New Jersey, but stated that Sahai had not been able to locate addresses for the remaining two former employees, Patel and Marra.
...
Sahai, through counsel, responded that, "These were temporary employees for whom records were not kept other than in a computer address book program which crashed sometime in 2000. The NASD investigator testified that he contacted "411" and that no one named Haas had been listed at the address identified by Sahai.
...
On April 27, 2001, NASD sent Sahai a fifth request seeking: (1) the source from which Sahai obtained Haas's address ; (2) Social Security numbers for Haas, Patel and Marra; (3) payroll records for Sahai's former employees or an explanation of how they were paid; and (4) any employment applications for Haas, Patel, and Marra.
...
Sahai failed to provide the requested information or an explanation of why he could not provide it.
On May 10, 2001, NASD sent Sahai a written request reiterating its April 23 request for the addresses of his former employees. The May 10 request advised Sahai that, if he failed to respond, he could be subject to disciplinary action, and enclosed a copy of the relevant sanction guideline for failure to respond violations. The response date for the May 10 request was May 21, 2001. By letter dated May 10, 2001, Sahai's counsel informed NASD that Sahai could not locate the remaining addresses for his former employees. Counsel reiterated Haas's address and the fact that the computer address book had crashed . Sahai also did not provide the information requested in the April 27, 2001 request.
On May 14, 2001, NASD sent Sahai a sixth and "final" request to produce, by May 24, 2001, the documents and information NASD had requested in the April 27, 2001 request. Sahai f ailed to provide the requested information or an explanation of why he could not provide the information.
...
The NASD subsequently filed charges against Sahai and a Hearing Panel found that Sahai caused the signatures of two customers to be forged on documents, engaged in an unauthorized transaction , and failed to respond to information requests, in violation of NASD Conduct Rule 2110 and Procedural Rule 8210. The Hearing Panel dismissed an allegation that Sahai was liable for engaging in outside business activities without proper notice to his member firm. The Hearing Panel determined that a unitary sanction was appropriate for all the violations found, and it barred Sahai in all capacities and assessed costs.
On appeal, the NASD's National Adjudicatory Counsel (NAC) affirmed the findings and modified the sanctions of the Hearing Panel so that each violation was individually sanctioned. The NAC imposed a bar in all capacities for the forgery violation and a second bar in all capacities for the failure to respond violation. The NAC thought a fine of $5,000 for the unauthorized transaction violation was appropriate, but due to the imposition of the bars, declined to impose it.
Sahai appealed the NASD's decision to the SEC
...
The NASD found that Sahai forged or caused the forgery of the the Form W-9, Note Two, and the mutual fund application for Coblentz; and the 2000 Mutual Fund Application and Annuity Application in Ikonomou's name.
...
Sahai admitted completing the dealer information on both the 2000 Mutual Fund Application and Annuity Application and writing the text of Note Two. Otherwise, he denied completing any of the alleged forged docum
RRBDLAW.com :: Special Features :: Securities Industry Commentator
www.rrbdlaw.com, 29 Mar 2006 [cached]
Case Analysis: SEC Appeal of Rooney A. Sahai (NASD):Forgery; Failure to Cooperate Case Analysis: SEC Appeal of E. Magnus Oppenheim & Co., Inc. (NASD): Late FOCUS Report
In the Matter of the Application ...
rrbdlaw.com, 1 Jan 2005 [cached]
In the Matter of the Application of Rooney A. Sahai
...
Rooney A. Sahai entered the securities industry in 1986, and became associated with The Key Group, Inc. ("Key Group") in 1999, during which time he worked out of his home.In 1999 and 2000, Sahai was registered with Key Group as a limited representative - investment company and variable contracts products representative.
Customer Malcolm Coblentz
In 1998 or early 1999, Malcolm Coblentz, a physician, purchased health insurance from Sahai.
...
Thereafter, Sahai visited Coblentz's office from time to time to discuss various investment products.
...
On December 3, 1999, Coblentz and his wife met with Sahai, and the doctor requested that Sahai liquidate the MIIX stock and use the proceeds to establish an IRA account.
...
Coblentz's wife telephoned Bear Stearns to inquire about the delay and was informed that the firm had waited until Coblentz had signed and returned to Bear Stearns an IRS Form W-9, which had been sent to Sahai.
...
Sahai said he either had "no role" or minimal involvement with paperwork and that his clerical staff was responsible for processing paperwork, obtaining customer signatures, and other administrative tasks.During this period, he employed part-time high school and college students who remained with his office for only short periods of time.Sahai was the only registered representative in his office.
...
Sahai denied that he had signed Note Two but was not sure whether his handwriting appeared on Note Two --- he admitted that the language authorizing the transaction was in his handwriting.
...
Ikonomou asked Coblentz and his wife for the name of someone to reinvest the funds held in the retirement account, and they recommended Sahai.
...
In January 2000, Ikonomou received from American Skandia a copy of a letter, dated January 18, 2000, that was addressed to Sahai.
...
Although Sahai initially stated that an American Skandia annuity was purchased with Ikonomou's knowledge and consent, he subsequently admitted that the transaction had been a "mistake" and a "clear error" resulting from a rush to comply with Ikonomou's wish for re-investment by year-end 1999.Sahai admitted that the annuity had been unsuitable for Ikonomu, but noted that he would have earned between $300 to $300 in commission on either the mutual fund or annuity (suggesting he had no economic incentive for the latter purchase).
Sahai admitted that his handwriting appears in the "Investment Dealer" section of the 2000 Mutual Fund Application, but denied signing Ikonomou's signature on the document or authorizing anyone else to do so.Sahai admitted also that it is "likely" that he wrote "The Key Group" on the Annuity Application.
NASD Investigation
On February 15, 2001, NASD sent Sahai a Rule 8210 written request for, among other things, the names and addresses of the employees that had been working for him at Key Group.At the request of Steven Mannion, who represented Sahai during the investigation, NASD extended the response date from March 1 to March 16, 2001.
...
Sahai failed to respond by the extended deadline to NASD's request for information.
On March 19, 2001, NASD sent Sahai a second letter informing Sahai that NASD had not received a response to its prior request and sought his reply.The March 19 letter further advised Sahai that, if he failed to respond, he could be subject to disciplinary action.
...
The letter repeated that the former employees had been terminated because Sahai "was generally not satisfied" with their performance.
On March 29, 2001, NASD staff sent a third request to Sahai informing him that they had received a partial response to its prior requests and again requested, among other things, the addresses of the former employees.The March 29 request also informed Sahai that he had an unconditional obligation to respond could not determine what information requested would be material to the investigation.The response date for this request was April 9, 2001.On April 3, 2001, Sahai's counsel responded that Sahai had provided all documents contained in his personal files and would continue to search for additional records, and that, if any were found, Sahai would produce them.The response also stated that "[u]ntil that time the response tendered is complete."The April 3 response did not include, among other things, the requested addresses of Sahai's former employees.On April 18, 2001, Sahai's counsel sent an additional response, stating that Sahai "is seeking that his former accountant voluntarily produce [the addresses and possibly telephone numbers of the employees] from the payroll records."
On April 23, 2001, NASD sent Sahai a fourth request, again seeking the addresses of his former employees.On April 25, 2001, Sahai's counsel provided the last known address for Haas in Ridgefield, New Jersey, but stated that Sahai had not been able to locate addresses for the remaining two former employees, Patel and Marra.
...
Sahai, through counsel, responded that, "These were temporary employees for whom records were not kept other than in a computer address book program which crashed sometime in 2000."The NASD investigator testified that he contacted "411" and that no one named Haas had been listed at the address identified by Sahai.He also attempted unsuccessfully to run an Internet search for Deepa Patel.
On April 27, 2001, NASD sent Sahai a fifth request seeking: (1) the source from which Sahai obtained Haas's address; (2) Social Security numbers for Haas, Patel and Marra; (3) payroll records for Sahai's former employees or an explanation of how they were paid; and (4) any employment applications for Haas, Patel, and Marra.
...
Sahai failed to provide the requested information or an explanation of why he could not provide it.
On May 10, 2001, NASD sent Sahai a written request reiterating its April 23 request for the addresses of his former employees.The May 10 request advised Sahai that, if he failed to respond, he could be subject to disciplinary action, and enclosed a copy of the relevant sanction guideline for failure to respond violations.The response date for the May 10 request was May 21, 2001.By letter dated May 10, 2001, Sahai's counsel informed NASD that Sahai could not locate the remaining addresses for his former employees.Counsel reiterated Haas's address and the fact that the computer address book had crashed.Sahai also did not provide the information requested in the April 27, 2001 request.
On May 14, 2001, NASD sent Sahai a sixth and "final" request to produce, by May 24, 2001, the documents and information NASD had requested in the April 27, 2001 request.Sahai failed to provide the requested information or an explanation of why he could not provide the information.
...
The NASD subsequently filed charges against Sahai and a Hearing Panel found that Sahai caused the signatures of two customers to be forged on documents, engaged in an unauthorized transaction, and failed to respond to information requests, in violation of NASD Conduct Rule 2110 and Procedural Rule 8210.The Hearing Panel dismissed an allegation that Sahai was liable for engaging in outside business activities without proper notice to his member firm.The Hearing Panel determined that a unitary sanction was appropriate for all the violations found, and it barred Sahai in all capacities and assessed costs.
On appeal, the NASD's National Adjudicatory Counsel (NAC) affirmed the findings and modified the sanctions of the Hearing Panel so that each violation was individually sanctioned.The NAC imposed a bar in all capacities for the forgery violation and a second bar in all capacities for the failure to respond violation.The NAC thought a fine of $5,000 for the unauthorized transaction violation was appropriate, but due to the imposition of the bars, declined to impose it.
Sahai appealed the NASD's decision to the SEC
...
The NASD found that Sahai forged or caused the forgery of the the Form W-9, Note Two, and the mutual fund application for Coblentz; and the 2000 Mutual Fund Application and Annuity Application in Ikonomou's name.
...
Sahai admitted completing the dealer information on both the 2000 Mutual Fund Application and Annuity Application and writing the text of Note Two.Otherwise, he denied completing any of the alleged forged documents or signing Coblentz's or Ikonomou's signatures or authorizing anyone else to do so.
Notwithstanding the NASD's finding that Sahai had profited from Coblentz's and Ikonomou's tr
RRBDLAW.com 917-520-2836: SEC Appeal Rooney A. Sahai Forgery Rule 8210 Unauthorized Trades NASD
www.securitiesindustrycommentator.com, 1 Jan 2005 [cached]
Case Analysis:  SEC Appeal of Rooney A. Sahai (NASD)RRBDLAW.com 917-520-2836: SEC Appeal Rooney A. Sahai Forgery Rule 8210 Unauthorized Trades NASD
...
In the Matter of the Application of Rooney A. Sahai
...
Rooney A. Sahai entered the securities industry in 1986, and became associated with The Key Group, Inc. ("Key Group") in 1999, during which time he worked out of his home.In 1999 and 2000, Sahai was registered with Key Group as a limited representative - investment company and variable contracts products representative.
Customer Malcolm Coblentz
In 1998 or early 1999, Malcolm Coblentz, a physician, purchased health insurance from Sahai.
...
Thereafter, Sahai visited Coblentz's office from time to time to discuss various investment products.
...
On December 3, 1999, Coblentz and his wife met with Sahai, and the doctor requested that Sahai liquidate the MIIX stock and use the proceeds to establish an IRA account.
...
Coblentz's wife telephoned Bear Stearns to inquire about the delay and was informed that the firm had waited until Coblentz had signed and returned to Bear Stearns an IRS Form W-9, which had been sent to Sahai.
...
Sahai said he either had "no role" or minimal involvement with paperwork and that his clerical staff was responsible for processing paperwork, obtaining customer signatures, and other administrative tasks.During this period, he employed part-time high school and college students who remained with his office for only short periods of time.Sahai was the only registered representative in his office.
...
Sahai denied that he had signed Note Two but was not sure whether his handwriting appeared on Note Two --- he admitted that the language authorizing the transaction was in his handwriting.
...
Ikonomou asked Coblentz and his wife for the name of someone to reinvest the funds held in the retirement account, and they recommended Sahai.
...
In January 2000, Ikonomou received from American Skandia a copy of a letter, dated January 18, 2000, that was addressed to Sahai.
...
Although Sahai initially stated that an American Skandia annuity was purchased with Ikonomou's knowledge and consent, he subsequently admitted that the transaction had been a "mistake" and a "clear error" resulting from a rush to comply with Ikonomou's wish for re-investment by year-end 1999.Sahai admitted that the annuity had been unsuitable for Ikonomu, but noted that he would have earned between $300 to $300 in commission on either the mutual fund or annuity (suggesting he had no economic incentive for the latter purchase).
Sahai admitted that his handwriting appears in the "Investment Dealer" section of the 2000 Mutual Fund Application, but denied signing Ikonomou's signature on the document or authorizing anyone else to do so.Sahai admitted also that it is "likely" that he wrote "The Key Group" on the Annuity Application.
NASD Investigation
On February 15, 2001, NASD sent Sahai a Rule 8210 written request for, among other things, the names and addresses of the employees that had been working for him at Key Group.At the request of Steven Mannion, who represented Sahai during the investigation, NASD extended the response date from March 1 to March 16, 2001.
...
Sahai failed to respond by the extended deadline to NASD's request for information.
On March 19, 2001, NASD sent Sahai a second letter informing Sahai that NASD had not received a response to its prior request and sought his reply.The March 19 letter further advised Sahai that, if he failed to respond, he could be subject to disciplinary action.
...
The letter repeated that the former employees had been terminated because Sahai "was generally not satisfied" with their performance.
On March 29, 2001, NASD staff sent a third request to Sahai informing him that they had received a partial response to its prior requests and again requested, among other things, the addresses of the former employees.The March 29 request also informed Sahai that he had an unconditional obligation to respond could not determine what information requested would be material to the investigation.The response date for this request was April 9, 2001.On April 3, 2001, Sahai's counsel responded that Sahai had provided all documents contained in his personal files and would continue to search for additional records, and that, if any were found, Sahai would produce them.The response also stated that "[u]ntil that time the response tendered is complete."The April 3 response did not include, among other things, the requested addresses of Sahai's former employees.On April 18, 2001, Sahai's counsel sent an additional response, stating that Sahai "is seeking that his former accountant voluntarily produce [the addresses and possibly telephone numbers of the employees] from the payroll records."
On April 23, 2001, NASD sent Sahai a fourth request, again seeking the addresses of his former employees.On April 25, 2001, Sahai's counsel provided the last known address for Haas in Ridgefield, New Jersey, but stated that Sahai had not been able to locate addresses for the remaining two former employees, Patel and Marra.
...
Sahai, through counsel, responded that, "These were temporary employees for whom records were not kept other than in a computer address book program which crashed sometime in 2000."The NASD investigator testified that he contacted "411" and that no one named Haas had been listed at the address identified by Sahai.He also attempted unsuccessfully to run an Internet search for Deepa Patel.
On April 27, 2001, NASD sent Sahai a fifth request seeking: (1) the source from which Sahai obtained Haas's address; (2) Social Security numbers for Haas, Patel and Marra; (3) payroll records for Sahai's former employees or an explanation of how they were paid; and (4) any employment applications for Haas, Patel, and Marra.
...
Sahai failed to provide the requested information or an explanation of why he could not provide it.
On May 10, 2001, NASD sent Sahai a written request reiterating its April 23 request for the addresses of his former employees.The May 10 request advised Sahai that, if he failed to respond, he could be subject to disciplinary action, and enclosed a copy of the relevant sanction guideline for failure to respond violations.The response date for the May 10 request was May 21, 2001.By letter dated May 10, 2001, Sahai's counsel informed NASD that Sahai could not locate the remaining addresses for his former employees.Counsel reiterated Haas's address and the fact that the computer address book had crashed.Sahai also did not provide the information requested in the April 27, 2001 request.
On May 14, 2001, NASD sent Sahai a sixth and "final" request to produce, by May 24, 2001, the documents and information NASD had requested in the April 27, 2001 request.Sahai failed to provide the requested information or an explanation of why he could not provide the information.
...
The NASD subsequently filed charges against Sahai and a Hearing Panel found that Sahai caused the signatures of two customers to be forged on documents, engaged in an unauthorized transaction, and failed to respond to information requests, in violation of NASD Conduct Rule 2110 and Procedural Rule 8210.The Hearing Panel dismissed an allegation that Sahai was liable for engaging in outside business activities without proper notice to his member firm.The Hearing Panel determined that a unitary sanction was appropriate for all the violations found, and it barred Sahai in all capacities and assessed costs.
On appeal, the NASD's National Adjudicatory Counsel (NAC) affirmed the findings and modified the sanctions of the Hearing Panel so that each violation was individually sanctioned.The NAC imposed a bar in all capacities for the forgery violation and a second bar in all capacities for the failure to respond violation.The NAC thought a fine of $5,000 for the unauthorized transaction violation was appropriate, but due to the imposition of the bars, declined to impose it.
Sahai appealed the NASD's decision to the SEC
...
The NASD found that Sahai forged or caused the forgery of the the Form W-9, Note Two, and the mutual fund application for Coblentz; and the 2000 Mutual Fund Application and Annuity Application in Ikonomou's name.
...
Sahai admitted completing the dealer information on both the 2000 Mutual Fund Application and Annuity Application and writing the text of Note Two.Otherwise, he denied completing any of the alleged forged document
RRBDLAW.com 917-520-2836: SEC Appeal Rooney A. Sahai Forgery Rule 8210 Unauthorized Trades NASD
rrbdlaw.com, 15 April 2005 [cached]
In the Matter of the Application of Rooney A. Sahai
...
Rooney A. Sahai entered the securities industry in 1986, and became associated with The Key Group, Inc. ("Key Group") in 1999, during which time he worked out of his home. In 1999 and 2000, Sahai was registered with Key Group as a limited representative - investment company and variable contracts products representative.
Customer Malcolm Coblentz
In 1998 or early 1999, Malcolm Coblentz, a physician, purchased health insurance from Sahai.
...
Thereafter, Sahai visited Coblentz's office from time to time to discuss various investment products.
...
On December 3, 1999, Coblentz and his wife met with Sahai, and the doctor requested that Sahai liquidate the MIIX stock and use the proceeds to establish an IRA account . Coblentz agreed with Sahai's recommendation that the stock certificate proceeds be invested in American Skandia mutual funds.
...
Coblentz's wife telephoned Bear Stearns to inquire about the delay and was informed that the firm had waited until Coblentz had signed and returned to Bear Stearns an IRS Form W-9 , which had been sent to Sahai.
...
Sahai said he either had "no role" or minimal involvement with paperwork and that his clerical staff was responsible for processing paperwork, obtaining customer signatures, and other administrative tasks. During this period, he employed part-time high school and college students who remained with his office for only short periods of time. Sahai was the only registered representative in his office.
...
Sahai denied that he had signed Note Two but was not sure whether his handwriting appeared on Note Two --- he admitted that the language authorizing the transaction was in his handwriting.
...
Ikonomou asked Coblentz and his wife for the name of someone to reinvest the funds held in the retirement account, and they recommended Sahai.
...
In January 2000, Ikonomou received from American Skandia a copy of a letter, dated January 18, 2000, that was addressed to Sahai.
...
Although Sahai initially stated that an American Skandia annuity was purchased with Ikonomou's knowledge and consent, he subsequently admitted that the transaction had been a "mistake" and a "clear error" resulting from a rush to comply with Ikonomou's wish for re-investment by year-end 1999. Sahai admitted that the annuity had been unsuitable for Ikonomu, but noted that he would have earned between $300 to $300 in commission on either the mutual fund or annuity (suggesting he had no economic incentive for the latter purchase).
Sahai admitted that his handwriting appears in the "Investment Dealer" section of the 2000 Mutual Fund Application, but denied signing Ikonomou's signature on the document or authorizing anyone else to do so. Sahai admitted also that it is "likely" that he wrote "The Key Group" on the Annuity Application.
NASD Investigation
On February 15, 2001, NASD sent Sahai a Rule 8210 written request for, among other things, the names and addresses of the employees that had been working for him at Key Group. At the request of Steven Mannion, who represented Sahai during the investigation, NASD extended the response date from March 1 to March 16, 2001.
...
Sahai failed to respond by the extended deadline to NASD's request for information.
On March 19, 2001, NASD sent Sahai a second letter informing Sahai that NASD had not received a response to its prior request and sought his reply. The March 19 letter further advised Sahai that, if he failed to respond, he could be subject to disciplinary action.
...
The letter repeated that the former employees had been terminated because Sahai "was generally not satisfied" with their performance.
On March 29, 2001 , NASD staff sent a third request to Sahai informing him that they had received a partial response to its prior requests and again requested, among other things, the addresses of the former employees. The March 29 request also informed Sahai that he had an unconditional obligation to respond could not determine what information requested would be material to the investigation. The response date for this request was April 9, 2001. On April 3, 2001, Sahai's counsel responded that Sahai had provided all documents contained in his personal files and would continue to search for additional records, and that, if any were found, Sahai would produce them. The response also stated that "[u]ntil that time the response tendered is complete. The April 3 response did not include, among other things, the requested addresses of Sahai's former employees. On April 18, 2001, Sahai's counsel sent an additional response, stating that Sahai "is seeking that his former accountant voluntarily produce [the addresses and possibly telephone numbers of the employees] from the payroll records."
On April 23, 2001, NASD sent Sahai a fourth request, again seeking the addresses of his former employees. On April 25, 2001, Sahai's counsel provided the last known address for Haas in Ridgefield, New Jersey, but stated that Sahai had not been able to locate addresses for the remaining two former employees, Patel and Marra.
...
Sahai, through counsel, responded that, "These were temporary employees for whom records were not kept other than in a computer address book program which crashed sometime in 2000. The NASD investigator testified that he contacted "411" and that no one named Haas had been listed at the address identified by Sahai.
...
On April 27, 2001, NASD sent Sahai a fifth request seeking: (1) the source from which Sahai obtained Haas's address ; (2) Social Security numbers for Haas, Patel and Marra; (3) payroll records for Sahai's former employees or an explanation of how they were paid; and (4) any employment applications for Haas, Patel, and Marra.
...
Sahai failed to provide the requested information or an explanation of why he could not provide it.
On May 10, 2001, NASD sent Sahai a written request reiterating its April 23 request for the addresses of his former employees. The May 10 request advised Sahai that, if he failed to respond, he could be subject to disciplinary action, and enclosed a copy of the relevant sanction guideline for failure to respond violations. The response date for the May 10 request was May 21, 2001. By letter dated May 10, 2001, Sahai's counsel informed NASD that Sahai could not locate the remaining addresses for his former employees. Counsel reiterated Haas's address and the fact that the computer address book had crashed . Sahai also did not provide the information requested in the April 27, 2001 request.
On May 14, 2001, NASD sent Sahai a sixth and "final" request to produce, by May 24, 2001, the documents and information NASD had requested in the April 27, 2001 request. Sahai f ailed to provide the requested information or an explanation of why he could not provide the information.
...
The NASD subsequently filed charges against Sahai and a Hearing Panel found that Sahai caused the signatures of two customers to be forged on documents, engaged in an unauthorized transaction , and failed to respond to information requests, in violation of NASD Conduct Rule 2110 and Procedural Rule 8210. The Hearing Panel dismissed an allegation that Sahai was liable for engaging in outside business activities without proper notice to his member firm. The Hearing Panel determined that a unitary sanction was appropriate for all the violations found, and it barred Sahai in all capacities and assessed costs.
On appeal, the NASD's National Adjudicatory Counsel (NAC) affirmed the findings and modified the sanctions of the Hearing Panel so that each violation was individually sanctioned. The NAC imposed a bar in all capacities for the forgery violation and a second bar in all capacities for the failure to respond violation. The NAC thought a fine of $5,000 for the unauthorized transaction violation was appropriate, but due to the imposition of the bars, declined to impose it.
Sahai appealed the NASD's decision to the SEC
...
The NASD found that Sahai forged or caused the forgery of the the Form W-9, Note Two, and the mutual fund application for Coblentz; and the 2000 Mutual Fund Application and Annuity Application in Ikonomou's name.
...
Sahai admitted completing the dealer information on both the 2000 Mutual Fund Application and Annuity Application and writing the text of Note Two. Otherwise, he denied completing any of the alleged forged documents or signing Coblentz's or Ikonomou's signatures or authorizing anyone else to do so.
Notwithstanding the NASD's finding that Sahai had profited from Coblentz's and
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