For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority (?FINRA?) and without admitting or denying the findings, prior to a regulatory hearing and without an adjudication of any issue, Judith Martin submitted a Letter of Acceptance, Waiver and Consent (?AWC?), which FINRA accepted.

In the Matter of Judith Martin, Respondent (AWC 2010023584301, February 2, 2012).