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(CRD No. 43678)

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   No. ST-09-7625-S

WHEREAS, the Banking Commissioner (the “Commissioner”) is responsible for administering Chapter 672a of the Connecticut General Statutes, the Connecticut Uniform Securities Act (the “Act”) and Sections 36b-31-2 et seq. of the Regulations of Connecticut State Agencies (the “Regulations”) promulgated under the Act;

WHEREAS, Williams Trading, LLC (“WTLLC”) of 860 Canal Street, Third Floor, Stamford, Connecticut is a registered broker-dealer under the Act;

WHEREAS, the Commissioner, through the Securities and Business Investments Division (the “Division”) of the Department of Banking has conducted an examination of WTLLC’s records pursuant to Section 36b-14(d) of the Act and Section 36b-31-14f of the Regulations, and a related investigation under Section 36b-26 of the Act to determine whether WTLLC had violated, was violating or was about to violate any provision of the Act or any regulation or order under the Act;

WHEREAS, the Commissioner, as a result of such examination and investigation, alleges that 1) in March 2007 and May 2007, two individuals became registered as agents of WTLLC under the Act; 2) on May 29, 2007, WTLLC filed with the Commissioner a Form U-5 terminating the Connecticut agent registrations of the two individuals; 3) on June 12, 2008, the two individuals each reapplied for registration as an agent of WTLLC under the Act, and have since become registered as agents of the firm; and 4) from at least May 2007 to June 2008, WTLLC employed the two individuals as agents at a time when such individuals were not registered under Section 36b-6(a) of the Act;

WHEREAS, WTLLC maintains that the May 29, 2007 Form U-5 filings made for the two individuals were submitted in error;

WHEREAS, upon being apprised by the Division that agent registration was required, WTLLC filed a Form U-4 on June 12, 2008 seeking to register both individuals as agents under the Act.  Such registrations have since been made effective;

WHEREAS, Section 4-177(c) of Chapter 54 of the Connecticut General Statutes permits the resolution of a contested case by stipulation or agreed settlement;

WHEREAS, WTLLC desires to settle the matters described herein and voluntarily enters into this Stipulation and Agreement, acknowledging that this Stipulation and Agreement is in lieu of any court action or administrative proceeding adjudicating any issue of fact or law on the matters described herein;

WHEREAS, WTLLC, through its execution of this Stipulation and Agreement, voluntarily waives any rights it may have to seek judicial review or otherwise challenge or contest the terms and conditions of this Stipulation and Agreement;


No later than the date this Stipulation and Agreement is executed by the Commissioner, WTLLC shall remit to the department by check made payable to “Treasurer, State of Connecticut” the sum of two thousand dollars ($2,000), one thousand, five hundred dollars ($1,500) of which shall constitute an administrative fine, and five hundred dollars ($500) of which shall represent reimbursement for past due agent registration fees and the costs associated with the Division’s investigation of this matter;
WTLLC shall comply with all statutory requirements governing the registration of affected personnel as broker-dealer agents, and shall review, revise and implement such supervisory and compliance procedures as are necessary to ensure such compliance;
(3) Execution of this Stipulation and Agreement by the Commissioner is without prejudice to the right of the Commissioner to take enforcement action against WTLLC based upon a violation of this Stipulation and Agreement or the basis for its entry if the Commissioner determines that compliance is not being observed with the terms hereof or if any representation made by WTLLC and reflected herein is subsequently determined to be untrue; and
(4) This Stipulation and Agreement shall become binding when executed by all parties hereto.

IN WITNESS WHEREOF, the undersigned have executed this Stipulation and Agreement on the dates indicated.

   Howard F. Pitkin
            Banking Commissioner

Dated at Hartford, Connecticut                 
this 19th day of March 2009.                         

I, David B. Williams, state on behalf of Williams Trading, LLC, that I have read the foregoing Stipulation and Agreement; that I know and fully understand its contents; that I am authorized to execute this Stipulation and Agreement on behalf of Williams Trading, LLC and that Williams Trading, LLC agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein.

      Williams Trading LLC

       David B. Williams

On this 6th day of March 2009, personally appeared David B. Williams, signer of the foregoing Stipulation and Agreement, who, being duly sworn, did acknowledge to me that he was authorized to execute the same on behalf of Williams Trading, LLC, and acknowledged the same to be his free act and deed, before me.

Notary Public/Commissioner of the Superior Court
My Commission Expires:  June 30, 2009

Administrative Orders and Settlements