The allegations read: Sec administrative proceeding release 34-19876; the commission deems it appropriate that public proceedings be instituted pursuant to sections 15(b) and 19(h) of the securities exchange act of 1934 ("exchange act") with respect to a broker dealer ("registrant")and its principals to determine whether the registrant willfully violated and whether kowal willfully aided and abetted violations of sections 15(c)(3) and 17(a) of the exchange act and rules 15c3-1, 15c3-3 and 17a-3 thereunder.
