Investor Lawyers Blog

Morgan Stanley Smith Barney Employee Fined and Suspended by FINRA Over Unauthorized Signatures

Published on: September 19, 2011 | by Shepherd Smith Edwards & Kantas, LLP

The Financial Industry Regulatory Authority has imposed a 60-day suspension on Carmela L. Knieriem, a former Morgan Stanley Smith Barney female employee over allegations that while employed by the financial firm, she signed other employees’ signatures without obtaining the required approvals and authorizations. FINRA is also fining Knierem $5,000. While she has submitted a Letter of Acceptance, Waiver and Consent to settle the charges, Knierem is not denying or admitting to the findings.

According to Forbes.com, Between November 2009 and October 14, 2010, Knieriem was associated with the financial firm’s Rancho Bernardo Branch, where she was tasked with providing branch managers, financial advisers, and other employees with administrative support. Part of her job was to prepare specific internal administrative forms related to the processing and documenting of verbal requests, known as “Verbal Forms,” that were made by customers.

FINRA says that when Knieriem made the unauthorized signatures when preparing these Verbal Forms she violated FINRA Rule 2010 10 times. The SRO contends that in six instances, at the request of the financial advisor EP, she prepared an instruction form documenting a client’s verbal request for journal funds between the client’s accounts, the transfer of money from a client’s account, the release of account statements to a third party, and the issuance of a $75,397.22 check from the customer’s account. Knieriem also is said to have followed a financial advisor GT’s request to prepare an instruction form for a client’s verbal request that a stop payment be placed on one of his checks. She also followed the request of a financial adviser CL, who asked her to prepare an instruction form to issue a $95.62 for a client. Also, FINRA says that branch manager RL asked her to prepare an instruction form to journal funds between accounts.

Broker-Dealer Pacific West Securities Closes Shop

Published on: September 17, 2011 | by Shepherd Smith Edwards & Kantas, LLP

Broker-dealer Pacific West Securities is going out of business next year. The independent broker-dealer, which has about 290 affiliated advisers and reps, decided to close its doors because staying in operation is costing too much and margins are too thin.

The broker-dealer made $46 million in commission and fees in 2010 and its gross revenue for this year is expected to be $54 million. Pacific West has struck a deal with Cetera Financial Group over the transfer of many of its representatives and advisers to the latter’s subsidiary, Multi-Financial Securities Corp. The Financial Industry Regulatory Authority, however, must still approve this arrangement.

Unfortunately, dozens of independent brokers that are thinly capitalized have had to close shop or be put up for sale in the last few years. Many took huge hits in the wake of securities fraud lawsuits related to the sale of Provident Royalties LLC preferred stock, Medical Capital Holdings Inc. notes, and DBSI Inc. real estate deals. Although Pacific West didn’t sell any of these financial instruments, it has had to contend with Securities arbitration claims, including losses of nearly $1 million in FINRA arbitration awards over the last 24 months.

Investment News reported not too long ago that at least 2,500 reps have been displaced because of broker-dealers that shut down their operations. It became clear trouble was starting to brew in the industry in 2010, when Jesup & Lamont Securities Corp. and GunnAllen Financial Inc., which both have hundreds of reps, shut their doors after violating SEC rules dealing with capital. By the end of last year, there were 142 less broker-dealers than in 2009.

In February, QA3 Financial Corp. followed their lead. The broker-dealer, which worked with about 400 reps, couldn’t deal with securities lawsuits costs over the sale of allegedly fraudulent private placements.

The following month, Investors Capital Holdings Inc.’s owner Theodore E. “Ted” Charles submitted an SEC filing giving notice that he was going to sell his stake in the broker-dealer. More brokerage firms have since shuttered. FINRA says that if the broker-dealer you are working announces that it is going out of business, you should contact its offices right away to find out about next steps for you.

Our stockbroker fraud law firm represents clients that suffered losses because of broker misconduct and other formers of broker-fraud. Please contact our securities fraud lawyers and ask for your free consultation today.

B-D with 290 reps to shutter, Investment News, December 6, 2011
Broker-Dealer Pacific West to Close Its Doors, Adviser One, December 6, 2011
If a Brokerage Firm Closes Its Doors, FINRA

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Broker-Dealers are Making Reverse Convertible Sales That are Harming Investors, Says SEC, Stockbroker Fraud Blog, July 28, 2011
Holding Brokers to Investment Adviser Accountability Standards is a Bad Idea, Say Some Wall Street Executives, Stockbroker Fraud Blog, July 16, 2011
Tribune Bondholders Can Sue Shareholders for Over $8.2B, Institutional Investor Securities Blog, April 30, 2011 Continue Reading ›

Morgan Stanley Faces $1M FINRA Fine for Excessive Markups and Markdowns on Corporate and Municipal Bond Transactions

Published on: September 17, 2011 | by Shepherd Smith Edwards & Kantas, LLP

The Financial Industry Regulatory Authority has fined Morgan Stanley Smith Barney LLC and Morgan Stanley & Co. Inc. $1 million for charging excessive markdowns and markups to corporate and municipal bond transactions clients. The SRO has also ordered that the financial firm pay $371,000 plus interest in restitution to these investors. By agreeing to settle, Morgan Stanley has not denied or admitted to the securities charges.

According to FINRA, the markdowns and markups that Morgan Stanley charged ranged from under 5% to 13.8%. Considering how much it costs to execute transactions, market conditions, and the services valued, these charge were too much.

The SRO also determined that the financial firm had an inadequate supervisory system for overseeing markups and markdowns of corporate and municipal bonds. Morgan Stanley must now modify its written supervisory procedures dealing with markups and markdowns involving fixed income transactions.

FINRA Market Regulation Executive Vice President Thomas Gira has said that Morgan Stanley violated fair pricing standards. He noted is important for financial firms that sell and purchase securities to make sure that clients are given reasonable and fair prices whether/not a markdown or markup exceeds or is lower than 5%.

A Markup is what is charged above market value. It is usually charged on principal transactions involving NASDAQ and other OTC equity securities. Markups on principal transactions usually factor in the type of security, its availability, price, order size, disclosure before the transaction is effected, the type of business involved, and the general markups pattern at a firm.

A markup on an equities security that is over 5% is seldom considered reasonable or fair. Regulators have rules in place for how much registered representatives can charge customers for services rendered. Not only do the charges have to be reasonable, but also they must be fair and not show particular preferences to any clients.

The 5% policy also applies to agency transactions. Commissions for such transactions also must be “fair and reasonable.” Commissions that go above that must be justified and are often closely examined by regulators.
While most securities professionals are committed to doing their jobs fairly and ethically, there are those determined to take advantage of the system to defraud investors. There are also honest mistakes that can occur that also can result in investor losses.

Financial firms and their representatives are responsible for protecting investors and their money from unnecessary losses resulting from securities fraud or other negligence.

Morgan Stanley Fined $1M Over Muni-Bond Markups, Bloomberg, November 10, 2011

More Blog Posts:
Whistleblower Claims SEC is Illegally Destroying Records of Closed Enforcement Cases, Institutional Investor Securities Blog, August 31, 2011

Ex-Bank of America Employee Pleads Guilty to Mortgage Fraud Scam Using Stolen Identities to Buy Homes Not For Sale, Institutional Investor Securities Blog, August 30, 2011

Securities Lawsuits Expected to Reach Record High in ’11, Says Advisen Ltd. Report, Institutional Investor Securities Blog, April 23, 2011

**This blog has been backdated.

Five Broker-Dealers Fined by FINRA Over Allegedly Misrepresenting Commissions as Fees to Clients

Published on: September 16, 2011 | by Shepherd Smith Edwards & Kantas, LLP

The Financial Industry Regulatory Authority has issued fines against broker-dealers Pointe Capital, Inc., John Thomas Financial, First Midwest Securities, Inc., A&F Financial Securities, Inc., and Salomon Whitney LLC for allegedly mischaracterizing part of their commission charges to clients and calling them service handling fees, This caused the amount of total commissions that clients were charged to be understated. As a result, the fees for handling-related services ended up costing clients more.

FINRA says trade commissions and fee schedules should clearly reflect the actual commission charges, which shouldn’t be disguised.

Among the sanctions issued by FINRA:

• A $60,000 fine against Salomon Whitney LLC. FINRA accused the financial firm is accused of charging clients handling service fees of up to $69.95/trade plus commission. FINRA contends that Salomon Whitney did not tell its Connecticut clients that part of the transactional handling fee was a profit to the financial firm, the fee was not determined by the costs of handing a specific transaction, and certain clients were fined lower fees. FINRA believes the handling fee charged by Salmon Whitney was unreasonable. By agreeing to settle, the financial firm is not denying or admitting to the findings.

• First Midwest Securities, Inc. was fined $150,000. The financial firm is accused of charging clients up to $99.75/trade plus commission. FINRA says that this “handling fee” was in fact a commission and not reasonably connected to any direct handling services conducted by First Midwest Securities. The SRO notes that some customers even paid handling fees that were double of what other First Midwest Clients paid. FINRA also says that First Midwest Securities committed other violations, including having inadequately written supervisory procedures and “unfair and unreasonable” markdowns and markups. The financial firm has settled the securities case but is not admitting to or denying FINRA’s allegations.

• FINRA charged A&F Financial Securities, Inc. a $125,000 fine for charging clients an up to $65/trade handling fee, as well as commission. FINRA says that A & F acted inaccurately and improperly. FINRA also accused the financial firm of failing to comply with continuing education requirements, having inadequate supervisory system and procedures, and not properly assessing its training needs or developing and executing a written training plan. A & F also admitted to the findings without denying or admitting to them.

• FINRA fined John Thomas Financial A $275,000 fine for its up to $75/trade handling fee plus commissions. The SRO is also alleging other violations, including deficiencies related to complaint reporting, supervisory controls and certifications, and branch office supervision and recordkeeping. FINRA says the broker-dealer effected key changes to its business without obtaining its approval. John Thomas Financial agreed to settle but did not deny/admit to the findings.

• Pointe Capital, Inc. was fined $300,00 for charging an up to $95//trade handling fee plus commission. FINRA contends that seeing as the “handling” charge wasn’t reasonably linked to actual handling-related services/expenses, the clients were actually charged another commission. Pointe Capital has settled the case.

FINRA Fines Five Broker Dealers for Improper Handling Fees, FINRA, September 7, 2011

More Blog Posts:
FINRA Tells Congress It Is Ready to Act as SRO for Investment Advisor, Stockbroker Fraud Blog, September 13, 2011
Financial Industry Regulatory Authority Alerts Investors About Gold Stock Scams, Stockbroker Fraud Blog, August 25, 2011
Wedbush Ordered By FINRA Panel To Pay $3.5M to Trader Over Withheld Compensation, Stockbroker Fraud Blog, July 16, 2011 Continue Reading ›

President Obama Supports Senate Bill Raising SEC Registration Exemption to $50M

Published on: September 16, 2011 | by Shepherd Smith Edwards & Kantas, LLP

President Barack Obama says he supports Senate bill, S. 1544, which would let companies sell up to $50 million in securities in a public offering without having to register with the SEC. That’s a huge leap from the current $5 million threshold that is allowed under Regulation A of the 1933 Securities Act.

Called the Small Company Capital Formation Act, Senators Jon Tester (D-Mont.) and Pat Toomey (R-Pa.) introduced the bill earlier this month. If passed, Tester said it would relieve some regulatory burdens. S. 1544 is almost identical to H.R. 1070, which Rep. David Schweikert (R-Ariz.) introduced in the House earlier this year.

Senator Tester says that the new rule will help entrepreneurs create jobs and raise additional capital. Greater transparency of offers would also be enhanced, giving investors access to more information. On his Web site, Tester speaks about the need to do everything possible to push for “innovation, entrepreneurship, and job creation.” Tester says the bill streamlines new companies’ ability to be successful and have the capital they need for growth. With this capital, they can concentrate on succeeding rather than getting mired in “government paperwork.” Senator Pat Toomey has the Small Company Capital Formation Act will make it easier for small companies and start-ups to go public.

Meantime, Republican lawmakers have introduced a series of job bills that could also affect securities laws. The Entrepreneur Access to Capital Act, H.R. 2930, exempts crowdfunding from the 1933 Securities Act‘s registration requirements for business individuals who invest under $10,0000 or under 10% of their annual income and companies that raise under $5 million. In his jobs plan, President Obama has also said that he supports this proposed measure.

Other Republican Bills:
H.R. 2930: Introduced by Rep. Patrick McHenry (R-N.C.), this bill would exclude crowdfunding from the 500 shareholder cap of the 1934 Securities Exchange Act, while preempting state regulation. McHenry said that if passed the bill would give smaller investors a chance to get into startups, which they currently cannot do because of current SEC regulation.

S. 1538: Known as the Regulatory Time-Out Act, this bill would set up a one-year moratorium on key regulations with a $100 million or greater yearly effect on the economy.

Access to Capital for Job Creators Act: Introduced by GOP whip Rep. Kevin McCarthy (R-Calif.), the bill would get rid of the SEC’s current ban on general solicitation. Currently, the Commission’s Section 4(2) of the 1933 Act or its Rule 506 of Regulation D doesn’t let private placement issuers use general solicitation or advertising to get investors to put money in their offerings. McCarthy believes that this ban keeps small companies from being able to draw in capital that they need.

Our securities fraud attorneys are here to help investors that have been victims of financial fraud recoup their losses.

American Jobs Act, White House, September 8, 2011

More Blog Posts:
Wedbush Securities Ordered by FINRA to Pay $2.8M in Senior Financial Fraud Case Over Variable Annuities, Stockbroker Fraud Blog, August 31, 2011

FDIC Objects to Bank of America’s Proposed $8.5B Settlement Over Mortgage-Backed Securities, Stockbroker Fraud Blog, August 30, 2011

SEC Looking at Other Ways to Communicate with Whistleblowers

Published on: September 14, 2011 | by Shepherd Smith Edwards & Kantas, LLP

According to Sean McKessy, who is in charge of the Securities and Exchange Commission’s Office of the Whistleblower, the agency is exploring the best ways to communicate with whistleblowers and their lawyers. McKessy spoke as part of a TheCorporateCounsel.net—sponsored webcast panel on whistleblower issues.

Right now, the office is adhering to the communications policies of the SEC’s enforcement division. However, McKessy said that the Whistleblower Office is in the process of coming up with “communicating best practices,” documenting interactions, and developing internal policies and procedures. Proper documentation would hopefully ensure that the necessary information, and the extent that the whistleblower cooperated, are properly recorded so that this information can be presented in the event there is a claim.

The SEC’s whistleblower office is also working on its yearly report to Congress about the progress the program has made, as well as its the investor protection fund that provides whistleblowers who come forward with their financial reward with compensation.

David Becker, who is a former SEC general counsel and was also a co-panelist, spoke about companies considering whether to self-report internal problems. Becker noted that there is greater incentive to self-report when there is a possibility that an employee might go to the SEC first. However, he pointed out that companies considering self-reporting would have to take into consideration how revealing specific information could impact them, as there is certain information that he SEC “will not be able to walk away from.”

Meantime, many companies are now using certification forms. These request employees to notify a company about unethical or unlawful behavior that they observe. McKessey, however, cautioned that unless the forms are properly worded and constructed, they might affect the employee’s ability to come forward to the SEC. That said, he did push for companies to move towards developing systems that allow for the reporting of wrongdoing. As long as an employee fears reprisal and punishments for stepping forward there is a greater likelihood that they won’t say anything.

The whistleblower bounty program is supposed to provide employees that come forward with certain protections. However, a worker can still be fired for company policy violations and poor performance as long an employer provides proper documents showing that the termination would have happened regardless of whether or not the employee was a whistleblower.

Whistleblower Complaints
A whistleblower that steps forward to voluntarily report possible violations of federal securities laws may be entitled to part of the damages collected by the government from the responsible parties. That percentage of the award is 10-30%.

To receive this money, the information provided by the whistleblower must be original and has to result in a successful SEC action ending in an order of monetary sanctions above $1 million.

Stockbroker Fraud
Our securities fraud lawyers are here to help our investor clients recoup their losses.

Office of the Whistleblower, SEC

Whistleblower Lawsuit Claims Taxpayers Were Defrauded When Federal Government Bailed Out Houston-Based American International Group in 2008, Stockbroker Fraud Blog, May 5, 2011

SEC is Finalizing Its Whistleblower Rules, Says Chairman Schapiro, April 28, 2011

Whistleblower Claims SEC is Illegally Destroying Records of Closed Enforcement Cases, Institutional Investor Securities Blog, August 31, 2011

FINRA Tells Congress It Is Ready to Act as SRO for Investment Advisors

Published on: September 13, 2011 | by Shepherd Smith Edwards & Kantas, LLP

Speaking before a House Financial Services Committee, Financial Industry Regulatory Authority Chief Executive Richard Ketchup said that the self-regulatory organization is ready to set up a new entity to oversee investment advisers and make sure they are in compliance with federal securities laws. Ketchum also said the SRO would hire experienced staff to do the job and that regulatory oversight to tailored to investment advisers would be put into place.

Currently, the Securities and Exchange Commission is the watchdog for investment advisers. Staffing issues, however, prevent the commission from doing a thorough and frequent job-checks are about once every 11 years. Last year, the SEC was only able to examine 9% of all registered investment advisers.

Yet there are many in the financial industry that have expressed a preference for this status quo, or, if change has to happen, they would like state regulators to do the job. Some have expressed worry that FINRA would uphold investment advisers to rules more that applicable to broke-dealers. Others are not sure that the SRO is up to the task. Many are still not happy with FINRA’s performance as a financial industry watchdog prior to financial crisis. (It is important to note that FINRA has taken some responsibility for not discovering the Bernard Madoff Ponzi scam earlier.)

Man Allegedly Involved in Texas Securities Fraud Scam that Bilked Over 7,000 Deaf Investors of $3.45M is Charged by the SEC

Published on: September 12, 2011 | by Shepherd Smith Edwards & Kantas, LLP

The Securities and Exchange Commission has charged Jody Dunn with fraud. Dunn is accused of soliciting $3.45 million from over 7,000 deaf investors in a Texas securities scam. He is also deaf. According to the SEC, he engaged in material misrepresentations, the fraudulent and unregistered offering and selling of securities, and the misappropriation of investor funds.

Per the commission, Dunn told investors he would place their money with Imperia Invest IBC, which guaranteed returns of 1.2% a day. He solicited investments for Imperia between August 2007 and July 2010.

While he did send the send the remaining funds to the Imperia-owned offshore accounts, he never confirmed that the financial firm was really investing the money-even though he allegedly knew that Imperia lost investor funds and wasn’t properly crediting clients’ accounts. Dunn also never paid investors the interest they were owed and he failed to tell them that his fee was more than 10% of the money he collected from them.

Last year, the SEC charged Imperio with involvement in a $7 million fraud scam and secured a court order freezing the internet-based firms assets. The SEC claims that Imperia defrauded approximately 14,000 investors, who were told that they could only obtain their money by paying a few hundred dollars for a Visa debit card. Apparently, however, the financial firm did not have ties Visa and it never paid any money back to its victims.

In the commission’s complaint against Dunn, it is accusing him of making a number of misrepresentations to investors including:

• Claiming he would help them get into Traded Endowment Policies (viatical settlements) by having them invest through Imperia even though none of their money was used to buy TEPs.

• Claiming he knew the people behind Imperia even though he had never met anyone affiliated with the financial firm.

• Not being able to give an accurate analysis of the way he calculated profits or fees.
.
TEPs or Viatical Settlements
With TEPs, the insurance policy owner sells the policy before it matures. These are sold at a discount but in an amount greater than the current cash surrender value. All beneficial obligations then go to the new owner. Investors of the Imperia-offered TEP investments had to put in at least $50 for an $80,000 loan from a foreign bank. The funds were then supposed to go toward buying a TEP. The SEC is accusing Dunn of violating sections of the Securities Act and sections of the Exchange Act and Rule 10b-5 thereunder.

SEC Charges Solicitor in Investment Scheme Targeting Deaf Community, SEC, September 9, 2011
Texan defrauded deaf investors out of $3.45M, Investment News, September 12, 2011
Read the SEC Complaint (PDF)

SEC Charges Internet Company With Defrauding the Deaf, New York Observer, October 7, 2010

More Blog Posts:
Morgan Keegan & Company Ordered by FINRA to Pay $555,400 in Texas Securities Case Involving Morgan Keegan Proprietary Funds, Stockbroker Fraud Blog, September 6, 2011
Texas Minister Pleads Guilty to Involvement in $7.2M “White Hat Guys” Securities Fraud that Bilked Thousands of Petro America Corporation Investors in the US and Canada, Stockbroker Fraud Blog, June 21, 2011
Alleged $800 Affinity Fraud Scheme Prompts SEC to Sue GTF Enterprises and Its Money Manager, Stockbroker Fraud Blog, June 4, 2010 Continue Reading ›

SEC Spent $100K More Than Necessary By Failing to Follow Office of Personnel Management Guidelines In Director’s Hiring

Published on: September 10, 2011 | by Shepherd Smith Edwards & Kantas, LLP

According to the Office of the Inspector General, by failing to abide by its own practices when hiring Henry Hu as Division of Risk director, as well as the guidelines provided by the Office of Personnel Management, the Securities and Exchange Commission unnecessarily spent $100,000. Details of these findings were provided in a report released by the SEC late last month.

The “unprecedented arrangement” with Hu covered his living expenses in DC when he worked as an SEC division director between 9/09 through 1/11. He is now back at work as a professor at the University of Texas Law School.

Specifically faulted over this matter was ex-SEC Executive Director Diego Ruiz, who the Office of Personnel Management said was the person mainly responsible for the offer to cover Hu’s living costs while he worked for the Commission. Ruiz, who has resigned from the agency, was also allegedly involved in the SEC’s misuses of its independent leasing authority. Because Ruiz is no longer with the agency, no disciplinary action will be taken against him.

Claimant Not Only $100K Loses Securities Arbitration Case Against Citigroup Global Markets But Gets Stuck with Financial Firm’s $50K in Legal Bills

Published on: September 9, 2011 | by Shepherd Smith Edwards & Kantas, LLP

Alphonse M. Lucchese, a CitiSmith Barney customer, has not only lost his $100,000 securities claim against the financial firm in Financial Industry Regulatory Authority arbitration, but he also now must pay for Citigroup‘s $49,985 in attorney fees. The case is Alphonse M. Lucchese, Claimant, v. Citi Smith Barney, Citigroup Global Markets, Inc., Robert Joseph Malenfant, and Alfred George Weaver, Respondents.

Lucchese had originally filed a securities fraud lawsuit in Middlesex Superior Court of Massachusetts. The case was later dismissed and sent to arbitration.

Lucchese claims Smith Barney stockbroker Weaver, who is a Respondent, recommended that he buy 4,000 shares of Lehman preferred. Despite his reservations-including concerns about the stock and how they compared with other companies’ shares-Lucchese “reluctantly agreed” and at $25/share spent $100,000.

The stock initially dropped 20%-a $20,000 drop in value. The Claimant says that Weaver told him to hold on to his stock. When the financial markets collapsed, Lucchese’s stocks’ worth then dropped by 63%. He says that when he told Weaver to sell the position even though it meant losing $63,000, the broker recommended that the Claimant still hold on to his shares and that Lehman was not going to fail… only it did. Lucchese’s shares then became worthless when Lehman filed for bankruptcy.

While Weaver acknowledged making a mistake by not selling Lucchese’s stock, the Respondent claims that the Claimant never ordered him to sell. Lucchese disputes this account.

The arbitrator, when ruling on the case, decided that there was lack of credible evidence supporting Lucchese’s claim. He also found that Weaver acted on “good faith” when he advised Lucchese not to sell prior to Lehman filing for bankruptcy and that the broker would have no way of knowing that this would happen.

Lucchese’s claims of securities fraud, including breach of fiduciary duty, breach of contract, negligence, failure to supervise, violations of federal and state securities laws, and other violations were denied in their entirety. In addition, the arbitrator determined that the Claimant should be responsible for Citigroup’s legal fees of $49,985, $3,150 in arbitration forum fees, and $400 for the explained decision.

Most securities cases must be resolved in arbitration and you want to make sure you are represented by experienced stockbroker fraud lawyers to increase your chances of recouping your losses. A securities claim is not the type of case you want to handle on your own.

Citi Smith Barney Customer Sues Over 2008 Failure to Sell Lehman Shares, Forbes, December 18, 2011

More Blog Posts:
Citigroup Global Markets Inc. Sues Two Saudi Investors in an Attempt to Block Their FINRA Arbitration Claim Over $383M in Losses, Stockbroker Fraud Blog, October 22, 2011
Citigroup Global Markets Fined $500,000 by FINRA for Inadequate Supervision of Broker Accused of Bilking Sick and Elderly Investors, Stockbroker Fraud Blog, August 16, 2011
Citigroup to Pay $285M to Settle SEC Lawsuit Alleging SecuritiesFraud in $1B Derivatives Deal, October 20, 2011
**This post has been backdated for publication.
Continue Reading ›