Sisung Investment Management Services Llc

Allegations: NASD ALLEGED VIOLATIONS OF MSRB RULES G-8, G-9, G-17, G-37(B), G-37(C), G-37(D), AND G-37(E). Status: Final Sanction Detail: SSC FINED $10,000 FOR REPORTING RULE G37(E)& SSC AND LARRY J. SISUNG, JR. FINED JOINTLY AND SEVERALLY $10,000 FOR RECORDKEEPING RULES G-8 AND G-9. Summary: BASED ON PRIOR LEGAL ADVICE, AFFILIATES OF THE FIRM SSC MADE LEGAL POLITICAL CONTRIBUTION TO LA STATE OFFICIALS, A SMALL NUMBER OF WHOM SAT ON THE LA BOND COMMISSION (BC). THE BC IS NOT INVOLVED IN HIRING OF MFP'S, BUT BY LA CONSTITUTION REVIEWS ALL LA MUNICIPALITIES' DEBT FOR LEGALITY AND FINANCIAL FEASIBILITY. THE NASD TOOK A POSITION THAT THE CONTRIBUTIONS INVOKED A 2 YEAR BAN ON MUNICIPAL BUSINESS BY SSC FOR ALL LA MUNICIPALITIES. SSC AND LARRY SISUNG OPPOSED THE NASD'S POSITION AND THE SEC DISAGREED WITH THE NASD IN A FINAL ACTION AND FOUND THAT THEIR WAS NO EVIDENCE THAT THE CONTRIBUTIONS ACTUALLY INFLUENCED THE AWARDING OF MUNICIPAL SECURITIES BUSINESS AND THAT THEIR WERE NO VIOLATIONS OF THE PAY TO PLAY PROVISIONS OF RULE G-37(B), (C), OR (D) OR RULE G-17. IN A RELATED MATTER THE SEC HELD THAT SSC DID VIOLATE RECORDKEEPING (G-37(E)) AND REPORTING REQUIREMENT (G-8 & G-9) FOR WHAT THE NASD HEARING PANEL FOUND AS "GOOD FAITH" AND "NON-EGREGIOUS" VIOLATIONS. SSC CONTINUES TO BELIEVE IT COMPLIED WITH THE RULES AS WRITTEN AND WITH REGARDS TO THOSE VIOLATIONS THE SEC RECOGNIZED THE NASD'S FINDING OF THE "ABSENCE OF CULPABLE INTENT, THE ABERRNANT NATURE OF THE FIRM'S MISCONDUCT AND THE FIRM'S REGULATORY COOPERATION TO BE MITIGATIVE."