Never heard of them.  Where are they?

www.bkst.com

Irvine, CA

I checked your web site, and noted your comment:

"Comment from Bill Singer:
  Compare Appell/Swicker with Brookstreet.  We see an emerging trend in which NASD is holding principals personally responsible for the alleged failures to maintain reasonable procedures.  Nonetheless, these prosecutions always raise a troubling questions.  When a firm applies for membership, it is required to submit Written Supervisory Procedures (WSPs).  The WSPs are presumably reviewed and approved by the Staff pursuant to approving the applicant's membership.  Further, during every ensuing examination the Staff normally reviews the WSPs.  What many industry veterans cite with frustration is the NASD's frustrating (if not infuriating) practice of suddenly discovering the inadequacy of WSPs that were previously reviewed by the Staff and not deemed in violation.  Similarly, the age-old call for a standard WSP still goes unheeded.  Yes, the regulators say that one-size cannot fit all and that the WSPs must be tailored to each firm.  However, compliance veterans rarely buy that line. "