Both were suspended from association with any FINRA member in any capacity for 90 days. Nouchi and Winters were also fined $10,000 and $19,882, respectively. The NAC imposed the sanctions following an appeal of an OHO decision. The sanctions were based on findings that Nouchi and Winters caused their member firms’ books and records to contain inaccurate information about customers selling Class B mutual fund shares by entering sales charge waivers for those customers that falsely represented that these customers were disabled.

Nouchi’s suspension is in effect fromOctober 5, 2009, through January 2, 2010, and Winters’ suspension is in effect fromSeptember 21, 2009, through December 19, 2009.

(FINRA Cases #E102004083705/E102004083704)