Win Capital Corp. (CRD #36172, Bayville, New York) received a censure and fine of $21,500. According to the findings, the firm served as placement agent for a "minimum-maximum" "best-efforts" private placement offering of securities and, during the contingency period of the offering. While doing so, the firm failed to ensure that the money or other consideration it received was promptly transmitted to a bank that had agreed in writing to hold such funds in escrow for the persons who had the beneficial interests therein, and to transmit or return such funds directly to the persons entitled thereto when the appropriate event or contingency had occurred. The firm accepted the fine and censure but did not admit or deny the accusations. (NASD Case #CLI020010)
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