CREWS & ASSOCIATES, INC.
A consent order entered in connection with Crews & Associates, Inc.’s role as the placement agent for and its sale of debentures issued by Bamco Gas, LLC, finding the following violations of the Arkansas Securities Act, the Rules of the Arkansas Securities Commissioner, and relevant rules of the Financial Industry Regulatory Authority: 1) NASD Conduct Rule 2310 (Recommendations to Customers – Suitability), Ark. Code Ann. § 23-42-308(a)(2)(G), and Rules 308.01(d) and (x) regarding Crews’ failure to conduct a reasonable due diligence investigation into the Bamco debenture offerings, rendering the Bamco debentures not suitable for at least some customers under a reasonable-basis suitability analysis; 2) Ark. Code Ann. § 23-42-308(a)(2)(G) and Rule 308.01(y) for Crews’ failure to disclose certain information about Bamco, Bamco’s control persons, and the Bamco Debentures; and 3) NASD Conduct Rule 3010 (Supervision), Ark. Code Ann. § 23-42-308(a)(2)(G) and (J), and Rule 308.01(x) for failure to enforce a supervisory system reasonably designed to enable Crews and its agents to achieve compliance with applicable securities laws, rules, and regulations in the sale of the Bamco debentures.