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STATE OF
OFFICE OF SECURITIES
121 STATE
HOUSE STATION
CONSENT AGREEMENT
No. 06-061-CAG
This Agreement is entered into between the State of Maine Office
of Securities (“the Office”) and CitiStreet Advisors
LLC (“CitiStreet”) (CRD #3989).
WHEREAS, the parties agree as follows:
1.
CitiStreet is a limited liability company formed under the laws of
2.
Since
September 25, 2000, CitiStreet has been registered as
an investment adviser with the United States Securities and Exchange Commission
(the “SEC”) and, since July 8, 2004, properly notice-filed with the Office.
32 M.R.S.A. §§10305-A, 16405.
3.
Under
§10304(2-A) of the Revised
4.
From
September 30, 2002, until December 31, 2005, it was unlawful under the Revised
Act for an investment adviser exempt from licensing under §10304(2-A) to employ
or contract with an individual as its investment adviser representative in Maine
unless the representative was licensed or unless the investment adviser was otherwise
exempt from licensing under the Revised Act. 32 M.R.S.A. §10303(4).
5.
Since
December 31, 2005, it has been unlawful under the Uniform Act for an investment
adviser to employ or associate with an individual required to be licensed as an
investment adviser representative who transacts business in Maine on behalf of
the investment adviser unless the individual is licensed or exempt from licensing.
32 M.R.S.A. §16403(4).
6.
It
is the Office’s position that CitiStreet employed at
least three individuals as investment adviser representatives while their license
applications were pending but without each one being properly licensed as an investment
adviser representative in
7.
CitiStreet has represented to the Office that it was not the firm’s intention
to violate either the Revised Act or the Uniform Act.
8.
All
parties desire an expeditious resolution of this matter.
NOW, THEREFORE, without trial or adjudication of
any issue of fact or law, and without CitiStreet admitting
or denying that its conduct violated the Revised Maine Securities Act or the Maine
Uniform Securities Act, it is agreed that:
1.
CitiStreet will comply with all licensing and other legal requirements
governing persons acting as investment advisers in the State of Maine at all times
from the date hereof;
2.
In
lieu of the Office seeking the imposition of a penalty for the allegations contained
herein, CitiStreet will pay the sum of $4,500 to the
Office upon CitiStreet’s execution of this Agreement;
and
3.
The
Office will not take further action against CitiStreet
based solely upon the unlicensed status of the three individuals during the period
preceding and including the date of execution of the Agreement, PROVIDED, however, that this paragraph
applies only to the unlicensed activity previously disclosed to the Office by
CitiStreet.
August
14, 2006
s/Raymond Martin, President
Date
Raymond Martin, President
CitiStreet Advisors, LLC
August
17, 2006
s/Michael J. Colleran
Date
Michael J. Colleran
Securities Administrator
Reviewed by:
August
16, 2006
s/Bonnie E. Russell
Date
Bonnie E. Russell
Assistant Securities Administrator
Presented by:
August
16, 2006
s/Cathy J. Williams
Date
Cathy J. Williams
Investigator/Examiner