James Earl Williams, of Boca Raton, Florida, a stockbroker registered with Newbridge Securities Corporation, was the subject of a customer initiated investment related Financial Industry Regulatory Authority (FINRA) securities arbitration claim that was settled for $5,000.00 in damages based upon alleged breach of fiduciary duty, violation of state securities laws, and breach of contract when…
Michael Charles Grande of Fort Lauderdale, Florida, a stockbroker registered with Newbridge Securities Corporation, has been charged by Financial Industry Regulatory Authority (FINRA) in a Complaint alleging that Grande failed to cooperate with a FINRA investigation into his mutual fund recommendations. Department of Enforcement v. Michael Charles Grande, Disciplinary Action No. 2018060128401 (April 24, 2024)….
Philip Andrew Gibson, of Boca Raton, Florida, a stockbroker registered with Newbridge Securities Corporation, was the subject of a customer initiated investment related Financial Industry Regulatory Authority (FINRA) securities arbitration claim that was settled for $65,000.00 in damages based upon allegations that Gibson defrauded the customer, violated securities laws, breached his fiduciary duties, was negligent,…
John Gerard Forrester Jr., of Boca Raton, Florida, a stockbroker registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer requested $200,000.00 in damages based upon allegations that Forrester breached his fiduciary duties, committed fraud, was negligent, and breached contract in connection with…
Richard S. Siminou of New York, New York, a stockbroker previously associated with Newbridge Securities Corporation, has been fined $5,000.00 and suspended for four months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Siminou engaged in excessive and unsuitable trading during the time that he was associated with Newbridge…
Douglas Blake Solinsky of New York, New York, a stockbroker registered with Newbridge Securities Corporation, has been fined $10,000.00 and suspended for four months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Solinsky engaged in excessive and unsuitable trading. Letter of Acceptance, Waiver, and Consent No. 2019064511203 (June 29,…
Betsy Lou Whipple of Hiko, Nevada, a stockbroker registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer requested $500,000.00 in damages based upon allegations that Whipple breached a contract, made misrepresentations and omissions of material fact, and breached her fiduciary duties, and…
Michael Leonard Whitaker (also known as Mike Leonard Whitaker), of The Villages, Florida, a stockbroker registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer requested $70,000.00 in damages based upon allegations that Whitaker breached his fiduciary duties, breached a contract, was negligent,…
William Lapiana (also known as Bill Lapiana), of New York, New York, a stockbroker registered with Newbridge Securities Corporation, was the subject of a customer initiated investment related FINRA securities arbitration claim that was settled for $14,999.00 in damages based upon allegations that Lapiana made unsuitable investment recommendations, made misrepresentations of material fact, and failed…
Dana H. Davis of Hauppauge, New York, a stockbroker registered with Newbridge Securities Corporation, has been suspended for twelve months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Davis made unsuitable recommendations and inappropriately advised customers regarding margin. Letter of Acceptance, Waiver, and Consent No. 2019064511202 (March 31, 2023)….
Newbridge Securities Corporation, a securities broker dealer headquartered in Boca Raton, Florida, has been censured and fined $50,000.00 by Financial industry Regulatory Authority (FINRA) because Newbridge Securities Corporation failed to supervise certain representatives in connection with the recommendation and sale of LJM Preservation and Growth Fund. Letter of Acceptance, Waiver, and Consent No. 2019061764901 (March…
John Eugene Egan of Boca Raton, FL, a stockbroker registered with Newbridge Securities Corporation, was the subject of a customer initiated investment related FINRA securities arbitration claim that was settled for $20,000.00 in damages based upon allegations that Egan breached his fiduciary duties, breached a contract, and was negligent in connection with the recommendation and…
Peter Lewis Goffin of Boca Raton, FL, a stockbroker registered with Newbridge Securities Corporation, was the subject of a customer initiated investment related FINRA securities arbitration claim that was settled for $32,500.00 in damages based upon allegations that Goffin committed fraud, made unsuitable recommendations, breached a contract, and breached his fiduciary duties in connection with…
Frank Louis Avallone of New York, NY, a stockbroker registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer requested compensation based upon allegations that Avallone made unsuitable recommendations, breached his fiduciary duties, committed fraud, and violated FINRA rules in connection with the…
Mitchell Scott Biernick of Freeport, New York, a stockbroker registered with Arive Capital Markets, has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Biernick failed to testify during the time that FINRA investigated the stockbroker for possible violations of FINRA rules. Letter of Acceptance, Waiver, and Consent…
John Richard Boatright of Duluth, Georgia, a stockbroker formerly registered with Newbridge Securities Corporation, has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Boatright failed to respond to FINRA’s request for information in connection with the investigation of Boatright’s sales practices. FINRA Enforcement No. 2021071440501 (Jan. 18,…
Dustin Paul Shafer of Springfield, Illinois, a stockbroker formerly registered with Newbridge Securities Corporation, is referenced in a customer initiated investment related FINRA securities arbitration claim which was settled for $45,000.00 in damages founded on accusations that the customer was placed into unsuitable direct participation program interests or limited partnership interests when Shafer was employed…
Marshall Owen Isaacson of Boca Raton, Florida, a stockbroker formerly registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related FINRA arbitration claim where the customer sought $75,000.00 in damages founded on allegations of negligence, breach of contract, and breach of fiduciary duty by Isaacson in regard to alternative investment transactions,…
Austin Richard Dutton Jr. (also known as Austin Richard Duttin), of Doylestown, Pennsylvania, a stockbroker formerly registered with Newbridge Securities Corporation, is referenced in a customer initiated investment related FINRA securities arbitration claim in which the customer sought $100,001.00 in damages based upon allegations that Dutton breached a fiduciary duty and breached a contract relating…
David Stewart Silberg of Melville New York a stockbroker formerly registered with Aegis Capital Corporation is the subject of a customer initiated investment related FINRA securities arbitration claim where the customer requested $50,000.00 in damages supported by accusations that the customer had been placed into unsuitable structured products between September of 2015 and June of…
Stephen James Sullivan (also known as Stephen Sullivan) of New York New York a stockbroker formerly registered with Newbridge Securities Corporation is referenced in a Financial Industry Regulatory Authority (FINRA) investigation in which he might face disciplinary action from the regulator based on allegations of defrauding customers by churning their accounts and making excessive trades….
Jeffrey Allen Baber of Red Bank New Jersey a stockbroker formerly registered with First Standard Financial Company LLC is referenced in a customer initiated investment related FINRA securities arbitration claim in which the customer requested $95,000.00 in damages founded on accusations of unsuitable transactions being effected in the customer’s account and First Standard Financial Company…
Christopher John Shaw (also known as Chris Shaw) of Belmont North Carolina a stockbroker of Kalos Capital and investment adviser representative of Kalos Management is referenced in a customer initiated investment related FINRA securities arbitration claim in which the customer requested $175,000.00 in damages founded on allegations that Shaw breached a fiduciary duty to the…
Gerald John Cocuzzo (also known as Jerry Cocuzzo) of Boca Raton Florida a stockbroker formerly registered with Newbridge Securities Corporation is referenced in a customer initiated investment related FINRA securities arbitration claim where the customer requested $208,287.00 in damages based upon allegations of unsuitable stock trading by Cocuzzo while he was registered with Newbridge Securities…
Dustin Paul Shafer of Springfield Illinois a stockbroker formerly registered with Newbridge Securities Corporation has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity founded on findings that he failed to cooperate with FINRA during the period that he was investigated for borrowing from Newbridge customers. Letter of Acceptance…
Solomon David Krispeal (also known as David Krispeal) of Hauppauge New York a stockbroker formerly registered with PHX Financial Inc. is referenced in a customer initiated investment related FINRA securities arbitration claim where the customer requested $650,000.00 in damages supported by allegations of unsuitable options, stock and over-the-counter equities being sold to the customer by…
Jeffrey Allan Broten of Red Bank New Jersey a stockbroker formerly registered with First Standard Financial Company LLC has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based on findings that he failed to cooperate with the regulator during the time that he was under investigation for potentially…
Gaetano Magarelli (also known as Guy Magarelli) of Boca Raton Florida a stockbroker formerly registered with Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim where the customer sought $130,000.00 in damages based upon accusations that contractual obligations to the customer were breached and that the customer’s losses were attributed…
Travis Justin Lippmann of New York New York a stockbroker formerly registered with Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim which was settled for $55,000.00 in damages based upon allegations that the customer’s losses had been caused by negligence and the breach of a fiduciary by Lippmann in…
Marshall Owen Isaacson of Boca Raton Florida a stockbroker formerly associated with Newbridge Securities Corporation has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity supported by findings that Isaacson failed to cooperate with FINRA’s investigation into allegations that he provided unsuitable investment advice to customers. Letter of Acceptance…
Michael Robert Greenfield of Boca Raton Florida a stockbroker formerly associated with Oppenheimer Co. Inc. has been referenced in a customer initiated investment related arbitration claim in which the customer requested $100,000.00 in damages supported by allegations of the violation of FINRA rules by Greenfield concerning oil and gas master limited partnership transactions that were…
Dustin Paul Shafer of Springfield Illinois a stockbroker formerly registered with Money Concepts Capital Corp is the subject of a customer initiated investment related arbitration claim in which the customer requested unspecified damages based upon allegations that securities laws of the State of Illinois were violated in regard to Shafer’s securities transactions and that the…
Kevin Thomas Doyle of Mineola New York a stockbroker formerly associated with Aegis Capital Corp and Newbridge Securities Corp has been referenced in a customer initiated investment related arbitration claim in which the customer requested $125,000.00 in damages supported by allegations that alternative investment recommendations made by Doyle had failed to be suitable as they…
Lawrence Michael LaBine (also known as Larry LaBine) of Scottsdale Arizona a stockbroker formerly registered with Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim where the customer sought $99,000.00 in damages based upon accusations of the stockbroker’s negligence with regard to alternative investments sold to the Newbridge Securities Corporation…
David Howard Fagenson of Boca Raton Florida a stockbroker formerly employed by Newbridge Securities Corporation has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity founded on accusations that he failed to cooperate with FINRA’s requests for his information. Case No. 2018057351801 (Jan 27, 2020). According to FINRA Public…
Glen Derek Delaney of New York New York a stockbroker formerly registered with Newbridge Securities Corporation has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon accusations that the stockbroker failed to respond to FINRA’s request for information about his activities. FINRA Case No. 2017054192101 (Feb. 11,…
Anil Ishwar Jethmal of Boca Raton Florida a stockbroker registered with Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim which was settled for $14,999.00 in damages based upon accusations of (1) negligence concerning stock trades effected in the customer’s Newbridge Securities Corporation account (2) breach of a fiduciary duty…
Dean Robert Nowak of Winter Park Florida a stockbroker formerly registered with TCM Securities Inc. is the subject of a customer initiated investment related complaint on April 22, 2019 where the customer sought $66,666.67 in damages based upon accusations of misrepresentations and omissions of investment information being made by the stockbroker when advising the customer…
Andrew Scott Corbman of Lansdowne Virginia a stockbroker employed by Kovack Securities Inc. has been referenced in a customer initiated investment related arbitration claim which has been resolved for $80,000.00 in damages founded on accusations that (1) common or preferred equity stock transactions failed to be adequately supervised by the securities broker dealer (2) transactions…
John Gerard Forrester Jr. of Boca Raton Florida a stockbroker currently registered with Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim where the customer sought $55,000.00 in damages supported by allegations that (1) the customer’s account was handled in a negligent manner (2) contractual obligations had been breached and…
Marshall Owen Isaacson of Boca Raton Florida a stockbroker formerly registered with National Securities Corporation and Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim where the customer requested unspecified damages based upon accusations that (1) contractual obligations had not been complied with by the stockbroker (2) fiduciary duties were…
David Francis Faline of St. Augustine Florida a stockbroker formerly employed by Newbridge Securities Corporation is the subject of a customer initiated investment related arbitration claim in which the customer requested more than $5,000.00 in damages based upon allegations that (1) the customer’s investments were overconcentrated in alternative investments and common and preferred stocks and…
David Gene Menashe of Mineola New York a stockbroker formerly employed by Joseph Stone Capital LLC is referenced in a customer initiated investment related arbitration claim in which the customer requested $50,000.00 in damages based upon accusations that (1) fiduciary duties were breached (2) the customer’s account was administered negligently (3) misrepresentations had been made…
Newbridge Securities Corporation a securities broker dealer headquartered in Boca Raton Florida, and Bruce H. Jordan (Director of Investment Banking), have been censured by Financial Industry Regulatory Authority (FINRA) based upon findings that (1) Newbridge failed to supervise structured products sold to customers of the firm (2) Newbridge failed to supervise non-traditional exchange traded fund…
Martin David Batstone (also known as Marty Batstone) of San Diego California a stockbroker formerly registered with Independent Financial Group has been charged by Financial Industry Regulatory Authority (FINRA) Department of Enforcement in a Complaint alleging that Batstone converted a customer’s funds and engaged in securities transactions away from the securities broker dealer. Department of…
John Kirkland Moy of Boca Raton Florida a stockbroker formerly employed by National Securities Corporation has been terminated from the securities broker dealer on April 5, 2019 based upon allegations of Moy giving bad advice to customers concerning the liquidation of their accounts. This is not the first time that Moy has been terminated from…
Gerald John Cocuzzo (also known as Gerry Cocuzzo and as Jerry Cocuzzo) of Boca Raton Florida a stockbroker formerly employed by Newbridge Securities Corporation has been barred from being a stockbroker or investment advisor representative or otherwise associating with securities broker dealers or investment advisories according to a Securities and Exchange Commission (SEC) Order containing…
Stephen James Sullivan of New York New York a stockbroker employed by Newbridge Securities Corporation is referenced in a customer initiated investment related arbitration claim in which the customer sought $540,618.00 in damages founded on allegations that (1) trades had been executed in the customer’s account in excessive amounts (2) transactions were not suitable for…
Brian Michael Berger of Boca Raton Florida a stockbroker formerly registered with Newbridge Securities Corporation has been barred from being a stockbroker or investment advisor or otherwise associating with securities broker dealers or investment advisors according to a Securities and Exchange Commission (SEC) Initial Decision of Default containing findings that Berger defrauded investors. In the…
Dennis Allen Hayes of Boca Raton Florida a stockbroker formerly employed by Newbridge Securities Corporation has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity according to a FINRA Office of Hearing Officers Order Accepting Offer of Settlement containing findings that (1) Hayes engaged in private securities transactions while…
Dominic Joseph Linsalata Jr. of Boca Raton Florida a stockbroker formerly registered with Dawson James Securities Inc. is referenced in a customer initiated investment related arbitration claim in which the customer sought $80,013.13 in damages supported by accusations that (1) misrepresentations had been made to the customer concerning equity investments and (2) excessive equity trades…
Sebastian George Bongiovanni of Staten Island a stockbroker currently employed by Newbridge Securities Corporation is referenced in a customer initiated investment related arbitration claim which was resolved for $91,000.00 in damages supported by accusations that (1) investment recommendations made to the customer were not suitable (2) unauthorized trades were executed in the customer’s account (3)…
Dennis Allen Hayes of Melville New York a stockbroker formerly registered with Newbridge Securities Corporation has been charged by Financial Industry Regulatory Authority (FINRA) Department of Enforcement in a Complaint alleging that (1) Hayes sold away from Newbridge Securities Corporation (2) Hayes failed to document his communications with the firm regarding his activities and (3)…
David Francis Faline of Boca Raton Florida a stockbroker formerly registered with NewBridge Securities Corporation is referenced in a customer initiated investment related arbitration claim which settled for $80,000.00 in damages founded on accusations that Faline provided the customer with poor advice in reference to common or preferred stock held in the customer’s investment account…
William Sidney Friedman of Boca Raton Florida a stockbroker formerly registered with Newbridge Securities Corporation is referenced in a customer initiated investment related arbitration claim which settled for $10,000.00 in damages supported by accusations that Friedman (1) engaged in inappropriate equity trading in the customer’s account (2) breached his fiduciary duties to the customer (3)…
Geoffrey Scott Cambal of West Yarmouth Massachusetts a stockbroker registered with NBC Securities Inc. has been ordered by the Massachusetts Securities Division to be placed on heightened supervision as a condition of registering with the firm based upon findings that Cambal has been subject of six complaints that alleged sales practice violations including (1) unauthorized…
John Richard Boatright of Duluth Georgia a stockbroker formerly employed by Summit Brokerage Services Inc. is referenced in a customer initiated investment related written complaint on May 11, 2018 where the customer sought $46,000.00 in damages based upon allegations that the customer’s account was handled in a negligent manner and the customer was poorly advised…
Austin R. Dutton, Jr., at least until August 2017, was a stockbroker or registered representative of Newbridge Securities Corporation allowed to conduct business under the name Bridge Valley Financial Services at 171 South Main Street in Doylestown, Pennsylvania 18901. On August 10, 2017, Dutton and Newbridge Securities parted ways. Weeks earlier, on July 24, 2017, Dutton…
Austin Richard Dutton Jr. of Doylestown Pennsylvania is a stockbroker formerly registered with Newbridge Securities Corporation who is the subject of a customer initiated investment related arbitration claim where the customer sought thirty thousand dollars in damages based upon allegations that (1) misrepresentations and omissions had been made to the customer relating to features and…
Michael Robert Greenfield of Boca Raton Florida is a stockbroker formerly registered with Oppenheimer and Company who is the subject of a customer initiated investment related arbitration claim where the customer requested one hundred forty-seven thousand three hundred thirty-four dollars in damages founded on allegations of (1) omissions (2) fraud (3) breach of contract (4)…
David Francis Faline of Boca Raton Florida is a stockbroker formerly registered with Newbridge Securities Corporation who is the subject of a customer initiated investment related arbitration claim in which the customer requested two hundred thousand dollars in damages based upon accusations that Faline made unsuitable investment recommendations to the customer which caused the customer…
PHILADELPHIA (OCTOBER 30, 2017) – The Guiliano Law Group, P.C. filed an arbitration action before the Financial Industry Regulatory Authority (“FINRA”) Office of Dsipute Resolution against Newbridge Securities Corporation, based upon the conduct of its former Registered Representative, Austin R. Dutton, Jr., alleging the violation of the federal securities laws, the Pennsylvania Securities Act, the…
Gaetano Magarelli, a stockbroker currently registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related arbitration claim on August 31, 2017, in which the customer requested $266,355.00 in damages based upon allegations that Magarelli placed unsuitable equity transactions in the customer’s account, causing the customer to sustain investment losses within her…
Lawrence Michael LaBine, of Scottsdale, Arizona, a stockbroker formerly registered with Newbridge Securities Corporation, has been permanently barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity according to an Office of Hearing Officers Order Accepting Offer of Settlement containing findings that LaBine fraudulently misrepresented information to investors and made unsuitable…
Glen Derek Delaney, of New York, New York, a stockbroker formerly registered with Newbridge Securities Corporation, is the subject of a customer initiated investment related written complaint on March 6, 2017, in which the customer requested $46,634.00 in damages based upon allegations that Delaney breached his fiduciary duties, over-concentrated the customer’s assets in stock, effected…
Christopher Carl Jansen, of Burlington, New Jersey, a stockbroker registered with Invest Financial Corporation, was terminated from employment on December 28, 2016, based upon allegations that he made misrepresentations to a customer pertaining to the guarantees and features of annuity products. Financial Industry Regulatory Authority (FINRA) Public Disclosure reveals that Jansen has been identified in…
Steven Michael Wisniewski, of Boca Raton, Florida, a stockbroker formerly registered with Newbridge Securities Corporation, has been suspended from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon allegations that Wisniewski never corresponded with FINRA regarding his compliance with the terms of a customer initiated investment related dispute settlement or…
Daniel M. King, of Melville, New York, a stockbroker formerly registered with Brookville Capital Partners, has been named in a customer initiated investment related arbitration claim on May 1, 2017, in which the customer requested $59,330.70 in damages based upon allegations that he solicited customers’ investments for products they were not suitable for, and led…
Andrew Scott Corbman, of Lansdowne, Virginia, a stockbroker formerly registered with Kovack Securities, Inc., has been named in a customer initiated investment related arbitration claim, which settled on April 20, 2017, for $100,000.00 in damages based upon allegations including breach of contract and unsuitability pertaining to the customer’s stock purchases. Financial Industry Regulatory Authority (FINRA)…
Austin Richard Dutton Jr., of Doylestown, Pennsylvania, a stockbroker currently registered with Newbridge Securities Corporation, has been named in a customer initiated investment related arbitration claim based upon allegations that Dutton breached his fiduciary and contractual duties owed to the customer, negligently managed the customer’s investment portfolio, and made misrepresentations and omissions concerning real estate…
James Walter Ignatowich, of Boca Raton, Florida, a stockbroker formerly registered with Newbridge Securities Corporation, has been named in a customer initiated investment related arbitration claim on December 21, 2016, in which the customer requested $61,469.00 in damages based upon allegations that Ignatowich violated the Iowa Securities Act, made misrepresentations to the customer, negligently handled…
Jesse Julian Griffin Jr., of Palm City, Florida, a stockbroker formerly associated with VSR Financial Services, Inc., has been subject to a customer initiated investment related arbitration action from June 19, 2015, which settled for $52,000.00 in damages based upon allegations that Griffin effected unsuitable transactions in the customers’ accounts. FINRA Public Disclosure reveals that…
Robert C. Bragg, of Colorado Springs, Colorado, a stockbroker formerly registered with VSR Financial Services, Inc., has been subject to a customer initiated investment related arbitration claim on February 24, 2015, which was settled for $60,000.00 in damages based upon allegations that Bragg made misrepresentations to the customer concerning investments, and made unsuitable investment recommendations….
Nicholas M. Giaallourakis, of Boca Raton, Florida, a stockbroker formerly associated with VSR Financial Services, Inc., has been subject to a customer initiated investment related arbitration claim from October 20, 2015, which settled for $14,000.00 in damages based upon allegations that Giaalourakis violated Florida Securities Act, breached his contractual and fiduciary duties to the customer,…
Gerald J. Cocuzzo, of Boca Raton, Florida, a stockbroker formerly registered with Newbridge Securities Corporation, has been named in a customer initiated investment related arbitration claim on July 5, 2016, based upon allegations that Cocuzzo breached his fiduciary and contractual duties to the customers, overconcentrated the customers’ assets, and committed fraud. Additionally, the customers alleged…
William K. Bradley, of New York, New York, a stockbroker formerly with Newbridge Securities Corporation, now associated with Meyers Associates, has been named in a pending customer initiated investment arbitration claim, in which the customer has requested $30,236.00 in damages based upon allegations that Bradley effected unsuitable investments in the customer’s account. FINRA Public Disclosure…
Newbridge Securities Corporation, headquartered in Boca Raton, Florida, was censured and fined $115,000.00 by Financial Industry Regulatory Authority (FINRA) after consenting to findings that the firm failed to apply sales charge discounts to eligible customers’ purchases of unit investment trusts (UITs); and failed to develop and manage supervisory practices and protocol to make sure eligible…