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1s11 A.

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RIUM3OW PU

NAL HEADCAUARTEIRS

930 East 50th Street Chicago, Illinois 60615 Phone: (773) 373-3366 Y Fax: (773) 373-3571

September 13, 2010


katIonal Headquarters 330 Seel 50th Street Chicago. IL 80515 (773) 373-3386 (Freedom) Office (773) 37?-3571 Fax LaSalle Street Project Lecatco within the Natlona; Office in Chicay. IL Peachtree Street Project 100 Auburn Avenue Suite lel Atlanta, GA 30303 (404) 525-5663 Office (404) 525-5233 FAX Automotive Project 4.335 W. Fort Street Detroit, MI 49209 313) 842-3853 Of5ce ;313) 842-2625 Fax Energy Project 2616 SouTh Loop Watt
Suite 100 Houston, TX 77054 (713)432.0209 (713) 432-9000

Mr. Richard. G. Ketchum Chairman and Chief Executive Officer FINRA 1735 K Street Washington, D.C. 20006
Dear Mr. Ketchum:

Ertterteirerent Project 1313 8th Street Suite 232 Loa Am:toles. CA 90017 (21314183-3500 Office (213)6.83-3517 Far. Wall Street Project 5 Hanover Square 2ne Floor New York, NY 10004 212) 425-7374 Office 2t21988-1412 Fex Silicon VI:1119y Project 1400 85th Street Emeryville, CA 94808 (510) 856-6258 OftIce
(510) 336-6893 Fax

I am writing to request a meeting with you to discuss a matter concerning a constituent and member of our International Trade Bureau, Sh.awn D. Baldwin, and his firm, CMG Institutional Trading LLC ("CMG"). Mr. Baldwin has brought to my attention a number of concerns that he has regarding recent activity involving FIN-RA and certain FINRA executives, and is alleging that certain of this activity has resulted in a substantial impact on the productive operation of his firm due to a number of what are believed to be unsupported allegations by Mr. nil Harris, from approximately 2001 until 2006. Mr. Baldwin acquired a broker-dealer and built his investment bank to a prominent position garnering accolades from various trade magazines and earning numerous industry awards .. Mr. Baldwin also had the honor ot securing a sponsorship as the national spokesperson for Blackberry during this time. As his success increased, the alleged mistreatment from those certain FINRA. executives seemed to build. It was during this time that Mr. Baldwin began documenting this perceived mistreatment beginning in 2002, and to this point, has attorneys formerly from the NASD (AKA FINRA) and the SEC that have indicated their willingness to attest to this mistreatment by these FINRA executives based on their knowledge of the present circumstances. During this period Mr. Baldwin contacted the head of the office at FINRA with letters, as well as the Ombudsman and the SEC, and copied letters to members of the GAO, and was met with no offer of assistance. We have been provided with copies of all referenced correspondence as well as voicemaiis from the many messages that Mr. Baldwin left. Mr. Baldwin even flew to Washington, D.C. in an. attempt to secure a meeting with senior FINRA. officials and while there met briefly with Barbara Sweeney, but he was not permitted to meet with anyone else to outline his many grievances.

Public. Policy I

Toiocorntrunicattomt Project
727 15th Street NW Suite 1200 Washl0c100, OC 20005

;20)38-74Ofice (202) 393-1455 Fax

Rev. Jesse L, JaCicsOn, Sr.. Foamier &

Pmairlarn

Martin L. King, Chaletan , www.raintowptish.org

.iUe" it/ ZtJILI

CL.

Page Two Mr. Ketchum After a number of incidents, FriellIA. District S launched a proceeding against Mr. Baldwin and his firm that consisted of claims of net capital deficiency along with. 42 other points; by the time of the proceeding, these 42 points had. been reduced to 3. In two of the three points it was determined that the top three officials had lied under oath and were forced to recant their testimony. On the third point, which involved officials alleging that they did not receive a deposit ticket for a wire, Mr. Baldwin and his firm were expelled. From our initial review, it appears that the first expulsion was not warranted and the claims of net capital deficiency were untrue and can be verified by a review of the focus reports and bank statements. The proceeding and judgment were based on an allegation of an unregulated company in which FINRA had no jurisdiction. The transcripts and recorded messages also clearly indicated Mr. Baldwin's intention that be would offer all information for the regulated company. The 2-year suspension for not providing a deposit ticket for a wire transfer for an unregulated company appeared to be unfair, and impossible, since deposit tickets do not exist for wire transfers and since the wire was initiated by another party. This extreme focus on Mr. Baldwin occurred when he had only institutional clients, during a period when individuals like Bernard Madoff were allowed to take billions of dollars from innocent investors, unchecked. It is our understanding that, to date, FINRA, officials have refused to perform. a net capital computation for the many alleged net capital deficiencies when in fact CMG had over $440,000, had made over $900,000 in that quarter and had receivables of hundreds of thousands of dollars. Mr. Baldwin withdrew all of his capital from the broker-dealer and stopped all reporting to FINRA and the broker-dealer was subsequently expelled pursuant to Rule 9552. Although FINRA officials have alleged since CMG's admittance that they believed net capital was deficient and interrupted CMG's business multiple times under, the guise of protecting the public, FINRA reinstated the CMG broker-dealer without capital or reporting - a position that seemed antithetical to their stated mission and their position with respect to CMG. This amounted to Mr. Baldwin being taken through proceedings although he was in Europe, had no clearing agreement and had written and stated that he would not conduct any securities business during one of the worst times of financial crisis. FINRA, officials ran two additional proceedings against Baldwin and CMG despite the fact that neither has been in a securities transaction since December of 2005. We also note that another proceeding was initiated soon after Mr. Baldwin made a televised appearance on NBC discussing unrelated matters. It came to Mr. Baldwin's attention that, following this appearance, a comment was made by a member of the Department of Enforcement, Pamela Sim, in which she referred to him as a "menace" and further stating to Baldwin's attorney that they were "amazed that he continued to get back upno matter how many times he was knocked down." The substitution of documents during the second proceeding can easily be validated by the documents submitted in 2006 by Mr. Baldwin's attorney to the NAC and the SEC, and Mr. Baldwin pointed out as much verbally during the proceedings.

Page Three Mr. Ketchum This was not reviewed. by the NAC, and we believe that the previous proceedings involving the top three officials recanting their testimony after a determination was made that they were lying under oath regarding whether certain, requested documents were received should be taken into full consideration. There are many other incidents too numerous to list that have been documented arid that suggest the strong possibility that Mr. Baldwin was singled out and subject to unwarranted scrutiny. Mr. Baldwin's platinum reputation has been severely tarnished as a direct result of FINRA's actions which essentially destroyed his multi-million dollar business and has had the continuing effect of severely limiting his opportunities due to the negative references made against him and his firm that remain on the FINRA website. We believe it of note that, during Mr. Baldwin's entire tenure neither he nor his organization, nor any of his employees, had ever received a customer complaint. As Mr. Baldwin has continued to write for Forbes and exert his influence and. knowledge in other prominent forums, we are concerned at any actions by executives of FINRA that may continue to undermine or reduce Mr. Baldwin's credibility. Accordingly, we would appreciate having the opportunity to meet to discuss these matters with you, with the hope that together we can work to resolve this matter amicably for the benefit of all parties involved. Please contact my Special Counsel, Brenda Robinson, Esq., on (773)3146420. Respect 11 ,

Reverj d Jess 'Jackson, Sr. Fourier and President

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