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| | J.W. Barclay & Co., Inc., John A. Bruno, Michael J. Wills, Edgar B. Alacan, Emmanuel P. Cube, Mayer Dallal, Danoo Noor, ... |
 | | During the time period from in or about June 1997 through in or about December 1998, Michael J. Wills ("Wills"), age 38, was the vice president and senior sales manager of J.W. Barclay and Co., Inc. ("Barclay"). |
 | | Wills acted as a supervisor at Barclay, and certain of the RRs were subject to his supervision. |
 | | Wills caused Barclay to institute an inadequate supervisory system by failing to hire enough supervisors for the number of registered representatives associated with Barclay, and by failing to establish adequate procedures designed to detect and prevent sales practice violations and securities fraud resulting from those violations. |
| www.sec.gov /litigation/admin/33-8202.htm (900 words) |
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