Page
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
1
In
the
Matter
of:
File
No.
GIG-509
GIG-509
WITNESS:
PAGES: PLACE:
Number
1 through Securities
100 F
11
66 and
Street,
i-I
ORIGINAL
Exchange
N.E., Room
Commission
2264
Washington, DATE: Wednesday,
D.C. March 25, 2009
The
to notice,
above-entitled
at 11:02 a.m.
matter
came
on
for
hearing,
pursuant
Diversified
Reporting
(202) 467-9200
Services,
Inc.
MADOFF
EXHIBITS-00264
Page
1 APPEARANCES:
2
3 4
On behalf HEIDI
of
the
Securities ESQ.,
and Assistant
Exchange
Commission:
STEIBER,
Investigator
5
6 7
8 9
10
CHRISTOPHER WILSON, ESQ.,
Office Securities
100 F Street, DC
Assistant
Investigator
of
the and
Inspector Exchange
NE 20549
General Commission
Washington,
11
On
behalf
of
the
Witness:
12
13
OCIE Staff Attorney
,
pro
se
14
15
16 17 18 19 20 21 22 23 24
25
MADOFF
EXHIBITS-00265
Page
1 CONTENTS
3
2
WITNESS:
OCIE Staff Attorney
EXAMINATION
3
6
5
EXHIBITS:
DESCRIPTION
IDENTIFIED
6
7
8
1
E-mail,
and T.
OCIE Staff Attorney
to M. Daug~erty
11
Eidt,
8/27/03
2
Complaint, ~
M. Kelly, 5/21/03
OCIE Staff Attorney
to
· 14 to T. Eidt, cc
9 10 3
E-mail,
11
12 13 14 15 4
T.
Stickley
and
M. Daugherty,
17
9/11/03 E-mail, Daugherty Madoff
OCIE Staff Attorney
to Stickley, 9/12/03
T.
Eidt, with
cc
and memo,
21
16
17
5
E-mail,
10/20/03
OCIE Staff Attorney
to
E.
Swanson,
23
18
19 20
21
6
E-mail,
10/31/03
OCIE Staff Attorney
to
E.
Swanson,
24
OCIE Staff Attorney
7
Memo,
examination of
to
E.
Swanson,
execution
re
Madoff
22 23
24 25
quality, 8 E-mail,B.
11/10/03
OCIE Staff Attorney
30 to A. Sadowski 33
MADOFF
EXHIBITS-00266
Page
4
1
2 Whereupon,
PROCEEDINGS
OCIE Staff Attorney
4
was
called as a witness, and, havingbeen first duly sworn,
as follows:
11 a.m. on
5
was examined and testified
6
MR.WILSON: are on the record at We
7 March 2009,at the Securities and Exchange 25, Commission,
8 located at 100 F Street, Northeast, Washington D.C.
9
10. the record?
Couldyouplease state and spell your full namefor
OCIE Staff Attorney
11
OCIE Staff Attorney
THE WITNESS: nameis My
e,
12
13 14 15
MR.WILSON: nameis Christopher Wilson. I am My an investigator in the Office of Inspector Genera~in the United States Securities and Exchange Commission. r amhere
16 todaywithmycolleague,HeidiSteiber, also an investigator 17 in the IG's office here at the Securities Jnd ~xchange
18 Commission.
I
'
19 Thisis an investigation the Officeof Inspector by 1 20 ~eneral, Case Number 5009. We goingto ask youcertain are 21 queations.y,, are goingto provide answers underoath. The
22 courtreporter record later transcribe will and everything
;· 23 that is said. Pleaseprovide verbalanswers the to
24
25
questions
~
If you give a nod of the head or other non-verbal
MADOFF
EXHIBITS-00267
Page
10
1
2 on
a
that?
Do you remember about what date you started
working
3
4 5 6 7
8
A
which
I imagine it was when I first
have been late August in
started
working here,
would Q
2003. why you became involved
Okay. Was it Yeah,
it,
Now, do you recall the Triple it
in that? A
understood
Q inspection? was involving
Eric, and
I think
they had
Triple
I think
Q.
Matt
As I
done.
9 10
Daugherty front-running
had been
working
on a project Qs. There
regarding of locked and
and Triple
was a lot
11
12
cross
markets
occurring
did
in that
some data
particular
requests
security.
before I started
So they
13
14
15
working
here,
like
of data.
I think
the spring
haven't
before
been
that.
able to
So they
look at
had a bunch
it yet.
They just
16 17
18
So when Take a look
MS.
I started, what you
Great.
they're find.
like,
here's
some
data.
and
see
STEIBER:
19
20 source of
MR. WILSON:
that trading
The trading
data was?
data,
do you know what
the
21
THE WITNESS:
For
this
exam,
it
would
have
been
22
23
from Madoff,
it came directly
because
from
it
would have been a Section
17exam,
so
a broker-dealer.
24
25 that we are
MS. STEIBER:
going to mark
I am going
as Division
to
show you a document
Exhibit i.
MADOFF
EXHIBITS-00268
Page
1 2 (Exhibit identification.) No. 1 was marked for
11
3 4
5 6
7
MS. STEIBER: Daugherty
Okay, with
better."
It
is
an e-mail date
from is
you to Matt August 27, 2003.
call
and Thomas Eidt.
in the first we think line
And the
you say:
now, Madoff
"We had these
a second trades
and
we understand
a lot
8
BY
MS.
STEIBER:
9
10 that's
Q
Do you
referenced
recall
here?
who you
spoke
to,
who the
Madoff
is
11
12 officer
A
of
I believe
the
it
was Dana Madoff,
the
chief
compliance
broker-dealer.
13
Q
Could
that
be
Shana?
14
A
Shana;
that's
possible
as
well.
I remember
her
15
16 17
last
name is
Q A But It
Madoff
you're definitely
and
she
was the
certain not. It
compliance
it wasn't was
person.
Bernie Madoff?
fairly was
a female.
18
19
Q
A
And do you recall
I'm referencing an
if
you had two phone
call so
calls?
have.
earlier
we must
20
21 22 23 24
When you're
else's trading
doing
data you
an exam and particularly
you're looking use at, you
when it's
need to
someone
understand, mean different
know. things. you're
People
different
shorthands
to
So when
looking
at
it,
you
want
to
make
sure
25
you understand
it
like
they
would
so that
you're
coming
to
MADOFF
EXHIBITS-00269
Page
12
1
2
3
the
the
data
right
process
to
conclusion.
really,
sure
So it's
to contact
know what
not unusual,
the
the
and it's
provided
part
the
of
firm
that
make
you
abbreviations
mean.
So
4
5
that's
where
obviously,
we thought
you know, we went through
we had gotten
probably
one call
the
some understanding
of what
6
7
different
must have
abbreviations
had a second
and shorthands
call that got
mean.
some
We obviously
clarification.
8
9 on the
Q
Now, you said
phone call?
"we."
Who else
do you recall
being
10
11
12
A
frankly,
Q
I don't
so I don't
who
remember
know.
is Thomas
anyone
else
working
on this
exam,
Now,
Eidt?
13 14 15 16 17 18
19
A but
Tom Eidt
started
at for
the the
same time SEC for
that
I did
in OC, I don't
he actually but for
had worked a while before on the Os -Exchange
P-H-L-X?
a period. working --
know,
I had started
here, all
but
when we had started related to the Tripe
same day he was given he was given part of the the
PHLX part,
the
Philadelphia
Q Is
Stock
that
inspection.
20
A
Yeah,
there
is
any,
but
the
Philadelphia
stock
21
22
exchange,
the Madoff
yeah.
data.
So he was given
And, so,
their
data,
I felt
and I was given
that he needed
obviously,
23
24
to
be cc'd
with
on this
a-mail.
I don't
And, in
remember
fact, he
him directly
didn't have a lot
working
me on this.
25
of time
to look at the
Philadelphia
data,
so I ended up
MADOFF EXHIBITS-00270
Page
1 taking that part over as well later on.
13
2
3
4
Q
calls
Madoff
And so doyou
anybody
recall
if
you had any other
other than
phone
the Shana
with
call?
at Madoff
Securities,
5 6 that
A I can
That
would
have
been the
the only
only
one that
I'm
aware be
of
recall,
because
reason
we would
7
8
9
calling
Q
them is to get clarification
Now, what was your
your
about the trading
on this Triple Q
data.
role
examination?
Who was
supervisor?
10 11
12 13 14 15 16
17 18
19
A there's
because working Swanson. assignment.
This was an unusual a branch
it
one.
Like I said,
usually, at the time,
started to Eric
chief,
but it's
small
not so unusual
when I first report me, gave involved, question
with so there
was a pretty But
group
there.
I actually one that
directly handed I think on the
He was the Matt working
how much was
firms
me an because before. I think I
that a lot he of
was also, with
direct
he had been
don't had,
different
Eric
know but it
involvement a sweep,
involved.
Madoff was
essentially
that were
20 21
22
23
Q examination,
relatedto
A
Okay.
When you started
working
on this
Triple
Q
did anyone ma~ke you aware of any complaints
Madoff
No.
that
OC had
received?
24
MS. STEIBER:
I'm
going
to
show you what
we're
25
going
to mark as Exhibit
2, and if you could
just
review
the
EXHIBITS-00271
MADOFF
Page
1 2 3 4 5 Madoff. prior to directly, Q A I no. And Had that we you call spoke ever with before spoken Shana that to you had at a call with securities Shana am not aware or anyone speaking to Bernie Madoff
17
anyone
Madoff
Madoff?
6 7 8
9
A remember the
that
No. talking
That's to
really anyone at
honestly the firm was
he would
the
only
time
I ever working brokers
desk
when of
talk
I was the
to
at
SEC.
At Ameritrade,
woulduse,
Madoff
so
one
big
like
Ameritrade
10
11
traders
extent
and
of our
stuff
contact.
like
that.
But,
I
mean,
that
would
be
the
12 13
Q A
So He
what was
was huge.
his He
reputation was basically
in
the the
industry? NASDAQ start
14
15
market
maker
as
and
I understood
basically does
it,
the
but
he
trading
was
a very
for large
large
firms
market
like
16
17
Ameritrade
Q
and
Were
other
there
large
any
brokerage
whispers about
firms
him
behind
that
the
you
scenes.
are
18
19
aware
A
of
that
Not
he
that
might
T'm
be
aware
engaged
of.
in
anything
illegal?
20
Q
But
he
was
a very
prominent
person?
21
22
23
A
here, yeah.
I recognized
the
name
when
I first
started
working
(Exhibit
No.
3
was
marked
for
24
identification.)
25
MS.
STEIBER:
I
am going
to
show
you
another
MADOFF
EXHIBITS-00272
Page
25
1
2 3
4
things;
kind really
whatever
and,
particularly,
project back.
issue
John had kind
to project So it
John
of a tendency
quickly without with
So
to
of go from circling
current
very
was kind
might be
of dealing
dealing with.
like
this
5 6
7
might about,
actually,
not
have
been
something asking
slow.
John
was asking about,
was
him questions but I guess,
a week.
so he wasn't
not that
me questions
I suppose it
about
8
9 memo?
Q
Do you recall
if
he ever
gave
you feedback
on your
10 11 12 13 and, would initial
A frankly, just
I don't there kind of and
remember. was die you a lot off. go up
I remember of projects you
sending at know, And the
this time you I think do
memo; that some the
I mean, the chain.
review
14
15
16
superiors
about.
had a lot
had determined,
Those
of
well,
just
that.
I got
kind
other
of
things
to
worry
I
old
projects
projects
like
languished;
and,
17 18
19
Q pulledonto
conclusions?
You had
projects else,
you so
started you never
and
then to
you any
were
something
came
20
21 22 23
A
whatever, just was
Well,
and never
no.
say any like
I mean,
okay,
we do our
what direction; we had
fact-finding,
And write when the there a memo wind
do we do next. or, we'd
further
summarizing
whatever
we thought
found
24
25
gained
occurrence.
further
I
input.
don't
So that
know if I
was a pretty
ever heard
common
back from him. He
MADOFF
EXHIBITS-00273
Page
1 may have given more feedback. I don't know.
26
2
Q
So was
there
kind
of
like
no
formalized
procedure?
3 4
5 6 7 8
9 10
Do you remember - just kind
A one ended,
from
OC for
following-up over
on old old
a lot. the first
exams
they
of prioritized
Frankly, frankly; really found
I didn't shows
new things
that when what but happened
things?
So how this time, I that were I
yeah, and, remember
we talked happened. I didn't
That what I
couldn't may have
major it, so or this
I remembered think
was how
some
things,
they
I
find you.
anything. You know
remembered we did
mean?
Like
11
what
we did
and
that's
what
happened.
12
13 14
15 16
Q
the
Well,
then focus
looking
if
you look
you than
more
at
"The
the
bottom,
you follow-up
stuff at
with
on
had and
memo and
say, what
for
Philadelphia looking
ahead
I did Madoff
and
a different
that BestEx I was with
I was
trading
with
Madoff
Philadelphia.
17 18 BestEx?"
Should And then
I look
again
at
Madoff "I
concentrating what you are
on
Swanson
says,
assume
19
20 21
22
asking
quotes. looking
report?
is
whether
The answer
to
look
is
at
Madoff
trades
against
is you
is
the
you the
yes."
My question on when
what this
weren't wrote
about?
at
Best
Execution
you just
earlier
explain
Could
23 24 and
A you
BestEx
is
kind in
of doing
nebulous, this that
right? terms
I mean, and
I found
know my time
securities
25
and
securities
law have
different
terms,
different
meanings
MADOFF
EXHIBITS-00274
Page
1 2 3 4 and in of different different a broker I think people; situations. to provide Eric the is and, they BestEx Best asking might is mean generally for and different the his things obligation client. what
27
Execution about
Now,
what
presumably
5
6 7 8 9 10
I'm
what
talking
was the
about
best I
here
price think you are at
is
what
prices
in is being looking because Did
did
open
clients
market.
get
versus
available what must the
That's that's what the the best like saying
referenced at the those the
here. trades would get
So versus be that
mean time,
quotes price
quote clients
that's
available.
11 12
13
price? usually
notices,
And, it's
they'll
generally, not a huge
call
that's difference.
back the
something
that the
happens client
hey
and
And i~
broker and
said,
look.
14 15
16 17 18 19
You gave improved,
me $10, they
Trading
but do it.
it
was
$9 on a different it happens.
I a an I want think type order, to buy the of
exchange;
price
I mean
at is
ahead, ahead is says
least also
way BestEx
I'm in a way a Buy
referencing because market the order
trading client that
providing "Hey,
particularly this stock.
20 21 22
23 24 25
it the
for
me." isn't were
So,
But
you as
don't as to
buy it when
can
it would they
see
right have first
why
away. been sent
looking
You wait. had in
for
And done order. it
price you
good
you the
when
supposed
you what know, BestEx
you
a precise when we're over
definition talking
of about
means, looking
and at
particularly e-mails where
shorthand
even
MADOFF
EXHIBITS-00275
Page 1 2
3
28
time, time.
here.
the
way
I probably
used is
the that's
word
Best
Ex changes what's
over going on
So my recollection
probably
4
5 at did the
When I first
clients send
looked
in their
at
Madoff,
order and
I was just
did Madoff
looking
6
front-run
that
order
or
trade
ahead
of
that
order.
And
7
8
probably
lot of
what
orders
was
where
happening
PHLX was
was
that
PHLX I was
at one
noticing
but
a
executing
price,
9
10
really
they
the
weren't
market
price
was
saying
it
those
was
a much
clients.
better
price;
and
improving
11
12 13 14 15 16 17 18 19 this wow, probably I did. Q you're you
So probably
know ask He what? Eric said Okay. going and if yeah, So to it I
in
the
course
did that this
of
doing
with
that
Madoff. analysis
was
I
like
should do.
never wants
he so.
sort
of
done
seems be doing the
that
from
this work you
e-mail, on
after Madoff
additional exam that
Securities previously? A
expanding
had
done
In
a
way.
I
mean,
it's
just
another
way
to
go
with
20 21
22
the for
look
same another
at
data,
really. issue;
in an
Just, like,
analysis
it's
like
saying at one
analyzing rule.
rule.
it Let's
we're
of
looking
an
that
additional
23
24 25 expand doing?
Q
the
So but
scope you
in
of got
your
experience
or and
at
OC was
it
that
possible
you other were
to
examination in there
inspection you discovered
Once
MADOFF
EXHIBITS-00276
Page
1 2 Swanson MS. from STEIBER: you and it's It's a November entitled, 10, 2003 memo of to
31
Eric
"Examination
Madoff
3
4
5
execution
quality."
THE WITNESS
BY MS.
:
Okay.
STEIBER:
6
Q
So
was
this
a
separate
examination
than
the
7
8 9
Triple
that
Q examination
September How 12, were
you
2003 these
had
memo? two
done
previously,
which
you
wrote
different?
10
A
Well,
it's
hard
to
characterize
it.
This
looks
to
11 12
be. we
I went
would back
have to the
been firm
using and
the asked
same for
data, more
so
it's
not
like and
information;
13 14
15 16
we would since,
This talking
have you
been the
using earlier
the
same
stuff all
the
we had the
result
been other
of
using analysis.
what about it's
know,
to me with
memo and
this e-mail was in
looks
that Eric
maybe via
about
late
October
17 18 19 20 21
22
23
going clients this
back
and
checking versus be still
execution what was of the
quality; market thought had had
and
what
were And found. this part
getting looks Q to I'm same
you
A
offering. we had
a summary not clear
whatwe if you you
memo?
I
considered been doing
of
that
Triple
wrote
but
Q examination
a whole
I don't
earlier,
because
new
Yeah,
think
would
consider
it
as
24 25
such. asked
Iknow
in
my mind, exams
like, I had
conceptually, done I didn't
if want
you the
had exam,
me how many
MADOFF
EXHIBITS-00277
Page 1 2
3 4 5 6 7 8 9 10 11 12 13 14 15 16
17
32
because slightly
memo pasted memo of the Q recognize which A this it's must I -for
it
was different
whatever
th.e
same issue
reason.
data. and
But I guess
of
this
was,
I suppose, I needed
be cut short this and
a a new
I thought
them it's have issue. might a pretty considered
Some but
from and, same
like I
the don't just you
--
I mean I would
know.
part
exam, And this do
a different think this is
the in
final the
draft? corner, "BG
Do you final,"
handwritten is is been supposed stand okay. think the if for probably my
comment your
think That have
handwriting. I one like, I must had boy have sent Eric. believed him; I and think I it that think was
handwriting. the final to Best And you be,
actually to
supposed Q you you'll
work.
Execution. could look you at look page you drew at what conclusion "Conclusion," doing this
Oh, I
have?
3 under after
summarize
conclusion
18 19 20 21 22 23 24 25 in
A significant particularly we found
It
looks activity. hard
like,
basically, But a deficiency to take. You ton of or a this
I
believe, letter
that isn't basically them. to go
this a
was
stance
It's should
just change ways to
like OC about
these really
deficiencies. have a
doesn't it. It's Q your
heavy-handed referral behavior you
basically Now, memo do would
that you have think
Enforcement. from would what have you see
been
something
MADOFF
EXHIBITS-00278
Page
recommended 2 3 4 5
6
33
for
Enforcement for an
referral
where referral?
you
thought
would
be
appropriate A This know not
of
Enforcement have been like
would I sure
we
two of
exams. was the
if we
I
mean,
I
don't I'm
were
if
had I
could
a good understood
do.
concept exactly
What can
what what
appropriate. consequences
find a
even
what
we
do
7
8
violation?
drafts where
It's
Eric
marked
had
"Final."
commented on
Maybe
and
there
said
were
basically
some
that's
9
10 11 12 13 14 15 16
17
what we were probably
I sent. think wherein Q having any At that some So don't I believe don't
going
to do.
deficiency
I don't
letter
know.
was I that ever
any remember
least this of after
drafting sucked went. this any exam,
one. into
honestly black hole
just these
kind exams you
of
got just on with
worked
do
you
recall
other or
Not that
involvement investigations?
I can recall.
Madoff
Securities
examinations
A
I
know
that
we
had
18
19 20 21
followed-up
the other
regarding
exchanges
some
of
these
problems
in
the
Qs
with
(Exhibit identification.)
No.
8
was
marked
for
22 23 24
25
MS. Exhibit looks
what
STEIBER: it is an doing
involves?
Can e-mail some
I
show from work
you you on the
one to
document, Alex Qs. Sadowski. Do you
and
it's It
8 and like
this
you're
e-mail
know
MADOFF
EXHIBITS-00279
Page
37
1
2
certain
And there
people
was
and other
like maybe
people
three
would be looking
or four kind of
for stuff.
senior staff
3
4
5
that
needed
and
we are kind of there;
something
like, hey,
and then,
else,
Find
you know, like
they
this
if
they
from
give
somebody
me this.
go search
out.
them out
I need it
say
6
7
8
for John.
no.
like
I need it
tomorrow.
cliques.
hierarchy.
And that
There
kind of thing,
were definitely
but
There
some
was definitely
sort of social
9
10 11 they
Q
the A
And were
kind Well, or
like
Sadowski
circle?
and McCarthy,
Donahue,
were
i-nner no. I
apologize.
I
don't
mean
to
talk
over
12 13 14
15
your circle
questions. around
Probably, John, maybe and that
the
primary
inner
circle Eric
was the and Alex, and,
would
be John, Matt,
circle
and sometimes
there were
a few other
people not in
people:
the
in a way;
but were
certain
trusted
16
17
by the
circle
circle.
that got
You know what
a lot of work.
I mean?
Like
leaned
on by that
18
19 a separate
There
social
former OCIE
were
definitely;
with
and,
Mark
then
and
there
stuff
was
that
kind
went:
of
structure
20 21
22
him and Branch Chief and those partially.
Street, they
guys
that old
probably building
part of
developed when we were
the floor than
Because
were in
in our
on 9th
most
a separate
23
24 25
of the
part different and
rest
then
of the
Mark I
group,
and don't his
one part
folks know.
of the
were kind
group
of off
was on one
in a
place.
MADOFF
EXHIBITS-00280
Page 1 Q So did you hear about any other tips for those he
39
2
3
4
received? I showed that tip from you
you ever
A
Did
hear
No.
of
any
other
complaints
or
tips?
5
6 7
8
Q
Markopolos? A
Q
When was
Or Is
Yes.
the
you guy
first
heard that
time
of testified
you
Harry
heard
of
Harry
have the
Markopolos? at Congress?
he
9
10 at all
A
stuff
before the
happened
news hit.
last
fall.
I
was
not
aware
of
him
11
12
13
Q
receiving
A
You never
any
No,
heard
tips
of
from
Lori
Richards
or
John
McCarthy
other
it
anyone?
been unusual for them to
would
have
14
15
communicate
astounded.
something
like
that
to
me.
I mean,
I was
just
16
17 18 19 possible Richard
Q
And did
having any not
you
hear
about
calls
John
with having he is a
McCarthy
Bernie any. large
and
Lori
phone aware
Madoff? I think it's
A
I'm and
of
them
probable,
because
market
20
21
participant
BY
that
MR.
they
WILSON:
might
talk
to
him
on occasion.
22
23 on-site
Q
of
On
the
QQQ examination,
Securities to the
do
you
know
if
that
anybody
were
went
Madoff
documents
24
provided
or
any
information
was
sent
to
the
SEC?
25
A
It
was
sent,
and
I'm
not
aware
of
any.
I certainly
MADOFF
EXHIBITS-00281
Page 1
2
40
didn't
either.
go
on-site
to
Madoff.
I don't
think
anyone
else
did
3
Q
Okay.
Does
that
happen
on
occasion
that
the
SRO
4
5 6 7 8 9 10
11
group
and
market
oversight
group
will
actually
do
on-site
examinations? A SROs. number With you
it·
You But of it's
can
do also why it
on-site possible you
exams, to would do go
particularly it on-site at you and on-site. and
with There's you
the a
reasons exam,
wouldn't. data can look and at
this can
was them
primarily to send that
looking to
trading you
just
get
12 13
14
If order,
know
all
you're to
that's
worried be held
in
about in
the
is
did
you and
not
front-run we
or in
an
that's
whether
going
or not
the
numbers,
or
would
the
numbers
15
16 17
information
around that here causes
that
they
they
started
provided
hitting with going
to
us.
some
Particularly,
budget problems
I think,
and
problems
on-site.
18 19
20
There's, on-site,
on-site
you
know,
any there
reason was ever
why you any
was
wouldn't to
they
go go
made
but
with
I don't
these
think
guys.
plans
that
My understanding
21
22
23
the
request.
at the
BY
They
got
the
information
they provided.
and
it
was
just
looking
information
MS. STEIBER:
24 25
Q Swanson.
We talked Are you
before friends
about with
you Eric
working Swanson?
with
Eric
MADOFF
EXHIBITS-00282
Page
49
1 2 3
4
Here's
one, two, three
and four.
Check those
four things, very and you
This is
and then you move on to the next firm. kind of mechanical.
find a violation, it's
I mean, it's
And so when you do those things
kind of like, "Oh, my God.
5 6
7
the worst thing to ever happen, ever." it up and then it turns
is
And so then you blow or maybe it
out to not be a big deal,
8
9 10 11 noise. things violation
I don't know. And it becomes part of the white
The same people and it's or not. like, keep I don't· I guess complaining know if this yeah. about is the a rule same
I
sometimes,
12
13 adequate
Q
When you came, did you feel
training?
like
they gave you
14
15
A
training.
Oh, there
was no training.
that
This
Qs exam was my
this was a
And I was told
when I came in that
16
trial
by fire
kind of job that
you get trained
as you come
17
18
19
in; and, frankly,
this side
I don't
know how you trained.somebody
over time, luckily
to do
of the job.
in
And I feel
activity,
I had a
basic
background
some trading
so I understood
20
21
training,
of thing,
how it
but.
works,
what the terminology
is and thatsort
22
23 didn't
Q
have
Do you feel
your
like
you worked with
some people
that
background?
24
A
Oh, yeah,
yeah,
there's
a lot
of people
that
25
weren't
familiar
with securities
laws.
They were brought in
MADOFF EXHIBITS-00283