0001608743-17-000003.txt : 20170124
0001608743-17-000003.hdr.sgml : 20170124
20170124113139
ACCESSION NUMBER: 0001608743-17-000003
CONFORMED SUBMISSION TYPE: MA-I/A
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20170123
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Echo Financial Products LLC
CENTRAL INDEX KEY: 0001608743
IRS NUMBER: 261132148
STATE OF INCORPORATION: PA
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: MA-I/A
SEC ACT: 1934 Act
SEC FILE NUMBER: 868-04282
FILM NUMBER: 17542886
BUSINESS ADDRESS:
STREET 1: 200 NORTH WARNER ROAD
STREET 2: SUITE 150
CITY: KING OF PRUSSIA
STATE: PA
ZIP: 19406
BUSINESS PHONE: 610-768-7733
MAIL ADDRESS:
STREET 1: 200 NORTH WARNER ROAD
STREET 2: SUITE 150
CITY: KING OF PRUSSIA
STATE: PA
ZIP: 19406
MA-I/A
1
primary_doc.xml
MA-I/A
0001608743
XXXXXXXX
Christopher Monaghan
610-768-7733
chris@echo-fp.com
N
N
Michael
Warren
Garner
N
1
0001608743
Echo Financial Products LLC
09-20-2007
N
Concurrent with Form MA
LOCATED
09-20-2007
200 North Warner Road
Suite 150
KING OF PRUSSIA
PA
19406
09-2007
Echo Financial Products, LLC
King of Prussia
PA
19406
Y
Y
Principal
12-2002
09-2007
Investment Management Advisory Group
Pottstown
PA
19465
Y
Y
Vice President
Y
01-2010
Tartarus Capital
630 Freedom Business Center
3rd Floor
King of Prussia
PA
19406
N
N
Tax lien purchaser
Principal
8
Managerial
11-2013
Galene Ventures LLC
630 Freedom Business Center
3rd Floor
King of Prussia
PA
19406
N
N
Real estate
Principal
8
Managerial
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
01-23-2017
Christopher Monaghan
Principal
Applicant was engaged in transactions involving SLGS subscriptions made on behalf of issuers, each step of which was permissible, based on relevant federal regulations and examples. On 10/25/2013, Applicant received a letter from the Treasury Department instructing applicant to cease such transactions. Applicant was denied a hearing and given the right to respond only in written form, with no right to appeal within the Department of the Treasury. Applicant offered 7 mitigating factors in response to the allegations, including the fact that, in the absence of a definition of "cost-free option" in the regulations, Applicant reasonably relied on examples in the Treasury regulation. As a result of the Final Agency Decision from the Treasury, Applicant will not be able to act as an agent for issuers, however issuers can, and have traditionally, used other parties to subscribe.
Since the last filing of Forms MA and MA-I, the Department of Justice Civil Division ("DOJ") notified Michael Garner and Christopher Monaghan that DOJ was investigating possible violations of federal civil statutes and regulations in connection with the business interests outside of Echo Financial Products, LLC described above. Mr. Garner and Mr. Monaghan are cooperating fully with the DOJ and expect to be fully exonerated.
N
6D(1)(e)
6D(1)(b)
6D(1)(c)
6D(1)(d)
Department of the Treasury
Richard L. Gregg, Fiscal Assistant Secretary, Deciding Official
Suspension
10-25-2013
Treasury SLGS Working Group Report and Recommendation
0
Department of the Treasury
Washington
DC
20227
Enhanced Financial Solutions LLC
Debt - Government
Alleged violations of 31 CFR 344.2(f), which makes it impermissible to use the SLGS program to create a cost-free option. Treasury alleged that Applicants former employer, Enhanced Financial Solutions LLC's, use of its Yield Enhancement Program created impermissible cost-free interest rate options under three scenarios: (a) purchasing a long-term SLGS security and redeeming the security before maturity in order to capture premium; (b) changing the maturity and associated interest rate on SLGS already subscribed for to take advantage of interest rate movements; and (c) changing the SLGS subscription amount in response to movement in interest rates in order to maximize redemption premiums or minimize potential losses. Treasury alleged that taken as a whole, the actions taken to gain premiums and avoid losses did not comply with the purpose of the SLGS program which was to assist state and local government issuers of tax-exempt bonds with complying with the arbitrage rules under the tax regulations.
No appeal to any official within the Department of the Treasury was permitted.
Suspension
06-06-2014
Ineligibility to subscribe for SLGS securities; however, clients are still permitted to subscribe directly of indirectly (through other transaction participants such as Trustee) for SLGS if evidenced to be the most cost-effective solution for escrow securities.
Decision
Order
The Decision was titled "Final Agency Decision" though used the term "Order" with respect to the actions taken therein.
N
06-06-2014