td ameritrade clearing, inc

BrokerCheck Report

TD AMERITRADE CLEARING, INC.

Section Title

Report Summary

Firm History

CRD# 5633

1

6

Firm Profile 2 - 5

Page(s)

Firm Operations 7 - 18

Disclosure Events 19

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CRD# 5633

SEC# 8-16335

Main Office Location

200 SOUTH 108TH AVENUEOMAHA, NE 68154Regulated by FINRA Kansas City Office

Mailing Address

200 SOUTH 108TH AVENUEOMAHA, NE 68154

Business Telephone Number

800-669-3900

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 25

Arbitration 26

Firm Profile

This firm is classified as a corporation.

This firm was formed in Nebraska on 01/28/1971.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 16 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

• the SEC• 7 Self-Regulatory Organizations• 53 U.S. states and territories

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1©2022 FINRA. All rights reserved. Report about TD AMERITRADE CLEARING, INC.


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This firm is classified as a corporation.

This firm was formed in Nebraska on 01/28/1971.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.


SEC#

5633

8-16335

Main Office Location

Mailing Address

Business Telephone Number

Doing business as TD AMERITRADE CLEARING, INC.

800-669-3900

Regulated by FINRA Kansas City Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

TD AMERITRADE ONLINE HOLDINGS CORP.

SHAREHOLDER

75% or more

No

Domestic Entity

04/2006

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


FUESEL, GREGG JOSEPH

CHIEF FINANCIAL OFFICER/FINOP

Less than 5%

No

Individual

04/2021

Yes

4173460



Position


Position Start Date

KONOP, LYNN MARIE

CHIEF COMPLIANCE OFFICER

Less than 5%

Individual

05/2021

1216310








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


STARR, JEFFREY HAROLD

PRESIDENT

Less than 5%

No

Individual

01/2022

Yes

4700461








This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

TD AMERITRADE HOLDING CORPORATION

PARENT CORPORATION

TD AMERITRADE ONLINE HOLDINGS CORP

75% or more

Yes

Domestic Entity

09/2002

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




THE CHARLES SCHWAB CORPORATION

PARENT CORPORATION

TD AMERITRADE HOLDING CORPORATION

75% or more

Yes

Domestic Entity

10/2020

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 7 SROs and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 03/09/1971

Self-Regulatory Organization Status Date Effective

FINRA Approved 02/19/1971

Cboe BYX Exchange, Inc. Termination Requested 10/20/2016

Cboe BZX Exchange, Inc. Termination Requested 10/20/2016

Cboe EDGX Exchange, Inc. Approved 05/27/2010

MEMX LLC Approved 07/22/2020

NYSE Arca, Inc. Approved 09/18/2002

Nasdaq Stock Market Approved 07/12/2006






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/23/1981

Alaska Approved 03/31/1981

Arizona Approved 04/23/1979

Arkansas Approved 09/21/1979

California Approved 02/15/1979

Colorado Approved 04/20/1983

Connecticut Approved 02/22/1979

Delaware Approved 10/06/1981

District of Columbia Approved 08/08/1979

Florida Approved 04/27/1983

Georgia Approved 09/21/1981

Hawaii Approved 04/14/1981

Idaho Approved 02/22/1979

Illinois Approved 10/24/1975

Indiana Approved 10/20/1981

Iowa Approved 07/08/1983

Kansas Approved 03/16/1978

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 02/08/1984

Maryland Approved 10/03/1981

Massachusetts Approved 07/31/1981

Michigan Approved 02/02/1983

Minnesota Approved 07/15/1982

Mississippi Approved 10/14/1981

Missouri Approved 07/15/1983

Montana Approved 04/20/1983

Nebraska Approved 10/08/1981

Nevada Approved 09/19/1983

New Hampshire Approved 03/18/1983

New Jersey Approved 07/11/1983

New Mexico Approved 10/07/1981

New York Approved 01/04/1983

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 10/21/1981

Ohio Approved 07/16/1982

Oklahoma Approved 07/17/1982

Oregon Approved 10/24/1981

Pennsylvania Approved 12/28/1978

Puerto Rico Approved 10/30/1997

Rhode Island Approved 02/01/1983

South Carolina Approved 10/28/1981

South Dakota Approved 07/15/1982

Tennessee Approved 08/17/1981

Texas Approved 07/22/1983

Utah Approved 04/21/1983

Vermont Approved 02/13/1984

Virgin Islands Approved 09/10/2007

Virginia Approved 09/22/1981

Washington Approved 04/20/1983

West Virginia Approved 09/30/1981

Wisconsin Approved 06/07/1979

Wyoming Approved 07/26/1978






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

This firm currently conducts 16 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Mutual fund retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Solicitor of time deposits in a financial institution

Put and call broker or dealer or option writer

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables

Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union

Broker or dealer involved in a networking, kiosk or similar arrangment with a: insurance company or agency






Firm Operations

Clearing Arrangements

This firm does hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

Name: GLOBAL RELAY COMMUNICATIONS INC

Business Address: 270-200 CAMBIE STREETVANCOUVER, BRITISH COLUMBIA, CANADA V6B 2M9

Effective Date: 02/10/2014

Description: GLOBAL RELAY AGREES TO MAINTAIN AND PRESERVE BOOKS ANDRECORDS PERTAINING TO CERTAIN INTERNET COMMUNICATIONS, ANDTO PROMPTLY FURNISH SUCH BOOKS AND RECORDS IN ANACCEPTABLE MEDUIM AND FORMAT UPON REQUEST.

Name: ACCESS INFORMATION MANAGEMENT

Business Address: 6818 PATTERSON PASS ROADLIVERMORE, CA 94550


Description: ACCESS INFORMATION MANAGEMENT HAS CONTRACTED WITH TDAMERITRADE CLEARING, INC. TO STORE CERTAIN OF ITS RECORDS.ACCESS IS CHARGED ONLY WITH THE PHYSICAL STORAGE ANDMAINTENANCE OF INVENTORY OF SAID RECORDS. ALL RECORDSREMAIN THE PROPERTY OF TD AMERITRADE CLEARING, INC., AND ARESUBJECT TO PROMPT RETURN ON DEMAND. ACCESS ALSO PROVIDESCERTIFIED DESTRUCTION SERVICE TO TD AMERITRADE CLEARING,INC. ON DEMAND.

Name: IRON MOUNTAIN

Business Address: 1 FEDERAL STREET, BOSTON MA 02110BOSTON, MA 02110


Description: IRON MOUNTAIN HAS CONTRACTED WITH AMERITRADE, INC. TOSTORE CERTAIN OF ITS RECORDS. IRON MOUNTAIN IS CHARGED ONLYWITH THE PHYSICAL STORAGE AND MAINTENANCE OF INVENTORY OFSAID RECORDS. ALL RECORDS REMAIN THE PROPERTY OFAMERITRADE, INC., AND ARE SUBJECT TO PROMPT RETURN ONDEMAND. IRON MOUNTAIN ALSO PROVIDES CERTIFIED DESTRUCTIONSERVICE TO AMERITRADE, INC. ON DEMAND.






Firm Operations

Industry Arrangements (continued)

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

Yes

No

No

10/06/2020

211 MAIN STREETSAN FRANCISCO, CA 94105

151739

CHARLES SCHWAB INVESTMENT ADVISORY, INC is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB INVESTMENT ADVISORY, INCAND TD AMERITRADE CLEARING, INC.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

UNITED KINGDOM

Yes

10/06/2020

33 LUDGATE HILLLONDON, UNITED KINGDOM EC4M 7JN

CHARLES SCHWAB, U.K., LIMITED is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB, U.K., LIMITED AND TDAMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB, U.K., LIMITED AND TDAMERITRADE CLEARING, INC.

Description:

No

Yes

HONG KONG

Yes

10/06/2020

UNITS 602-606, 6F GLOUCESTER TOWERTHE LANDMARK, 15 QUEENS ROAD CENTRALCENTRAL, HONG KONG

CHARLES SCHWAB, HONG KONG, LTD. is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB, HONG KONG, LTD. AND TDAMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

IRELAND

Yes

10/06/2020

70 SIR JOHN ROGERSON'S QUAYDUBLIN 2, IRELAND

CHARLES SCHWAB ASSET MANAGEMENT (IRELAND) LIMITED is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB ASSET MANAGEMENT(IRELAND) LIMITED AND TD AMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

10/06/2020


106753

CHARLES SCHWAB INVESTMENT MANAGEMENT, INC is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

Yes

No

No

10/06/2020

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB INVESTMENTMANAGEMENT, INC AND TD AMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Yes

No

No

10/06/2020


159035

SCHWAB PRIVATE CLIENT INVESTMENT ADVISORY, INC. is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH SCHWAB PRIVATE CLIENT INVESTMENTADVISORY, INC. AND TD AMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

Yes

No

10/06/2020


5393

CHARLES SCHWAB & CO., INC. is under common control with the firm.

THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB & CO., INC. AND TDAMERITRADE CLEARING, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


THE CHARLES SCHWAB CORPORATION IS THE ULTIMATE PARENTCORPORATION FOR BOTH CHARLES SCHWAB & CO., INC. AND TDAMERITRADE CLEARING, INC.

Description:

No

Yes

HONG KONG

Yes

10/17/2017

SUITE 2210, TWO PACIFIC PLACE88 QUEENSWAY, HONG KONG

TD AMERITRADE HONG KONG LIMITED is under common control with the firm.

TD AMERITRADE HONG KONG LIMITED AND TD AMERITRADE CLEARING,INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADEHOLDING CORPORATION.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

SOUTHEAST ASIA

Yes

10/22/2010

1 TEMASEK AVE#15-02 MILLENIA TOWERSINGAPORE, SOUTHEAST ASIA 039192

TD AMERITRADE SINGAPORE PTE. LTD. is under common control with the firm.

TD AMERITRADE SINGAPORE PTE. LTD. AND TD AMERITRADE CLEARING,INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADEHOLDING CORPORATION

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

01/24/2006

200 S 108TH AVEOMAHA, NE 68154

7870

TD AMERITRADE, INC. is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

Yes

No

01/24/2006

TD AMERITRADE, INC. AND TD AMERITRADE CLEARING, INC. ARESUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADEHOLDING CORPORATION

Description:



Country:

Foreign Entity:

Effective Date:

Yes

No

No

07/21/1998

200 S 108TH AVEOMAHA, NE 68154

111514

TD AMERITRADE INVESTMENT MANAGEMENT, LLC is under common control with the firm.

TD AMERITRADE INVESTMENT MANAGEMENT, LLC AND TD AMERITRADECLEARING, INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TDAMERITRADE HOLDING CORPORATION

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

This firm is directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank

Business Address:

THE CHARLES SCHWAB CORPORATION is a Bank Holding Company and controls the firm.







Firm Operations


Effective Date:

Business Address:

Description: THE CHARLES SCHWAB CORPORATION WHOLLY OWNS TD AMERITRADEHOLDING CORPORATION WHICH WHOLLY OWNS TD AMERITRADECLEARING INC. THE CHARLES SCHWAB CORPORATION IN A FINANCIALHOLDING COMPANY UNDER THE BANK HOLDING COMPANY ACT OF 1956,AS AMENDED.

10/06/2020







Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 25 0

Arbitration N/A 26 N/A






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 25

Reporting Source: Regulator

Allegations: TD AMERITRADE CLEARING, INC VIOLATED THE EDGX RULE 3.2 AND RULE15C3-5 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLSAND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOPREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERSTHAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON ANORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THATINDICATE DUPLICATIVE ORDERS.

Current Status: Final






Initiated By: CBOE EDGX EXCHANGE, INC.

Principal Sanction(s)/ReliefSought:

Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s)/ReliefSought:

Date Initiated: 07/26/2021

Docket/Case Number: FILE NO. USRI-8114-07

Principal Product Type: Equity Listed (Common & Preferred Stock)

Other Product Type(s):

Allegations: TD AMERITRADE CLEARING, INC VIOLATED THE EDGX RULE 3.2 AND RULE15C3-5 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLSAND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOPREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERSTHAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON ANORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THATINDICATE DUPLICATIVE ORDERS.

Resolution Date: 07/29/2021

Resolution:

Other Sanctions Ordered:

Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $10,000.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Consent

iReporting Source: Firm


Allegations: THE FIRM VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND EDGX RULE 3.2 INTHAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS ANDSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOPREVENT THE ENTRY OF ERRONEOUS ORDERS.









Censure


MONETARY FINE IN THE AMOUNT OF $10,000


Docket/Case Number: FILE NO. USRI-8114-07

Principal Product Type: No Product



Resolution:


Sanction Details: FINE PAID BY WIRE 08/04/2021

Firm Statement THE FIRM NEITHER ADMITS NOR DENIES THAT VIOLATIONS OF EXCHANGERULES OR THE SECURITIES EXCHANGE ACT OF 1934 RULES HAVE BEENCOMMITTED. THE FIRM MADE NO ERRONEOUS ORDER FILINGS DURINGTHE REVIEW PERIOD AS A RESULT OF THE ACTS, PRACTICES, ANDCONDUCT DESCRIBED IN THE ALLEGATIONS. THE FIRM REPRESENTSTHAT PRIOR TO THE SUBMISSION OF THIS LOC IT HAS REMEDIATED THEALLEGED VIOLATIVE CONTROLS.


Acceptance, Waiver & Consent(AWC)

Disclosure 2 of 25

i


Initiated By: NYSE AMERICAN LLC


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT CORRECTLY THE EFFECTIVE DATE IN CONNECTION WITHSUBMISSIONS OF OPTIONS POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) DUE TO A CODING ERROR THAT IMPACTED OPTIONPOSITIONS AND HAD BEEN SELF-DETECTED AND REMEDIATED BY THEFIRM.









Docket/Case Number: 2014040549801

Principal Product Type: Options



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000.PURSUANT TO NYSE MKT RULE 9310(A)(1)(B), THIS AWC BECAME FINAL ONJULY 25, 2017.


No




Initiated By: NYSE AMERICAN LLC




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT CORRECTLY THE EFFECTIVE DATE IN CONNECTION WITHSUBMISSIONS OF OPTIONS POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) DUE TO A CODING ERROR THAT IMPACTED OPTIONPOSITIONS AND HAD BEEN SELF-DETECTED AND REMEDIATED BY THEFIRM.












Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. PURSUANT TO NYSE MKTRULE 9310(A)(1)(B). FINE PAID BY WIRE AUGUST 9, 2017.

Firm Statement FINE PAID BY WIRE AUGUST 9, 2017.



Disclosure 3 of 25

i


Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOSUBMIT THE CANCEL TYPE CODE AS P AND THE CORRECT NUMBER OFCANCELLED SHARES FOR THE CANCEL QUANTITY TO THE ORDER AUDITTRAIL SYSTEM (OATS) IN ONE INSTANCE, AND A CANCEL REPORT TO OATSIN ONE INSTANCE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRMSUBMITTED OATS REPORTS THAT INCORRECTLY INDICATED THAT THEORDERS INVOLVED FULL RATHER THAN PARTIAL CANCELLATIONS.THROUGH ITS OWN INVESTIGATION, THE FIRM DISCOVERED THAT ITSUBMITTED APPROXIMATELY 1,000 OATS REPORTS WITH THE INCORRECT "F" CODE ON THREE SAMPLED TRADE DATES IN 2015. FINRA'SINVESTIGATION REVEALED THAT THE FIRM INCORRECTLY SUBMITTEDAPPROXIMATELY 1,000 REPORTS TO OATS PER DAY INDICATING A FULLCANCELLATION BETWEEN JANUARY 1, 2013, AND DECEMBER 7, 2015.THESE 1,000 REPORTS REPRESENTED LESS THAN ONE PERCENT OF THE700,000 REPORTS THE FIRM TRANSMITTED TO OATS ON A DAILY BASISDURING THIS TIME PERIOD.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2015044227001





Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. FINE PAID IN FULL ON JUNE28, 2017.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOSUBMIT THE CANCEL TYPE CODE AS P AND THE CORRECT NUMBER OFCANCELLED SHARES FOR THE CANCEL QUANTITY TO THE ORDER AUDITTRAIL SYSTEM (OATS) IN ONE INSTANCE, AND A CANCEL REPORT TO OATSIN ONE INSTANCE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRMSUBMITTED OATS REPORTS THAT INCORRECTLY INDICATED THAT THEORDERS INVOLVED FULL RATHER THAN PARTIAL CANCELLATIONS.THROUGH ITS OWN INVESTIGATION, THE FIRM DISCOVERED THAT ITSUBMITTED APPROXIMATELY 1,000 OATS REPORTS WITH THE INCORRECT "F" CODE ON THREE SAMPLED TRADE DATES IN 2015. FINRA'SINVESTIGATION REVEALED THAT THE FIRM INCORRECTLY SUBMITTEDAPPROXIMATELY 1,000 REPORTS TO OATS PER DAY INDICATING A FULLCANCELLATION BETWEEN JANUARY 1, 2013, AND DECEMBER 7, 2015.THESE 1,000 REPORTS REPRESENTED LESS THAN ONE PERCENT OF THE700,000 REPORTS THE FIRM TRANSMITTED TO OATS ON A DAILY BASISDURING THIS TIME PERIOD.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOSUBMIT THE CANCEL TYPE CODE AS P AND THE CORRECT NUMBER OFCANCELLED SHARES FOR THE CANCEL QUANTITY TO THE ORDER AUDITTRAIL SYSTEM (OATS) IN ONE INSTANCE, AND A CANCEL REPORT TO OATSIN ONE INSTANCE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRMSUBMITTED OATS REPORTS THAT INCORRECTLY INDICATED THAT THEORDERS INVOLVED FULL RATHER THAN PARTIAL CANCELLATIONS.THROUGH ITS OWN INVESTIGATION, THE FIRM DISCOVERED THAT ITSUBMITTED APPROXIMATELY 1,000 OATS REPORTS WITH THE INCORRECT "F" CODE ON THREE SAMPLED TRADE DATES IN 2015. FINRA'SINVESTIGATION REVEALED THAT THE FIRM INCORRECTLY SUBMITTEDAPPROXIMATELY 1,000 REPORTS TO OATS PER DAY INDICATING A FULLCANCELLATION BETWEEN JANUARY 1, 2013, AND DECEMBER 7, 2015.THESE 1,000 REPORTS REPRESENTED LESS THAN ONE PERCENT OF THE700,000 REPORTS THE FIRM TRANSMITTED TO OATS ON A DAILY BASISDURING THIS TIME PERIOD.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. FINE PAID BY WIRE JUNE28, 2017.

Firm Statement FINE PAID BY WIRE JUNE 28, 2017.



Disclosure 4 of 25

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITIMPROPERLY SUBMITTED DUPLICATE CONTRARY EXERCISE ADVICES("CEAS"), AND FAILED TO CORRECT THESE ERRORS PRIOR TO THE 7:30P.M. E.T. CUT-OFF TIME.

THE FINDINGS STATED THAT ON AUGUST 17, 2012, THE FIRM RECEIVEDINSTRUCTIONS FROM A CUSTOMER TO "DO NOT EXERCISE" ("DNE") 20CAT 18 AUG 90 CALLS. HOWEVER, THE CEA SUBMITTED BY THE FIRM INCONNECTION WITH THIS REQUEST WAS ERRONEOUSLY SUBMITTEDTWICE TO THE OPTIONS CLEARING CORPORATION ("OCC"). TO CORRECTTHE RESULTING IMBALANCE IN ITS POSITIONS FROM THE DUPLICATESUBMISSIONS, THE FIRM EFFECTED CORRESPONDING TRANSACTIONSTO CLOSE ITS POSITION IN THE CAT CALLS, RESULTING IN A LOSS TO THEFIRM OF $3,103. ON SEPTEMBER 21, 2012, THE FIRM RECEIVEDINSTRUCTIONS FROM A CUSTOMER TO DNE 50 AAPL 22 SEP 700 CALLS.HOWEVER, THE CEA SUBMITTED BY THE FIRM IN CONNECTION WITH THISREQUEST WAS ALSO ERRONEOUSLY SUBMITTED TWICE TO OCC. TOCORRECT THE RESULTING IMBALANCE IN ITS POSITIONS FROM THEDUPLICATE SUBMISSIONS, THE FIRM EFFECTED CORRESPONDINGTRANSACTIONS TO CLOSE ITS POSITION IN THE AAPL CALLS, RESULTINGIN A PROFIT TO THE FIRM OF $47,514.

THE FINDINGS ALSO STATED THAT THE FIRM THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND BZX RULES, CONCERNINGTHE SUBMISSION OF CEAS. SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM WAS NOT ADEQUATE TO PREVENT THE SUBMISSION OFDUPLICATE CEAS. ADDITIONALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES ("WSPS") FAILED TO REFERENCE THE APPROPRIATEENTITY WITH WHICH A MEMORANDUM IS TO BE FILED WHEN MAKING AFINAL EXERCISE DECISION AFTER THE EXERCISE CUT-OFF TIME WITHOUTHAVING SUBMITTED A CEA.








Initiated By: BATS BZX EXCHANGE, INC.







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITIMPROPERLY SUBMITTED DUPLICATE CONTRARY EXERCISE ADVICES("CEAS"), AND FAILED TO CORRECT THESE ERRORS PRIOR TO THE 7:30P.M. E.T. CUT-OFF TIME.

THE FINDINGS STATED THAT ON AUGUST 17, 2012, THE FIRM RECEIVEDINSTRUCTIONS FROM A CUSTOMER TO "DO NOT EXERCISE" ("DNE") 20CAT 18 AUG 90 CALLS. HOWEVER, THE CEA SUBMITTED BY THE FIRM INCONNECTION WITH THIS REQUEST WAS ERRONEOUSLY SUBMITTEDTWICE TO THE OPTIONS CLEARING CORPORATION ("OCC"). TO CORRECTTHE RESULTING IMBALANCE IN ITS POSITIONS FROM THE DUPLICATESUBMISSIONS, THE FIRM EFFECTED CORRESPONDING TRANSACTIONSTO CLOSE ITS POSITION IN THE CAT CALLS, RESULTING IN A LOSS TO THEFIRM OF $3,103. ON SEPTEMBER 21, 2012, THE FIRM RECEIVEDINSTRUCTIONS FROM A CUSTOMER TO DNE 50 AAPL 22 SEP 700 CALLS.HOWEVER, THE CEA SUBMITTED BY THE FIRM IN CONNECTION WITH THISREQUEST WAS ALSO ERRONEOUSLY SUBMITTED TWICE TO OCC. TOCORRECT THE RESULTING IMBALANCE IN ITS POSITIONS FROM THEDUPLICATE SUBMISSIONS, THE FIRM EFFECTED CORRESPONDINGTRANSACTIONS TO CLOSE ITS POSITION IN THE AAPL CALLS, RESULTINGIN A PROFIT TO THE FIRM OF $47,514.

THE FINDINGS ALSO STATED THAT THE FIRM THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND BZX RULES, CONCERNINGTHE SUBMISSION OF CEAS. SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM WAS NOT ADEQUATE TO PREVENT THE SUBMISSION OFDUPLICATE CEAS. ADDITIONALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES ("WSPS") FAILED TO REFERENCE THE APPROPRIATEENTITY WITH WHICH A MEMORANDUM IS TO BE FILED WHEN MAKING AFINAL EXERCISE DECISION AFTER THE EXERCISE CUT-OFF TIME WITHOUTHAVING SUBMITTED A CEA.


Resolution:


No

Sanctions Ordered: CensureMonetary/Fine $12,500.00Disgorgement/Restitution








Sanction Details: THE FIRM WAS CENSURED, FINED $12,500 AND REQUIRED TO PAY $44,411IN DISGORGEMENT.PURSUANT TO BZX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE,THIS AWC BECAME FINAL MAY 1, 2017.

Sanctions Ordered: CensureMonetary/Fine $12,500.00Disgorgement/Restitution


Initiated By: BATS BZX EXCHANGE, INC.







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITIMPROPERLY SUBMITTED DUPLICATE CONTRARY EXERCISE ADVICES("CEAS"), AND FAILED TO CORRECT THESE ERRORS PRIOR TO THE 7:30P.M. E.T. CUT-OFF TIME. THE FINDINGS ALSO STATED THAT THE FIRM THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND BZX RULES,CONCERNING THE SUBMISSION OF CEAS.



Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $12,500 AND REQUIRED TO PAY $44,411IN DISGORGEMENT. PURSUANT TO BZX RULE 8.8, THE DECISION IN THISMATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THEDECISION. THEREFORE, THIS AWC WILL BECOME FINAL MAY 1, 2017.FINE\DISGOREMENT PAID BY WIRE MAY 1, 2017.

Sanctions Ordered: Monetary/Fine $12,500.00







Sanction Details: THE FIRM WAS CENSURED, FINED $12,500 AND REQUIRED TO PAY $44,411IN DISGORGEMENT. PURSUANT TO BZX RULE 8.8, THE DECISION IN THISMATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THEDECISION. THEREFORE, THIS AWC WILL BECOME FINAL MAY 1, 2017.FINE\DISGOREMENT PAID BY WIRE MAY 1, 2017.

Firm Statement FINE\DISGOREMENT PAID BY WIRE MAY 1, 2017.

Disclosure 5 of 25

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Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM TRANSMITTED ROUTE ORCOMBINED ORDER/ROUTE REPORTS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) THAT OATS WAS UNABLE TO LINK TO THE CORRESPONDING NEWORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TOINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA.



Resolution:



No










Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.


Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM TRANSMITTED ROUTE ORCOMBINED ORDER/ROUTE REPORTS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) THAT OATS WAS UNABLE TO LINK TO THE CORRESPONDING NEWORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TOINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.FINE PAID BY WIRE2/19/2015

Firm Statement FINE PAID BY WIRE 2/19/2015



Disclosure 6 of 25

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Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCREATE AND MAINTAIN A RECORD THAT IT HAD TIMELY SENT ACCOUNTRECORDS REFLECTING CUSTOMERS' CHANGES TO THEIR INVESTMENTOBJECTIVES. THE FINDINGS STATED THAT FOLLOWING THEIMPLEMENTATION OF A DATA CENTER CONVERSION AND UNBEKNOWNSTTO THE FIRM, THE SOFTWARE AND RELATED AUTOMATED PROCESS FORNOTIFYING CUSTOMERS OF INVESTMENT OBJECTIVE CHANGES CEASEDTO FUNCTION PROPERLY WHEN THE FIRM TRANSFERRED ITS DATACENTER. THE DATA FILES CONTAINING NEW OR UPDATED CUSTOMERSUITABILITY INFORMATION FAILED TO ROUTE TO THE FIRM'S PRINTINGVENDOR SUCH THAT CHANGES IN CUSTOMERS' INVESTMENTOBJECTIVES WERE NOT SENT TO APPROXIMATELY 300,000 CUSTOMERS,DURING THE PERIOD FROM APPROXIMATELY AUGUST 2010 THROUGHNOVEMBER 2011. IN NOVEMBER 2011, A TECHNOLOGY ASSOCIATE, WHILEPERFORMING UNRELATED FUNCTIONS, DISCOVERED THAT SUITABILITY-RELATED DATA WAS RESIDING IN AN "ARCHIVE FILE" LOCATEDSOMEWHERE IN THE FIRM'S ROUTING HUB SYSTEM, AND HAD NOT BEENROUTED TO THE FIRM'S PRINTING VENDOR. THE FINDINGS ALSO STATEDTHAT ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES(WSPS) IN PLACE TO SUPERVISE COMPLIANCE WITH SEC RULE 17A-3(A)(17), THE FIRM DID NOT ESTABLISH WSPS REASONABLY DESIGNED TOMONITOR FOR AND DETECT PROBLEMS WITH THE TRANSMISSION OFUPDATED ACCOUNT INFORMATION TO CUSTOMERS.



Resolution:


No









Sanction Details: SEE ABOVE

Regulator Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM SELF-REPORTED THE ISSUE TO FINRA, REWROTE ITSSOFTWARE TO CORRECT THE PROBLEM, MAILED NOTIFICATIONS TO ALLOF THE AFFECTED CUSTOMERS BY DECEMBER 13, 2011 INFORMING THEMOF THE CHANGES IN THEIR INVESTMENT OBJECTIVES, AND REVISED ITSWSPS.

FINE PAID IN FULL ON JULY 16, 2014.


No



Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCREATE AND MAINTAIN A RECORD THAT IT HAD TIMELY SENT ACCOUNTRECORDS REFLECTING CUSTOMERS' CHANGES TO THEIR INVESTMENTOBJECTIVES. THE FINDINGS STATED THAT FOLLOWING THEIMPLEMENTATION OF A DATA CENTER CONVERSION AND UNBEKNOWNSTTO THE FIRM, THE SOFTWARE AND RELATED AUTOMATED PROCESS FORNOTIFYING CUSTOMERS OF INVESTMENT OBJECTIVE CHANGES CEASEDTO FUNCTION PROPERLY WHEN THE FIRM TRANSFERRED ITS DATACENTER. THE DATA FILES CONTAINING NEW OR UPDATED CUSTOMERSUITABILITY INFORMATION FAILED TO ROUTE TO THE FIRM'S PRINTINGVENDOR SUCH THAT CHANGES IN CUSTOMERS' INVESTMENTOBJECTIVES WERE NOT SENT TO APPROXIMATELY 300,000 CUSTOMERS,DURING THE PERIOD FROM APPROXIMATELY AUGUST 2010 THROUGHNOVEMBER 2011.THE FINDINGS ALSO STATED THAT ALTHOUGH THE FIRMHAD WRITTEN SUPERVISORY PROCEDURES (WSPS) IN PLACE TOSUPERVISE COMPLIANCE WITH SEC RULE 17A-3(A)(17), THE FIRM DID NOTESTABLISH WSPS REASONABLY DESIGNED TO MONITOR FOR ANDDETECT PROBLEMS WITH THE TRANSMISSION OF UPDATED ACCOUNTINFORMATION TO CUSTOMERS.







Initiated By: FINRA








Resolution:



Firm Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM SELF-REPORTED THE ISSUE TO FINRA, REWROTE ITSSOFTWARE TO CORRECT THE PROBLEM, MAILED NOTIFICATIONS TO ALLOF THE AFFECTED CUSTOMERS BY DECEMBER 13, 2011 INFORMING THEMOF THE CHANGES IN THEIR INVESTMENT OBJECTIVES, AND REVISED ITSWSPS.FINE PAID BY WIRE JULY 16, 2014.



Disclosure 7 of 25

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN EQUITYSECURITIES THAT RESULTED FROM A SALE, AND DID NOT CLOSE THEFAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KINDAND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE204(A) AND HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARINGAGENCY IN AN EQUITY SECURITY THAT RESULTED FROM A LONG SALE,AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITION BY PURCHASINGSECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAMEPRESCRIBED BY SEC RULE 204(A)(1). THE FINDINGS STATED THAT THEFIRM FAILED TO SUBMIT ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) AND INCORRECTLY SUBMITTED CUSTOMER INSTRUCTION FLAGSOF "Y" TO OATS. THE FIRM FAILED TO REPORT TRADES TO THE OVER THECOUNTER TRADE REPORTING FACILITY (OTCRF), INCORRECTLYREPORTED TRADES AS AN AGENCY CROSS TO THE OTCRF, ANDREPORTED ERRONEOUS TRADES TO THE OTCRF. THE FIRM FAILED TOPROVIDE CUSTOMER ORDER TICKETS, FAILED TO PROVIDE CUSTOMERORDER TICKETS WITH ORDER RECEIPT TIME, EXECUTION TIME, PRICE,AND TERMS AND CONDITIONS OF THE ORDER, FAILED TO PROVIDEEXECUTION TIMES ON ITS LEDGER, AND FAILED TO PROVIDE LEDGERSFOR ITS PRINCIPAL ACTIVITY. THE FINDINGS ALSO STATED THAT THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOCERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/ORFINRA AND SEC RULES. THE FIRM'S WRITTEN SUPERVISORYPROCEDURES (WSPS) FAILED TO PROVIDE FOR ONE OR MORE OF THEFOUR MINIMAL REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES IN THE FOLLOWING SUBJECT AREAS: TRADE REPORTING(ACCURATE AND TIMELY TRF REPORTING); OATS (CLOCKSYNCHRONIZATION); OATS REPORTING; AND OTHER RULES (BOOKS ANDRECORDS).








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN EQUITYSECURITIES THAT RESULTED FROM A SALE, AND DID NOT CLOSE THEFAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KINDAND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE204(A) AND HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARINGAGENCY IN AN EQUITY SECURITY THAT RESULTED FROM A LONG SALE,AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITION BY PURCHASINGSECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAMEPRESCRIBED BY SEC RULE 204(A)(1). THE FINDINGS STATED THAT THEFIRM FAILED TO SUBMIT ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) AND INCORRECTLY SUBMITTED CUSTOMER INSTRUCTION FLAGSOF "Y" TO OATS. THE FIRM FAILED TO REPORT TRADES TO THE OVER THECOUNTER TRADE REPORTING FACILITY (OTCRF), INCORRECTLYREPORTED TRADES AS AN AGENCY CROSS TO THE OTCRF, ANDREPORTED ERRONEOUS TRADES TO THE OTCRF. THE FIRM FAILED TOPROVIDE CUSTOMER ORDER TICKETS, FAILED TO PROVIDE CUSTOMERORDER TICKETS WITH ORDER RECEIPT TIME, EXECUTION TIME, PRICE,AND TERMS AND CONDITIONS OF THE ORDER, FAILED TO PROVIDEEXECUTION TIMES ON ITS LEDGER, AND FAILED TO PROVIDE LEDGERSFOR ITS PRINCIPAL ACTIVITY. THE FINDINGS ALSO STATED THAT THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOCERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/ORFINRA AND SEC RULES. THE FIRM'S WRITTEN SUPERVISORYPROCEDURES (WSPS) FAILED TO PROVIDE FOR ONE OR MORE OF THEFOUR MINIMAL REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES IN THE FOLLOWING SUBJECT AREAS: TRADE REPORTING(ACCURATE AND TIMELY TRF REPORTING); OATS (CLOCKSYNCHRONIZATION); OATS REPORTING; AND OTHER RULES (BOOKS ANDRECORDS).


Resolution:


No









Other Sanctions Ordered: UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WSPS




Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN EQUITYSECURITIES THAT RESULTED FROM A SALE, AND DID NOT CLOSE THEFAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KINDAND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE204(A) AND HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARINGAGENCY IN AN EQUITY SECURITY THAT RESULTED FROM A LONG SALE,AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITION BY PURCHASINGSECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAMEPRESCRIBED BY SEC RULE 204(A)(1). THE FINDINGS STATED THAT THEFIRM FAILED TO SUBMIT ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) AND INCORRECTLY SUBMITTED CUSTOMER INSTRUCTION FLAGSOF "Y" TO OATS. THE FIRM FAILED TO REPORT TRADES TO THE OVER THECOUNTER TRADE REPORTING FACILITY (OTCRF), INCORRECTLYREPORTED TRADES AS AN AGENCY CROSS TO THE OTCRF, ANDREPORTED ERRONEOUS TRADES TO THE OTCRF. THE FIRM FAILED TOPROVIDE CUSTOMER ORDER TICKETS, FAILED TO PROVIDE CUSTOMERORDER TICKETS WITH ORDER RECEIPT TIME, EXECUTION TIME, PRICE,AND TERMS AND CONDITIONS OF THE ORDER, FAILED TO PROVIDEEXECUTION TIMES ON ITS LEDGER, AND FAILED TO PROVIDE LEDGERSFOR ITS PRINCIPAL ACTIVITY. THE FINDINGS ALSO STATED THAT THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOCERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/ORFINRA AND SEC RULES. THE FIRM'S WRITTEN SUPERVISORYPROCEDURES (WSPS) FAILED TO PROVIDE FOR ONE OR MORE OF THEFOUR MINIMAL REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES IN THE FOLLOWING SUBJECT AREAS: TRADE REPORTING(ACCURATE AND TIMELY TRF REPORTING); OATS (CLOCKSYNCHRONIZATION); OATS REPORTING; AND OTHER RULES (BOOKS ANDRECORDS).














Resolution:

Other Sanctions Ordered: UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WSPS

Sanction Details: SEE ABOVEFINE PAID BY WIRE 04/25/2014.

Firm Statement FINE PAID BY WIRE 04/25/2014.



Disclosure 8 of 25

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Allegations: FINRA RULES 2010, 2360(B)(5), NASD RULES 2110, 2860(B)(5), 3010 - TDAMERITRADE CLEARING, INC. FAILED TO AGGREGATE POSITIONSPROPERLY AS ACTING IN CONCERT (AIC) BY REPRESENTATIVE CODE ATTHE INDEPENDENT REGISTERED INVESTMENT ADVISOR (RIA) LEVELWITHIN THE FIRM, IMPACTING APPROXIMATELY 4,099 ACCOUNTS ANDRESULTING IN THE FIRM FAILING TO REPORT APPROXIMATELY 1.4 MILLIONPOSITIONS THAT WERE REPORTABLE TO THE SECURITIES INDUSTRYAUTOMATION CORPORATION (SAIC) LARGE OPTIONS POSITIONS REPORT(LOPR). FOR APPROXIMATELY SIX YEARS, THE FIRM FAILED TOIMPLEMENT A REASONABLE SUPERVISORY SYSTEM TO ACHIEVECOMPLIANCE WITH RULES RELATING TO LOPR REPORTING, SPECIFICALLYTHOSE RELATING TO IN CONCERT REPORTING AND THE ACCURACY OFLOPR SUBMISSIONS. THE FIRM FAILED TO ESTABLISH AND MAINTAINADEQUATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDINGADEQUATE WRITTEN SUPERVISORY PROCEDURES, TO ACHIEVECOMPLIANCE WITH RULES RELATING TO LOPR REPORTING. (LOPR DATA ISUSED EXTENSIVELY TO IDENTIFY AND DETER THE ESTABLISHMENT OFOPTIONS POSITIONS THAT MAY PROVIDE AN INCENTIVE TO MANIPULATETHE UNDERLYING MARKET. THE ACCURACY OF LOPR DATA IS ESSENTIALFOR THE ANALYSIS OF POTENTIAL VIOLATIONS RELATED TO INSIDERTRADING, POSITION LIMITS, EXERCISE LIMITS, FRONT-RUNNING, CAPPINGAND PEGGING, MINI-MANIPULATION, AND MARKING-THE-CLOSE.)








Initiated By: FINRA







FINRA RULES 2010, 2360(B)(5), NASD RULES 2110, 2860(B)(5), 3010 - TDAMERITRADE CLEARING, INC. FAILED TO AGGREGATE POSITIONSPROPERLY AS ACTING IN CONCERT (AIC) BY REPRESENTATIVE CODE ATTHE INDEPENDENT REGISTERED INVESTMENT ADVISOR (RIA) LEVELWITHIN THE FIRM, IMPACTING APPROXIMATELY 4,099 ACCOUNTS ANDRESULTING IN THE FIRM FAILING TO REPORT APPROXIMATELY 1.4 MILLIONPOSITIONS THAT WERE REPORTABLE TO THE SECURITIES INDUSTRYAUTOMATION CORPORATION (SAIC) LARGE OPTIONS POSITIONS REPORT(LOPR). FOR APPROXIMATELY SIX YEARS, THE FIRM FAILED TOIMPLEMENT A REASONABLE SUPERVISORY SYSTEM TO ACHIEVECOMPLIANCE WITH RULES RELATING TO LOPR REPORTING, SPECIFICALLYTHOSE RELATING TO IN CONCERT REPORTING AND THE ACCURACY OFLOPR SUBMISSIONS. THE FIRM FAILED TO ESTABLISH AND MAINTAINADEQUATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDINGADEQUATE WRITTEN SUPERVISORY PROCEDURES, TO ACHIEVECOMPLIANCE WITH RULES RELATING TO LOPR REPORTING. (LOPR DATA ISUSED EXTENSIVELY TO IDENTIFY AND DETER THE ESTABLISHMENT OFOPTIONS POSITIONS THAT MAY PROVIDE AN INCENTIVE TO MANIPULATETHE UNDERLYING MARKET. THE ACCURACY OF LOPR DATA IS ESSENTIALFOR THE ANALYSIS OF POTENTIAL VIOLATIONS RELATED TO INSIDERTRADING, POSITION LIMITS, EXERCISE LIMITS, FRONT-RUNNING, CAPPINGAND PEGGING, MINI-MANIPULATION, AND MARKING-THE-CLOSE.)


Resolution:


Sanction Details: IN SETTLING THIS MATTER, FINRA TOOK INTO CONSIDERATION THEREMEDIAL STEPS TAKEN BY THE FIRM, INCLUDING ENHANCEMENTS TOITS SUPERVISORY SYSTEMS, RETENTION OF AN INDEPENDENTCONSULTANT, AND A PLAN TO IMPLEMENT SUCH CONSULTANT'SRECOMMENDATIONS WITH REGARD TO THE FIRM'S REPORTING TO ANDSUPERVISION OF LOPR. WITHOUT ADMITTING OR DENYING THE FINDINGS,THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED$1,150,000. FINE PAID IN FULL ON NOVEMBER 21, 2013.


No

Sanctions Ordered: CensureMonetary/Fine $1,150,000.00











Initiated By: FINRA









Resolution:


Sanction Details: IN SETTLING THIS MATTER, FINRA TOOK INTO CONSIDERATION THEREMEDIAL STEPS TAKEN BY THE FIRM, INCLUDING ENHANCEMENTS TOITS SUPERVISORY SYSTEMS, RETENTION OF AN INDEPENDENTCONSULTANT, AND A PLAN TO IMPLEMENT SUCH CONSULTANT'SRECOMMENDATIONS WITH REGARD TO THE FIRM'S REPORTING TO ANDSUPERVISION OF LOPR. WITHOUT ADMITTING OR DENYING THE FINDINGS,THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED$1,150,000.FINE PAID BY WIRE 11/21/2013.









IN SETTLING THIS MATTER, FINRA TOOK INTO CONSIDERATION THEREMEDIAL STEPS TAKEN BY THE FIRM, INCLUDING ENHANCEMENTS TOITS SUPERVISORY SYSTEMS, RETENTION OF AN INDEPENDENTCONSULTANT, AND A PLAN TO IMPLEMENT SUCH CONSULTANT'SRECOMMENDATIONS WITH REGARD TO THE FIRM'S REPORTING TO ANDSUPERVISION OF LOPR. WITHOUT ADMITTING OR DENYING THE FINDINGS,THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED$1,150,000.FINE PAID BY WIRE 11/21/2013.

Firm Statement FINE PAID BY WIRE 11/21/2013.

Disclosure 9 of 25

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Initiated By: FINRA





Principal Product Type: Equity - OTC


Allegations: FINRA RULE 7330(D)(4) - TD AMERITRADE CLEARING, INC. FAILED TOREPORT THE CORRECT EXECUTION TIME TO THE OVER-THE-COUNTERREPORTING FACILITY (OTCRF) IN OVER 250,000 NON-MEDIA REPORTEDTRANSACTIONS IN OTC EQUITY SECURITIES.



Resolution:



No









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000. FINE PAID INFULL ON 1/4/2013.


Initiated By: FINRA







Allegations: FINRA RULE 7330(D)(4) - TD AMERITRADE CLEARING, INC. FAILED TOREPORT THE CORRECT EXECUTION TIME TO THE OVER-THE-COUNTERREPORTING FACILITY (OTCRF) IN OVER 250,000 NON-MEDIA REPORTEDTRANSACTIONS IN OTC EQUITY SECURITIES.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.FIRM PAID INFULL BY WIRE ON 01/04/2013.

Firm Statement FINED $10,000.00 - FIRM PAID BY WIRE ON 01/04/2013.



Disclosure 10 of 25

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Reporting Source: Firm







Initiated By: THE OPTIONS CLEARING CORPORATION




Docket/Case Number: 2011-5



Allegations: TD AMERITRADE VIOLATED OCC RULES 502(A) AND 605 IN THAT TDAMERITRADE FAILED TO TIMELY MEET ITS MORNING SETTLEMENTOBLIGATION IN THE AMOUNT OF $507,407,809.50, BY 9:00AM, CENTRAOLTIME, AS ITS DESIGNATED SETTLEMENT BANK, BANK OF NEW YORKMELLON, DID NOT APPROVE MORNING SETTLEMENTS INSTRUCTIONSISSUED BY OCC UNTIL APPROXIMATELY 9:08AM, CENTRAL TIME.



Resolution:


Sanction Details: TD AMERITRADE, WITHOUT ADMITTING OR DENYING THE ALLEGATIONSCONTAINED IN THE CHARGES, CONSENTED TO THE ENTRY OF A FINALDECISION BY THE DISCIPLINARY COMMITTEE PROVIDING FOR THEIMPOSITION OF A FINE IN THE AMOUNT OF TWENTY-FIVE THOUSAND ANDNO\100 DOLLARS (25,000.00)

Firm Statement FINED $25,000 - FIRM PAID BY WIRE ON 12/6/2011



Disclosure 11 of 25

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Allegations: NASDAQ RULES 2110, 3010 - TD AMERITRADE CLEARING'S SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE NOTREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TOMEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OFERRONEOUS ORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLYERRONEOUS TRANSACTION COMPLAINTS.







Initiated By: NASDAQ STOCK MARKET







NASDAQ RULES 2110, 3010 - TD AMERITRADE CLEARING'S SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE NOTREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TOMEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OFERRONEOUS ORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLYERRONEOUS TRANSACTION COMPLAINTS.


Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD NOTICE TO MEMBERS 04-66 WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NASDAQ REVIEWCOUNCIL.


No




Allegations: TD AMERITRADE CLEARING'S SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS (INCLUDING NASD NOTICE TO MEMBERS 04-66) ANDNASDAQ RULES CONCERNING THE PREVENTION OF ERRONEOUSORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLY ERRONEOUSTRANSACTION COMPLAINTS.







Initiated By: NASDAQ STOCK MARKET







TD AMERITRADE CLEARING'S SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS (INCLUDING NASD NOTICE TO MEMBERS 04-66) ANDNASDAQ RULES CONCERNING THE PREVENTION OF ERRONEOUSORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLY ERRONEOUSTRANSACTION COMPLAINTS.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD NOTICE TO MEMBERS 04-66 WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NASDAQ REVIEWCOUNCIL.

Firm Statement FINED $10,000 - FIRM PAID BY WIRE ON 07/13/2010.



Disclosure 12 of 25

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Allegations: FINRA RULES 2010, 6622(G), NASD RULES 2110, 3010, 6620(G) - TDAMERITRADE CLEARING, INC. REPORTED NUMEROUS LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES TO THE OTCREPORTING FACILITY IT WAS NOT REQUIRED TO REPORT. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING TRADEREPORTING FOR TRANSACTIONS EXECUTED AND REPORTED BY WAY OFA GIVE-UP AGREEMENT.







Initiated By: FINRA







FINRA RULES 2010, 6622(G), NASD RULES 2110, 3010, 6620(G) - TDAMERITRADE CLEARING, INC. REPORTED NUMEROUS LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES TO THE OTCREPORTING FACILITY IT WAS NOT REQUIRED TO REPORT. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING TRADEREPORTING FOR TRANSACTIONS EXECUTED AND REPORTED BY WAY OFA GIVE-UP AGREEMENT.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TRADEREPORTING FOR TRANSACTIONS EXECUTED AND REPORTED BY WAY OFA GIVE-UP AGREEMENT WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC.


No




Allegations: TD AMERITRADE CLEARING, INC. REPORTED NUMEROUS LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES IT WAS NOTREQUIRED TO REPORT. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDFINRA RULES CONCERNING TRADE REPORTING FOR TRANSACTIONSEXECUTED AND REPORTED BY WAY OF A GIVE-UP AGREEMENT.








Initiated By: FINRA







TD AMERITRADE CLEARING, INC. REPORTED NUMEROUS LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES IT WAS NOTREQUIRED TO REPORT. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDFINRA RULES CONCERNING TRADE REPORTING FOR TRANSACTIONSEXECUTED AND REPORTED BY WAY OF A GIVE-UP AGREEMENT.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TRADEREPORTING FOR TRANSACTIONS EXECUTED AND REPORTED BY WAY OFA GIVE-UP AGREEMENT WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC.

Firm Statement FINED $12,500 - FIRM PAID BY WIRE ON 06/17/2010.



Disclosure 13 of 25

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Reporting Source: Firm

Initiated By: STATE OF DELAWARE


Docket/Case Number: 05-12-02

Allegations: VIOLATION OF 6 DEL.C SECTION 7316(A)(10)









Other


ADMINISTRATIVE




Resolution:


Sanction Details: PAID $40,000.00 BY CHECK ON 11/19/2009

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, TD AMERITRADECLEARING, INC CONSENTED TO ENTRY OF THE ORDER.


Decision & Order of Offer of Settlement

Disclosure 14 of 25

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Initiated By: FINRA







Allegations: NASD RULE 6955(A) - TD AMERITRADE CLEARING, INC. TRANSMITTED TOTHE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS; THE FIRM FAILED TO REPAIR SOME OF THE REJECTED ROES.THE FIRM TRANSMITTED TO OATS ROUTE OR COMBINED/ROUTEREPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THERELATED ORDER ROUTED TO NASDAQ DUE TO INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM FAILED TOTIMELY REPORT ROES TO OATS.










Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $47,500.


No




Initiated By: FINRA







Allegations: NASD RULE 6955(A) - TD AMERITRADE CLEARING, INC TRANSMITTED TOTHE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS; THE FIRM FAILED TO REPAIR SOME OF THE REJECTED ROES.THE FIRM TRANSMITTED TO OATS ROUTE OR COMBINED/ROUTEREPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THERELATED ORDER ROUTED TO NASDAQ DUE TO INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM FAILED TOTIMELY REPORT ROES TO OATS.










Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEFIRM IS CENSURED AND FINED $47,500.00.



Disclosure 15 of 25

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Initiated By: FINRA







Allegations: SEC RULE 203(B)(1) OF REGULATION SHO - TD AMERITRADE CLEARINGINC. ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROMANOTHER PERSON, OR EFFECTED SHORT SALES IN AN EQUITY SECURITYFOR ITS OWN ACCOUNT WITHOUT BORROWING THE SECURITY ORENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY;HAVING REASONABLE GROUNDS TO BELIEVE THE SECURITY COULD BEBORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY ISDUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OFREGULATION SHO.



Resolution:


No











No



Initiated By: FINRA







Allegations: SEC RULE 203(B)(1) OF REGULATION SHO - TD AMERITRADE CLEARINGINC. ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROMANOTHER PERSON, OR EFFECTED SHORT SALES IN AN EQUITY SECURITYFOR ITS OWN ACCOUNT WITHOUT BORROWING THE SECURITY ORENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY;HAVING REASONABLE GROUNDS TO BELIEVE THE SECURITY COULD BEBORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY ISDUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OFREGULATION SHO.



Resolution:









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000. FIRM PAID FULLFINE 10/07/2008.


Disclosure 16 of 25

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Initiated By: FINRA







Allegations: NASD RULE 6955(A) - TD AMERITRADE CLEARING, INC. SUBMITTED TOOATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATSSYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDERSUBMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA.



Resolution:




No











Initiated By: FINRA







Allegations: NASD RULE 6955(A) - TD AMERITRADE CLEARING, INC. SUBMITTED TOOATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATSSYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDERSUBMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000. FIRM PAID FULLFINE 01/25/2008.



Disclosure 17 of 25

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Allegations: NASD RULES 2110, 3010, 6955(A) - AMERITRADE, INC. SUBMITTED TO OATSREPORTABLE ORDER EVENTS (ROES) THAT WERE REJECTED BY OATSFOR CONTEXT OR SYNTAX ERRORS AND THE FIRM FAILED TO REPAIRMOST OF THE REJECTED ROES. THE FIRM'S SUPERVISORY SYSTEMFAILED TO PROVIDE FOR SUPERVSION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING OATS.








Initiated By: NASD






Other Product Type(s): UNKNOWN TYPE OF SECURITIES



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND REQUIRED TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGRDINGOATS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.


No












Initiated By: NASD


Censure








Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, AND REQUIRED TO REVISE THEFIRM'S WRITTEN SUPERVISORY PROCEDURES REGRDING OATS WITHIN30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. FINED$12,500 - FIRM PAID BY WIRE ON 05/17/2007.



Disclosure 18 of 25

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Initiated By: NASD



Allegations: NASD RULE 6955(A) - AMERITRADE, INC. FAILED TO TIMELY REPORT TOOATS REPORTABLE ORDER EVENTS.















Resolution:




No




Initiated By: NASD







Allegations: NASD RULE 6955(A) - AMERITRADE, INC. FAILED TO TIMELY REPORT TOOATS REPORTABLE ORDER EVENTS.











Resolution:


Sanction Details: 3-22-07 $10,000 WIRE PAID

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $10,000.



Disclosure 19 of 25

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Allegations: SINCE 2002, AMERITRADE HAS MAINTAINED AN INDEPENDENTINVESTMENT ADVISER TRADING PLATFORM. IN OR ABOUT JUNE 2003,AMERITRADE CONTRACTED WITH A THIRD PARTY TO ENGAGE INREGISTRATION VERIFICATIONS OF EACH INDEPENDENT INVESTMENTADVISER SEEKING TO UTILIZE THE TRADING PLATFORM. AMERITRADE'SWRITTEN POLICIES AND PROCEDURES STATED THAT AMERITRADE WILLNOT ENTER INTO A RELATIONSHIP WITH AN INDEPENDENT INVESTMENTADVISER UNTIL THE THIRD PARTY CONTRACTOR VERIFIED THEREGISTRATION STATUS OF THE INDEPENDENT INVESTMENT ADVISER.HOWEVER, IN OR ABOUT APRIL 2004 AND IN OR ABOUT OCTOBER 2004,AMERITRADE WAS INFORMED BY THE THIRD PARTY CONTRACTOR THATMULTIPLE INVESTMENT ADVISERS ON THE PLATFORM AND LOCATED INTEXAS WERE NOT APPROPRIATELY REGISTERED. AMERITRADE, INVIOLATION OF BOARD RULE 115.10(B)(1), FAILED TO ENFORCE ITSWRITTEN PROCEDURES BY FAILING TO DIRECT ITS EMPLOYEES TOIMMEDIATELY FOLLOW-UP AND PREVENT ANY THESE UNREGISTEREDINVESTMENT ADVISERS FROM CONTINUING TO USE AMERITRADE'SPLATFORM UNTIL AS LAST AS ON OR ABOUT DECEMBER 7, 2005.

ADDITIONALLY, UNTIL APRIL 4, 2006, AMERITRADE HAD NOT ESTABLISHEDA SYSTEM OR ANY PROCEDURES REASONABLY DESIGNED TO MONITORFOR, AND ADDRESS, MANAGEMENT FEE REQUESTS BY THEINDEPENDENT INVESTMENT ADVISERS THAT COULD BE IN EXCESS OFTHE INDUSTRY STANDARDS. AMERITRADE UNDERTOOK AND AGREED TO:(1) CONTINUE UTILIZING AN INTERIM MONITORING PROGRAM THAT WASESTABLISHED ON OR ABOUT APRIL 4, 2006 UNTIL A REASONABLECOMPUTER SYSTEM WAS ESTABLISHED; (2) ESTABLISH WRITTENPROCEDURES THAT ARE REASONABLY DESIGNED TO MONITOR FOR, ANDADDRESS, POTENTIALLY EXCESSIVE MANAGEMENT FEE REQUESTS BYINDEPENDENT INVESTMENT ADVISERS; AND (3) TAKE REASONABLE STEPSTO ENFORCE ITS POLICIES AND PROCEDURES WITH RESPECT TO THETRADING PLATFORM. AMERITRADE WAS ORDERED TO COMPLY WITHTHESE TERMS.







Initiated By: TEXAS STATE SECURITIES BOARD


Censure


FINE


Docket/Case Number: IC07-CAF-03

URL for Regulatory Action:



SINCE 2002, AMERITRADE HAS MAINTAINED AN INDEPENDENTINVESTMENT ADVISER TRADING PLATFORM. IN OR ABOUT JUNE 2003,AMERITRADE CONTRACTED WITH A THIRD PARTY TO ENGAGE INREGISTRATION VERIFICATIONS OF EACH INDEPENDENT INVESTMENTADVISER SEEKING TO UTILIZE THE TRADING PLATFORM. AMERITRADE'SWRITTEN POLICIES AND PROCEDURES STATED THAT AMERITRADE WILLNOT ENTER INTO A RELATIONSHIP WITH AN INDEPENDENT INVESTMENTADVISER UNTIL THE THIRD PARTY CONTRACTOR VERIFIED THEREGISTRATION STATUS OF THE INDEPENDENT INVESTMENT ADVISER.HOWEVER, IN OR ABOUT APRIL 2004 AND IN OR ABOUT OCTOBER 2004,AMERITRADE WAS INFORMED BY THE THIRD PARTY CONTRACTOR THATMULTIPLE INVESTMENT ADVISERS ON THE PLATFORM AND LOCATED INTEXAS WERE NOT APPROPRIATELY REGISTERED. AMERITRADE, INVIOLATION OF BOARD RULE 115.10(B)(1), FAILED TO ENFORCE ITSWRITTEN PROCEDURES BY FAILING TO DIRECT ITS EMPLOYEES TOIMMEDIATELY FOLLOW-UP AND PREVENT ANY THESE UNREGISTEREDINVESTMENT ADVISERS FROM CONTINUING TO USE AMERITRADE'SPLATFORM UNTIL AS LAST AS ON OR ABOUT DECEMBER 7, 2005.

ADDITIONALLY, UNTIL APRIL 4, 2006, AMERITRADE HAD NOT ESTABLISHEDA SYSTEM OR ANY PROCEDURES REASONABLY DESIGNED TO MONITORFOR, AND ADDRESS, MANAGEMENT FEE REQUESTS BY THEINDEPENDENT INVESTMENT ADVISERS THAT COULD BE IN EXCESS OFTHE INDUSTRY STANDARDS. AMERITRADE UNDERTOOK AND AGREED TO:(1) CONTINUE UTILIZING AN INTERIM MONITORING PROGRAM THAT WASESTABLISHED ON OR ABOUT APRIL 4, 2006 UNTIL A REASONABLECOMPUTER SYSTEM WAS ESTABLISHED; (2) ESTABLISH WRITTENPROCEDURES THAT ARE REASONABLY DESIGNED TO MONITOR FOR, ANDADDRESS, POTENTIALLY EXCESSIVE MANAGEMENT FEE REQUESTS BYINDEPENDENT INVESTMENT ADVISERS; AND (3) TAKE REASONABLE STEPSTO ENFORCE ITS POLICIES AND PROCEDURES WITH RESPECT TO THETRADING PLATFORM. AMERITRADE WAS ORDERED TO COMPLY WITHTHESE TERMS.


Resolution:

Other Sanctions Ordered: NO OTHER SANCTIONS

Sanction Details: .


No


Order


Allegations: SINCE 2002, AMERITRADE HAS MAINTAINED AN INDEPENDENTINVESTMENT ADVISER TRADING PLATFORM. IN OR ABOUT JUNE 2003,AMERITRADE CONTRACTED WITH A THIRD PARTY TO ENGAGE INREGISTRATION VERIFICATIONS OF EACH INDEPENDENT INVESTMENTADVISER SEEKING TO UTILIZE THE TRADING PLATFORM.AMERITRADE'S WRITTEN POLICIES AND PROCEDURES STATED THATAMERITRADE WILL NOT ENTER INTO A RELATIONSHIP WITH ANINDEPENDENT INVESTMENT ADVISER UNTIL THE THIRD PARTYCONTRACTOR VERIFIED THE REGISTRATION STATUS OF THEINDEPENDENT INVESTMENT ADVISER. HOWEVER, IN OR ABOUT APRIL2004 AND IN OR ABOUT OCTOBER 2004, AMERITRADE WAS INFORMED BYTHE THIRD PARTY CONTRACTOR THAT MULTIPLE INVESTMENT ADVISERSON THE PLATFORM AND LOCATED IN TEXAS WERE NOT APPROPRIATELYREGISTERED. AMERITRADE, IN VIOLATION OF BOARD RULE 115.10(B)(1),FAILED TO ENFORCE ITS WRITTENPROCEDURES BY FAILING TO DIRECT ITS EMPLOYEES TO IMMEDIATELYFOLLOW-UP AND PREVENT THESE UNREGISTERED INVESTMENTADVISERS FROM CONTINUING TO USE AMERITRADE'S PLATFORM UNTILAS LATE AS ON OR ABOUT DECEMBER 7, 2005. ADDITIONALLY, UNTIL APRIL4, 2006, AMERITRADE HAD NOT ESTABLISHED A SYSTEM OR ANYPROCEDURES REASONABLY DESIGNED TO MONITOR FOR, AND ADDRESS,MANAGEMENT FEE REQUESTS BY THE INDEPENDENT INVESTMENTADVISERS THAT COULD BE IN EXCESS OF THE INDUSTRY STANDARDS.







Initiated By: TEXAS STATE SECURITIES BOARD


Censure


FINE


Docket/Case Number: 1C07-CAF-03



Allegations: SINCE 2002, AMERITRADE HAS MAINTAINED AN INDEPENDENTINVESTMENT ADVISER TRADING PLATFORM. IN OR ABOUT JUNE 2003,AMERITRADE CONTRACTED WITH A THIRD PARTY TO ENGAGE INREGISTRATION VERIFICATIONS OF EACH INDEPENDENT INVESTMENTADVISER SEEKING TO UTILIZE THE TRADING PLATFORM.AMERITRADE'S WRITTEN POLICIES AND PROCEDURES STATED THATAMERITRADE WILL NOT ENTER INTO A RELATIONSHIP WITH ANINDEPENDENT INVESTMENT ADVISER UNTIL THE THIRD PARTYCONTRACTOR VERIFIED THE REGISTRATION STATUS OF THEINDEPENDENT INVESTMENT ADVISER. HOWEVER, IN OR ABOUT APRIL2004 AND IN OR ABOUT OCTOBER 2004, AMERITRADE WAS INFORMED BYTHE THIRD PARTY CONTRACTOR THAT MULTIPLE INVESTMENT ADVISERSON THE PLATFORM AND LOCATED IN TEXAS WERE NOT APPROPRIATELYREGISTERED. AMERITRADE, IN VIOLATION OF BOARD RULE 115.10(B)(1),FAILED TO ENFORCE ITS WRITTENPROCEDURES BY FAILING TO DIRECT ITS EMPLOYEES TO IMMEDIATELYFOLLOW-UP AND PREVENT THESE UNREGISTERED INVESTMENTADVISERS FROM CONTINUING TO USE AMERITRADE'S PLATFORM UNTILAS LATE AS ON OR ABOUT DECEMBER 7, 2005. ADDITIONALLY, UNTIL APRIL4, 2006, AMERITRADE HAD NOT ESTABLISHED A SYSTEM OR ANYPROCEDURES REASONABLY DESIGNED TO MONITOR FOR, AND ADDRESS,MANAGEMENT FEE REQUESTS BY THE INDEPENDENT INVESTMENTADVISERS THAT COULD BE IN EXCESS OF THE INDUSTRY STANDARDS.


Resolution:


Sanction Details: APPLICANT PAID $200,000.00 TO THE TEXAS STATE SECURITES BOARD ON02/02/2007.

Firm Statement AMERITRADE UNDERTOOK AND AGREED TO: (1) CONTINUE UTILIZING ANINTERIM MONITORING PROGRAM THAT WAS ESTABLISHED ON OR ABOUTAPRIL 4, 2006 UNTIL A REASONABLE COMPUTER SYSTEM WASESTABLISHED; (2) ESTABLISH WRITTEN PROCEDURES THAT AREREASONABLY DESIGNED TO MONITOR FOR, AND ADDRESS, POTENTIALLYEXCESSIVE MANAGEMENT FEE REQUESTS BY INDEPENDENTINVESTMENT ADVISERS; AND (3) TAKE REASONABLE STEPS TO ENFORCEITS POLICIES AND PROCEDURES WITH RESPECT TO THE TRADINGPLATFORM. AMERITRADE WAS ORDERED TO COMPLY WITH THESETERMS.


Order






Firm Statement AMERITRADE UNDERTOOK AND AGREED TO: (1) CONTINUE UTILIZING ANINTERIM MONITORING PROGRAM THAT WAS ESTABLISHED ON OR ABOUTAPRIL 4, 2006 UNTIL A REASONABLE COMPUTER SYSTEM WASESTABLISHED; (2) ESTABLISH WRITTEN PROCEDURES THAT AREREASONABLY DESIGNED TO MONITOR FOR, AND ADDRESS, POTENTIALLYEXCESSIVE MANAGEMENT FEE REQUESTS BY INDEPENDENTINVESTMENT ADVISERS; AND (3) TAKE REASONABLE STEPS TO ENFORCEITS POLICIES AND PROCEDURES WITH RESPECT TO THE TRADINGPLATFORM. AMERITRADE WAS ORDERED TO COMPLY WITH THESETERMS.

Disclosure 20 of 25

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Initiated By: NASD




Docket/Case Number: E042004045001


Other Product Type(s): FDIC-INSURED PRODUCTS

Allegations: NASD RULES 2110 AND 3010 - RESPONDENT MEMBER FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTENPROCEDURES DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESREGARDING FDIC-INSURED PRODUCTS.



Resolution:


No









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, AMERITRADE, INC.,CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $150,000.



Initiated By: NASD




Docket/Case Number: E0420040450-01


Other Product Type(s): FDIC-INSURED PRODUCTS

Allegations: NASD RULES 2110 AND 3010 - AMERITRADE, INC. FAILED TO ESTABLISHAND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN PROCEDURESDESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIESLAWS, REGULATIONS AND NASD RULES REGARDING FDIC-INSUREDPRODUCTS.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, AMERITRADE, INC.,CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $150,000.



Disclosure 21 of 25

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Initiated By: NASD




Docket/Case Number: C04040011



Allegations: REGULATION T, PROMULGATED UNDER SECTION 7 OF THE SECURITIESEXCHANGE ACT OF 1934, NASD RULE 2110 - RESPONDENT MEMBERPERMITTED DAY TRADING IN CASH ACCOUNTS THAT IN MANY INSTANCESWOULD HAVE REQUIRED THE $25,000 MINIMUM EQUITY MANDATED BYNASD RULE 2520 AND SHOULD HAVE OCCURRED IN A MARGIN ACCOUNT;DAY TRADING WAS EFFECTED WITHOUT REQUIRING FULL CASH PAYMENTFOR EACH PURCHASE PRIOR TO ITS SALE AS REQUIRED BY REGULATIONT; PERMITTED IMPROPER TRADING BY SELLING SECURITIES WITHOUTFULL CASH PAYMENT HAVING BEEN MADE BY THE CUSTOMER AND/ORPROCEEDS FROM UNSETTLED SALE TRANSACTIONS WERE APPLIED ASPAYMENT FOR SUBSEQUENT PURCHASES; FAILED TO STOP THEVIOLATIVE DAY TRADING DESPITE VARIOUS NOTICES THAT DAY TRADINGIN CASH ACCOUNTS WAS BEING CONDUCTED IN A MANNER THAT WOULDVIOLATE REGULATION T; FAILED TO FULLY RESTRICT THE VIOLATIVE CASHACCOUNT PRACTICES AFTER NASD WRITTEN NOTICE THAT IT WASPROHIBITED; AND NETTED TRADES IN CASH ACCOUNTS INCONTRADICTION OF REGULATION T.



Resolution:



No








Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AMERITRADECONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $10,000,000,JOINTLY AND SEVERALLY, TO BE PAID WITHIN 10 DAYS OF THIS AWC.


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Other


LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C04040011, DATEDMARCH 11, 2004. DATEK ONLINE FINANCIAL SERVICES, LLC, ICLEARING,LLC AND AMERITRADE, INC. WITHOUT ADMITTING OR DENYING THEALLEGATIONS OR FINDINGS, CONSENTED TO A CENSURE AND A FINE OF$10,000,000 CONCERNING ALLEGED VIOLATIONS OF REGULATION T ANDNASD CONDUCT RULE 2110.


Docket/Case Number: C04040011



Allegations: THE AWC ALLEGED THAT "[F]ROM AT LEAST OCTOBER 2001 TO AT LEASTMAY 2003, DATEK, ICLEARING AND AMERITRADE IMPROPERLY EXTENDEDCREDIT BY PERMITTING CASH ACCOUNT CUSTOMERS TO USE THEPROCEEDS OF UNSETTLED SALE TRANSACTIONS TO FUND SUBSEQUENTPURCHASE TRANSACTIONS IN VIOLATION OF REGULATION T AND NASDCONDUCT RULE 2110." IN ADDITION, THE AWC ALLEGED THAT "[T]HERESPONDENTS CONTINUED TO PERMIT SUCH TRADING AND FAILED TOTAKE STEPS IN A TIMELY MANNER TO ENSURE COMPLIANCE WITHREGULATION T AND SECTION 7 OF THE EXCHANGE ACT."



Resolution:


Sanction Details: DATEK ONLINE FINANCIAL SERVICES, LLC, ICLEARING, LLC ANDAMERITRADE, INC., WITHOUT ADMITTING OR DENYING THE ALLEGATIONSOR FINDINGS, CONSENTED TO A CENSURE AND A JOINT AND SEVERALFINE OF $10,000,000. FINE WAS PAID ON MARCH 19, 2004, IN THE FORM OFTWO WIRE PAYMENTS TO NASD $7.8 MILLION REPRESENTING PAYMENTFOR DATEK/ICLEARING, AND $2.2 MILLION REPRESENTING PAYMENT FORAMERITRADE.








DATEK ONLINE FINANCIAL SERVICES, LLC, ICLEARING, LLC ANDAMERITRADE, INC., WITHOUT ADMITTING OR DENYING THE ALLEGATIONSOR FINDINGS, CONSENTED TO A CENSURE AND A JOINT AND SEVERALFINE OF $10,000,000. FINE WAS PAID ON MARCH 19, 2004, IN THE FORM OFTWO WIRE PAYMENTS TO NASD $7.8 MILLION REPRESENTING PAYMENTFOR DATEK/ICLEARING, AND $2.2 MILLION REPRESENTING PAYMENT FORAMERITRADE.

Disclosure 22 of 25

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Initiated By: SECURITIES AND EXCHANGE COMMISSION




Docket/Case Number:

Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement ND 76-185 09/22/76LR 757609/08/ : COMPLAINT FILED SEEKING TO ENJOIN, &SEEKING A TEMPORARY RESTRAINING ORDER.09/09/ : TEMPORARY RESTRAINING ORDER ENTERED.CONSENTED TO THE ENTRY OF THE TEMPORARYRESTRAINING ORDER.

ND 77-61 03/30/77REL 34-13411PUBLIC ADMINISTRATIVE PROCEEDINGS ORDERED.

ND 77-149 08/03/77REL 34-13799 PURSUANT TO AN OFFER OF SETTLEMENT,CERTAIN OFFICERS AND DIRECTORS OF FIRMWITHOUT ADMITTING OR DENYING THE ALLEGATIONSCONSENTED TO FINDINGS THAT FIRMWILFULLY VIOLATED CERTAIN RECORDKEEPING &NOTICE RULES UNDER THE SECURITIES EXCHANGEACT OF 1934. FIRM'S REGISTRATION SUSPENDEDFOR 5 DAYS, PROVIDED THAT IT MAY CONDUCTCERTAIN LIMITED BUSINESS DURING SUCHSUSPENSION. FIRM TO COMPLY WITH CERTAINUNDERTAKINGS INCLUDING ITS CONSENTING TOTHE ENTRY OF A PERMANENT INJUNCTION.ND 77-210 10/01/77LR 817410/18/ : FINAL JUDGMENT OF PERMANENT INJUNCTION. CONSENTEDTO ORDER WITHOUT ADMITTING ORDENYING THE ALLEGATIONS.

Sanctions Ordered: Suspension

Consent






ND 76-185 09/22/76LR 757609/08/ : COMPLAINT FILED SEEKING TO ENJOIN, &SEEKING A TEMPORARY RESTRAINING ORDER.09/09/ : TEMPORARY RESTRAINING ORDER ENTERED.CONSENTED TO THE ENTRY OF THE TEMPORARYRESTRAINING ORDER.

ND 77-61 03/30/77REL 34-13411PUBLIC ADMINISTRATIVE PROCEEDINGS ORDERED.

ND 77-149 08/03/77REL 34-13799 PURSUANT TO AN OFFER OF SETTLEMENT,CERTAIN OFFICERS AND DIRECTORS OF FIRMWITHOUT ADMITTING OR DENYING THE ALLEGATIONSCONSENTED TO FINDINGS THAT FIRMWILFULLY VIOLATED CERTAIN RECORDKEEPING &NOTICE RULES UNDER THE SECURITIES EXCHANGEACT OF 1934. FIRM'S REGISTRATION SUSPENDEDFOR 5 DAYS, PROVIDED THAT IT MAY CONDUCTCERTAIN LIMITED BUSINESS DURING SUCHSUSPENSION. FIRM TO COMPLY WITH CERTAINUNDERTAKINGS INCLUDING ITS CONSENTING TOTHE ENTRY OF A PERMANENT INJUNCTION.ND 77-210 10/01/77LR 817410/18/ : FINAL JUDGMENT OF PERMANENT INJUNCTION. CONSENTEDTO ORDER WITHOUT ADMITTING ORDENYING THE ALLEGATIONS.


Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION


Other


FIRST OMAHA SECURITIES CORPORATION WAS PERMANENTLY ENJOINEDFROM ENGAGING IN ANY ACT WHICH WOULD VIOLATE SEC RULES 15C3-1;15C3-2; 17A-3; 17A-11; AND 17A-13.


Docket/Case Number: FILE NO. 76-0-343



Allegations: IN SETTLEMENT OF SEC ACTION DATED 09/08/76, THROUGH US DISTRICTCOURT OF NEBRASKA (FILE NO. 76-0-343), FIRST OMAHA SECURITIES WASPERMANENTLY ENJOINED FROM ENGAGING IN ANY ACT WHICH WOULDVIOLATE SEC RULES 15C3-1;15C3-2;17A-3; 17A-11;17A-13.THE ABOVESANCTIONS WERE AGREED TO IN SETTLEMENT OF PROCEEDINGSWITHOUT ADMITTING OR DENYING THE ALLEGATIONS.


Resolution: Other63©2022 FINRA. All rights reserved. Report about TD AMERITRADE CLEARING, INC.






Resolution:

Other Sanctions Ordered: IN SETTLEMENT OF SEC ACTION DATED 09/08/76, THROUGH US DISTRICTCOURT OF NEBRASKA (FILE NO. 76-0-343), FIRST OMAHA SECURITIES WASPERMANENTLY ENJOINED FROM ENGAGING IN ANY ACT WHICH WOULDVIOLATE SEC RULES 15C3-1;15C3-2;17A-3; 17A-11;17A-13.THE ABOVESANCTIONS WERE AGREED TO IN SETTLEMENT OF PROCEEDINGSWITHOUT ADMITTING OR DENYING THE ALLEGATIONS.

Sanction Details: IN SETTLEMENT OF SEC ACTION DATED 09/08/76, THROUGH US DISTRICTCOURT OF NEBRASKA (FILE NO. 76-0-343), FIRST OMAHA SECURITIES WASPERMANENTLY ENJOINED FROM ENGAGING IN ANY ACT WHICH WOULDVIOLATE SEC RULES 15C3-1;15C3-2;17A-3; 17A-11;17A-13.THE ABOVESANCTIONS WERE AGREED TO IN SETTLEMENT OF PROCEEDINGSWITHOUT ADMITTING OR DENYING THE ALLEGATIONS.

Firm Statement IN SETTLEMENT OF SEC ACTION DATED 09/08/76, THROUGH US DISTRICTCOURT OF NEBRASKA (FILE NO. 76-0-343), FIRST OMAHA SECURITIES WASPERMANENTLY ENJOINED FROM ENGAGING IN ANY ACT WHICH WOULDVIOLATE SEC RULES 15C3-1;15C3-2;17A-3; 17A-11;17A-13.THE ABOVESANCTIONS WERE AGREED TO IN SETTLEMENT OF PROCEEDINGSWITHOUT ADMITTING OR DENYING THE ALLEGATIONS.

Sanctions Ordered:

Other

Disclosure 23 of 25

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Initiated By: ILLINOIS




URL for Regulatory Action:



Allegations: A NOTICE OF HEARING WAS ISSUED JANUARY 3, 1989 ALLEGINGRESPONDENT AMERITRADE, INC. FAILED TO AMEND FORM BD.AUTHROITY: SECTION 8.B(12), 11.F AND 12.D OF THE ILLINOIS SECURITIESLAW OF 1953, AS AMENDED.









Resolution:


Sanction Details: A CONSENT ORDER OF CENSURE WAS ENTERED MARCH 20, 1989 ANDINCLUDED THE IMPOSITION OF A FINE OF $500.00 BASED UPONRESPONDENT'S FAILURE TO TIMELY AMEND FORM BD WITH THE STATE OFILLINOIS. AUTHORITY: SECTION 11.F OF THE ILLINOIS SECURITIES LAW OF1953, AS AMENDED.

Sanctions Ordered: CensureMonetary/Fine $500.00

Consent


Initiated By: STATE OF ILLINOIS


Censure


FINE


Docket/Case Number: STATE OF ILLINOIS FILE NO. 88-261



Allegations: STATE OF ILLINOIS FILE NO. 88-261, CENSURED AND FINED FIRST OMAHASECURITIES CORPORATION $500.00 FOR A VIOLATION OF SECTION 12D OFTHE ILLINOIS SECURITIES ACT. IN SETTLEMENT, THE FIRM NEITHERADMITTED NOR DENIED THE ALLEGATIONS.



Resolution:

Other Sanctions Ordered: STATE OF ILLINOIS FILE NO. 88-261, CENSURED AND FINED FIRST OMAHASECURITIES CORPORATION $500.00 FOR A VIOLATION OF SECTION 12D OFTHE ILLINOIS SECURITIES ACT. IN SETTLEMENT, THE FIRM NEITHERADMITTED NOR DENIED THE ALLEGATIONS.

Sanctions Ordered: CensureMonetary/Fine $500.00

Other






Other Sanctions Ordered: STATE OF ILLINOIS FILE NO. 88-261, CENSURED AND FINED FIRST OMAHASECURITIES CORPORATION $500.00 FOR A VIOLATION OF SECTION 12D OFTHE ILLINOIS SECURITIES ACT. IN SETTLEMENT, THE FIRM NEITHERADMITTED NOR DENIED THE ALLEGATIONS.

Sanction Details: STATE OF ILLINOIS FILE NO. 88-261, CENSURED AND FINED FIRST OMAHASECURITIES CORPORATION $500.00 FOR A VIOLATION OF SECTION 12D OFTHE ILLINOIS SECURITIES ACT. IN SETTLEMENT, THE FIRM NEITHERADMITTED NOR DENIED THE ALLEGATIONS.

Firm Statement STATE OF ILLINOIS FILE NO. 88-261, CENSURED AND FINED FIRST OMAHASECURITIES CORPORATION $500.00 FOR A VIOLATION OF SECTION 12D OFTHE ILLINOIS SECURITIES ACT. IN SETTLEMENT, THE FIRM NEITHERADMITTED NOR DENIED THE ALLEGATIONS.

Disclosure 24 of 25

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Initiated By: CHICAGO BOARD OF OPTION EXCHANGE







Allegations:



Resolution:


Sanction Details:

Regulator Statement 1/27/88-CBOE DECISION ACCEPTING OFFER OF SETTLEMENT IN THEMATTER OF: AMERITRADE, INC., RESPONDENT; FILE NO. 87-0049. THISPROCEEDING WAS INSTITUTED BY THE BUSINESS CONDUCT COMMITTEEOFTHE CBOE AS A RESULT OF AN INVESTIGATION BY THE STAFF OF THEEXCHANGE, WHICH INDICATED THAT THERE WAS PROBABLE CAUSE FORFINDING A VIOLATION WITHIN THE DISCIPLINARY JURISDICTION OF THEEXCHANGE. IN SUBMITTING THIS OFFER OF SETTLEMENT, THERESPONDENT NEITHER ADMITS NOR DENIES THE VIOLATIONS ALLEGED INTHE STATEMENT OF CHARGES AND ANY ANSWER TO THE CONTRARY ISDEEMED TO BE WITHDRAWN. ON THE BASIS OF THE STATEMENT OFCHARGES AND OFFER OF SETTLEMENT, THE COMMITTEE HASDETERMINEDTO ACCEPT THE RESPONDENT'S OFFER OF SETTLEMENT BASED UPONITSFINDING OF THE FOLLOWING FACTS: DURING THE APPROXIMATE PERIODFROM JANUARY 31, 1983 THROUGH OCTOBER 7, 1986, 27 OUT OF 27 OFAMERITRADE'S OPTION CUSTOMER INFORMATION FORMS REVIEWED BYTHEEXCHANGE DID NOT INDICATE THE OPTION CUSTOMERS' ESTIMATEDLIQUID NET WORTH. DURING THE APPROXIMATE PERIOD FROM JANUARY31, 1983 THROUGH OCTOBER 7, 1986, 27 OUT OF 27 OF AMERITRADE'SOPTION CUSTOMER INFORMATION FORMS REVIEWED BY THE EXCHANGEDIDNOT INDICATE THE OPTION CUSTOMERS' MATERIAL STATUS AND NUMBEROF DEPENDENTS. THE COMMITTEE HAS DETERMINED TO ACCEPT THERESPONDENT'S OFFER OF SETTLEMENT BASED UPON ITS MAKING THEFOLLOWING CONCLUSIONS: THE ACTS, PRACTICES AND CONDUCTDESCRIBED ABOVE CONSTITUTE VIOLATIONS OF EXCHANGE RULE 9.7(b)AND INTERPRETATION AND POLICY .01(5) THEREUNDER BY AMERITRADE,IN THAT AMERITRADE DID NOT OBTAIN AND MAKE A RECORD OF THEINFORMATION DESCRIBED ABOVE; AND VIOLATION OF EXCHANGE RULE9.7(b) AND INTERPRETATION AND POLICY .01(6) THEREUNDER BYAMERITRADE, IN THAT AMERITRADE DID NOT OBTAIN AND MAKE ARECORDOF THE INFORMATION DESCRIBED ABOVE. WITH DUE REGARD FOR THEPARTICULAR FACTS OF THIS MATTER, THE COMMITTEE BELIEVES ITAPPROPRIATE TO ACCEPT THE RESPONDENT'S OFFER OF SETTLEMENTWHEREIN IT CONSEN*See FAQ #1*


Consent





www.finra.org/brokercheck User Guidance1/27/88-CBOE DECISION ACCEPTING OFFER OF SETTLEMENT IN THEMATTER OF: AMERITRADE, INC., RESPONDENT; FILE NO. 87-0049. THISPROCEEDING WAS INSTITUTED BY THE BUSINESS CONDUCT COMMITTEEOFTHE CBOE AS A RESULT OF AN INVESTIGATION BY THE STAFF OF THEEXCHANGE, WHICH INDICATED THAT THERE WAS PROBABLE CAUSE FORFINDING A VIOLATION WITHIN THE DISCIPLINARY JURISDICTION OF THEEXCHANGE. IN SUBMITTING THIS OFFER OF SETTLEMENT, THERESPONDENT NEITHER ADMITS NOR DENIES THE VIOLATIONS ALLEGED INTHE STATEMENT OF CHARGES AND ANY ANSWER TO THE CONTRARY ISDEEMED TO BE WITHDRAWN. ON THE BASIS OF THE STATEMENT OFCHARGES AND OFFER OF SETTLEMENT, THE COMMITTEE HASDETERMINEDTO ACCEPT THE RESPONDENT'S OFFER OF SETTLEMENT BASED UPONITSFINDING OF THE FOLLOWING FACTS: DURING THE APPROXIMATE PERIODFROM JANUARY 31, 1983 THROUGH OCTOBER 7, 1986, 27 OUT OF 27 OFAMERITRADE'S OPTION CUSTOMER INFORMATION FORMS REVIEWED BYTHEEXCHANGE DID NOT INDICATE THE OPTION CUSTOMERS' ESTIMATEDLIQUID NET WORTH. DURING THE APPROXIMATE PERIOD FROM JANUARY31, 1983 THROUGH OCTOBER 7, 1986, 27 OUT OF 27 OF AMERITRADE'SOPTION CUSTOMER INFORMATION FORMS REVIEWED BY THE EXCHANGEDIDNOT INDICATE THE OPTION CUSTOMERS' MATERIAL STATUS AND NUMBEROF DEPENDENTS. THE COMMITTEE HAS DETERMINED TO ACCEPT THERESPONDENT'S OFFER OF SETTLEMENT BASED UPON ITS MAKING THEFOLLOWING CONCLUSIONS: THE ACTS, PRACTICES AND CONDUCTDESCRIBED ABOVE CONSTITUTE VIOLATIONS OF EXCHANGE RULE 9.7(b)AND INTERPRETATION AND POLICY .01(5) THEREUNDER BY AMERITRADE,IN THAT AMERITRADE DID NOT OBTAIN AND MAKE A RECORD OF THEINFORMATION DESCRIBED ABOVE; AND VIOLATION OF EXCHANGE RULE9.7(b) AND INTERPRETATION AND POLICY .01(6) THEREUNDER BYAMERITRADE, IN THAT AMERITRADE DID NOT OBTAIN AND MAKE ARECORDOF THE INFORMATION DESCRIBED ABOVE. WITH DUE REGARD FOR THEPARTICULAR FACTS OF THIS MATTER, THE COMMITTEE BELIEVES ITAPPROPRIATE TO ACCEPT THE RESPONDENT'S OFFER OF SETTLEMENTWHEREIN IT CONSEN*See FAQ #1*


Initiated By: CHICAGO BOARD OPTIONS EXCHANGE (CBOE)

Allegations: CBOE FILE NO. 87-0049 DATED 12/22/87 ALLEGED VIOLATION OFEXCHANGE RULE 9 7(B). ALLEGED VIOLATION WAS DISMISSED UPON ASETTLEMENT AGREEMENT THAT NEITHER ADMITTED NOR DENIED THEALLEGATION, AND PAYMENT OF A $1,500.00 FINE.







Initiated By: CHICAGO BOARD OPTIONS EXCHANGE (CBOE)


Other


CBOE FILE NO. 87-0049 DATED 12/22/87 ALLEGED VIOLATION OFEXCHANGE RULE 9 7(B). ALLEGED VIOLATION WAS DISMISSED UPON ASETTLEMENT AGREEMENT THAT NEITHER ADMITTED NOR DENIED THEALLEGATION, AND PAYMENT OF A $1,500.00 FINE.


Docket/Case Number: CBOE FILE NO. 87-0049




Resolution:

Other Sanctions Ordered: CBOE FILE NO. 87-0049 DATED 12/22/87 ALLEGED VIOLATION OFEXCHANGE RULE 9 7(B). ALLEGED VIOLATION WAS DISMISSED UPON ASETTLEMENT AGREEMENT THAT NEITHER ADMITTED NOR DENIED THEALLEGATION, AND PAYMENT OF A $1,500.00 FINE.

Sanction Details: CBOE FILE NO. 87-0049 DATED 12/22/87 ALLEGED VIOLATION OFEXCHANGE RULE 9 7(B). ALLEGED VIOLATION WAS DISMISSED UPON ASETTLEMENT AGREEMENT THAT NEITHER ADMITTED NOR DENIED THEALLEGATION, AND PAYMENT OF A $1,500.00 FINE.

Firm Statement CBOE FILE NO. 87-0049 DATED 12/22/87 ALLEGED VIOLATION OFEXCHANGE RULE 9 7(B). ALLEGED VIOLATION WAS DISMISSED UPON ASETTLEMENT AGREEMENT THAT NEITHER ADMITTED NOR DENIED THEALLEGATION, AND PAYMENT OF A $1,500.00 FINE.


Other

Disclosure 25 of 25

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.


Docket/Case Number: AWC-7

Allegations:












Resolution:


Sanction Details:

Regulator Statement COMPLAINT #AWC-7 FILED 06/25/76DIST. #4DECISION 06/25/76: CENSURED; FINED $1,000 J&S06/25/76: FINALFINES & COSTS 07/07/76: FC #6562 PAID.


Consent


Initiated By: NATIONAL ASOCIATION OF SECURITIES DEALERS (NASD) DISTRICT 4


Censure


FINE


Docket/Case Number: AW-7



Allegations: NASD DISTRICT 4 COMPLAINT AW-7 DATED 06/21/1976, CENSURED ANDFINED FIRST OMAHA SECURITIES CORPORATION $1,000.00. THIS ACTIONWAS THE RESULT OF THE SAME MATTER REFERRED TO IN PREVIOUS DRPFILED REGARDING THE STATE OF ILLINOIS (FILE NO. 76-0-343), DATED09/08/1976.








Resolution:

Other Sanctions Ordered: NASD DISTRICT 4 COMPLAINT AW-7 DATED 06/21/1976, CENSURED ANDFINED FIRST OMAHA SECURITIES CORPORATION $1,000.00. THIS ACTIONWAS THE RESULT OF THE SAME MATTER REFERRED TO IN PREVIOUS DRPFILED REGARDING THE STATE OF ILLINOIS (FILE NO. 76-0-343), DATED09/08/1976.

Sanction Details: NASD DISTRICT 4 COMPLAINT AW-7 DATED 06/21/1976, CENSURED ANDFINED FIRST OMAHA SECURITIES CORPORATION $1,000.00. THIS ACTIONWAS THE RESULT OF THE SAME MATTER REFERRED TO IN PREVIOUS DRPFILED REGARDING THE STATE OF ILLINOIS (FILE NO. 76-0-343), DATED09/08/1976.

Firm Statement NASD DISTRICT 4 COMPLAINT AW-7 DATED 06/21/1976, CENSURED ANDFINED FIRST OMAHA SECURITIES CORPORATION $1,000.00. THIS ACTIONWAS THE RESULT OF THE SAME MATTER REFERRED TO IN PREVIOUS DRPFILED REGARDING THE STATE OF ILLINOIS (FILE NO. 76-0-343), DATED09/08/1976.


Other






Arbitration Award - Award / Judgment

Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 26


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

03/27/2000

00-01156

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; NO OTHER TYPE OF SEC INVOLVE

$19,719.00

AWARD AGAINST PARTY

10/24/2000

$13,288.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

06/09/2000

00-01847

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; OTHER-ON-LINETRADING DISPUTE

COMMON STOCK; NO OTHER TYPE OF SEC INVOLVE71©2022 FINRA. All rights reserved. Report about TD AMERITRADE CLEARING, INC.




www.finra.org/awardsonline




Disposition:

Disposition Date:



$500,000.00

AWARD AGAINST PARTY

06/08/2001

$39,431.51


Disclosure 3 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/31/2000

00-03122

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT RELATED-BREACH OF CONTRACT; OTHER-ON-LINE TRADINGDISPUTE


$80,000.00

AWARD AGAINST PARTY

07/17/2001

$12,831.25


Disclosure 4 of 26

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Arbitration Forum:

Case Initiated:

Allegations:

NASD

03/05/2001

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; OTHER-ON-LINETRADING DISPUTE






Case Initiated:

Case Number:



Disposition:

Disposition Date:


03/05/2001

01-00774


$30,900.00

AWARD AGAINST PARTY

11/20/2001

$10,363.62


Disclosure 5 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/14/2004

04-02702

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-COLLECTION; ACCOUNT RELATED-NEGLIGENCE

NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES

$10,000.00

AWARD AGAINST PARTY

09/30/2004

$0.00


Disclosure 6 of 26

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Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-MARGINCALLS; OTHER-ON-LINE TRADING DISPUTE; TRADING DISPUTES-OTHER






Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

05/03/2005

05-01777

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-MARGINCALLS; OTHER-ON-LINE TRADING DISPUTE; TRADING DISPUTES-OTHER


$50,000.00

AWARD AGAINST PARTY

08/22/2006

$4,272.00


Disclosure 7 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

02/23/2006

06-00875

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; NO OTHER CONTROVERSY INVOLVED; OTHER-ON-LINE TRADING DISPUTE


$14,000.00

AWARD AGAINST PARTY

06/22/2006

$1,825.00


Disclosure 8 of 26

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Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; OTHER-ON-LINE TRADINGDISPUTE






Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/17/2006

06-01562

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; OTHER-ON-LINE TRADINGDISPUTE

COMMON STOCK; OTHER TYPES OF SECURITIES; REVERSE REPURCHASEAGREEMENTS; WARRANTS/RIGHTS

$9,244.54

AWARD AGAINST PARTY

10/25/2006

$4,225.00


Disclosure 9 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

02/05/2008

08-00299

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; EXECUTIONS-FAILURE TO EXECUTE; TRADING DISPUTES-SELL OUTS

NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK

$21,925.00

AWARD AGAINST PARTY

12/15/2008

$21,625.00


Disclosure 10 of 26

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Disclosure 10 of 26



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

10/22/2009

09-05201

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-MARGINCALLS; TRADING DISPUTES-SELL OUTS

COMMON STOCK

$16,695.00

AWARD AGAINST PARTY

04/19/2010

$257.49


Disclosure 11 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/18/2015

15-00598

ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNTACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

OPTIONS

$24,255,008.76

AWARD AGAINST PARTY

06/07/2016

$1,050,750.00







Disclosure 12 of 26

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

02/23/2016

16-00336

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-VIOLATE OF BLUESKY LWS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; OPTIONS

$140,000.01

AWARD AGAINST PARTY

05/17/2017

$40,000.00


Disclosure 13 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



FINRA

01/24/2018

18-00253

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE; TRADING DISPUTES-OTHER

REAL ESTATE INVESTMENT TRUST

$407,050.00 77©2022 FINRA. All rights reserved. Report about TD AMERITRADE CLEARING, INC.






Disposition:

Disposition Date:


$407,050.00

AWARD AGAINST PARTY

08/29/2019

$721,116.60


Disclosure 14 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

01/07/2019

19-00085

ACCOUNT ACTIVITY-FRAUD; ACCOUNT RELATED-TRANSFER; TRADINGDISPUTES-TRANSFERS

COMMON STOCK; EXCHANGE-TRADED FUNDS; MUTUAL FUNDS

$650,000.00

AWARD AGAINST PARTY

10/30/2019

$0.00


Disclosure 15 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

02/05/2020

20-00400

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER






Case Number:



Disposition:

Disposition Date:


20-00400

COMMON STOCK; EXCHANGE-TRADED FUNDS; LIMITED PARTNERSHIPS;MUTUAL FUNDS; OPTIONS; PREFERRED STOCK

$8,000,000.01

AWARD AGAINST PARTY

09/29/2021

$2,082,148.30


Disclosure 16 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

04/07/2020

20-01050

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-MARGIN CALLS; TRADING DISPUTES-SELL OUTS

COMMON STOCK

$30,372.50

AWARD AGAINST PARTY

11/06/2020

$22,929.00


Disclosure 17 of 26

i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;NO OTHER CONTROVERSY INVOLVED






Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

01/01/1988

88-00460

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;NO OTHER CONTROVERSY INVOLVED


$169,286.00

AWARD AGAINST PARTY

11/30/1989

$941.50


Disclosure 18 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/26/1991

91-02885

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY


$85,100.00

AWARD AGAINST PARTY

08/11/1992

$22,500.00


Disclosure 19 of 26

i








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/07/1992

92-02926

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-ERRORS-CHARGES; NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK

$22,000.00

AWARD AGAINST PARTY

03/24/1993

$300.00


Disclosure 20 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/27/1996

96-03685

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; NOOTHER CONTROVERSY INVOLVED

NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$4,007.50

AWARD AGAINST PARTY

07/30/1997

$1,125.00


Disclosure 21 of 26

i






Disclosure 21 of 26



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/01/1999

98-02968

EXECUTIONS-OTHER; NO OTHER CONTROVERSY INVOLVED; OTHER-ON-LINE TRADING DISPUTE


$40,750.00

AWARD AGAINST PARTY

03/14/2000

$23,200.00


Disclosure 22 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/03/1998

98-04040

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER


$54,312.50

AWARD AGAINST PARTY

10/12/1999

$18,348.00

There may be a non-monetary award associated with this arbitration.






Please select the Case Number above to view more detailed information.

Disclosure 23 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/29/1999

98-04397

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT


$225,000.00

AWARD AGAINST PARTY

01/14/2000

$40,514.00


Disclosure 24 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

12/04/1998

98-04560

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;EXECUTIONS-OTHER


$4,000.00

AWARD AGAINST PARTY

10/05/1999






Sum of All Relief Awarded: $62.50


Disclosure 25 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/23/1999

99-00236

EXECUTIONS-FAILURE TO EXECUTE; NO OTHER CONTROVERSYINVOLVED


$10,000.00

AWARD AGAINST PARTY

01/21/2000

$9,450.00


Disclosure 26 of 26

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

05/13/1999

99-02062

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE;EXECUTIONS-FAILURE TO EXECUTE; NO OTHER CONTROVERSYINVOLVED


$22,561.00

AWARD AGAINST PARTY84©2022 FINRA. All rights reserved. Report about TD AMERITRADE CLEARING, INC.





Disposition:

Disposition Date:


AWARD AGAINST PARTY

04/07/2000

$20,561.00







End of Report

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