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BrokerCheck Report

WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC

Section Title

Report Summary

Firm History

CRD# 11025

1

10

Firm Profile 2 - 9

Page(s)

Firm Operations 11 - 27

Disclosure Events 28

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WELLS FARGO ADVISORSFINANCIAL NETWORK, LLC

CRD# 11025

SEC# 8-28721

Main Office Location

ONE NORTH JEFFERSON AVENUEH0004-05BST. LOUIS, MO 63103Regulated by FINRA Kansas City Office

Mailing Address

ONE NORTH JEFFERSON AVENUEH0004-05BST. LOUIS, MO 63103

This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:

Business Telephone Number

314-875-3000

https://www.adviserinfo.sec.gov

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 24

Arbitration 40

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/12/2003.

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 22 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC

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This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/12/2003.

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.

WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC

SEC#

11025

8-28721

Main Office Location

Mailing Address

Business Telephone Number

Doing business as WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC

314-875-3000

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?

WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC

SOLE MEMBER

75% or more

No

Domestic Entity

12/2003

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BARNEY, KATHLEEN ELLEN

CHIEF FINANCIAL OFFICER

Less than 5%

No

Individual

08/2013

Yes

6168269



Position


Position Start Date

CHRISTIAN, CHARLIE KENT

PRESIDENT/CEO/MEMBER-BOARD OF MANAGERS

Less than 5%

Individual

07/2012

1465883








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


DAVID, ALEX MARCUS

MANAGING DIRECTOR OF BRANCH DEVELOPMENT GROUP ANDMARKETING

Less than 5%

No

Individual

07/2017

Yes

2421489



Position



Position Start Date


HUBBERT, MARK WILLIAM

CHIEF RISK AND CREDIT OFFICER

Less than 5%

No

Individual

09/2015

Yes

1802805









Firm Profile

Position



Position Start Date


HUNTRUDDY, HEATHER

MEMBER - BOARD OF MANAGERS

Less than 5%

No

Individual

11/2017

Yes

2091956



Position



Position Start Date


HURLEY, KEVIN BRADY

COMPLIANCE OFFICER (INVESTMENT ADVISOR ONLY)

Less than 5%

No

Individual

12/2008

Yes

1293748



Position


Position Start Date

KELLY, DOUGLAS LAIRD

CHIEF LEGAL OFFICER, SECRETARY

Less than 5%

Individual

03/2008

2428802









Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


MCGOUGH, ULRIC P

DESIGNATED TEXAS OFFICER; DIRECTOR OF SUPERVISION, RISK, ANDCONTROL

Less than 5%

No

Individual

04/2013

Yes

2573824



Position



Position Start Date


MEYER, BRAND FREDERICK

MEMBER- BOARD OF MANAGERS

Less than 5%

No

Individual

11/2013

Yes

808629



SANKOVICH, PAUL CAMERON

2475029








Firm Profile

Position



Position Start Date


CHIEF COMPLIANCE OFFICER (EXCEPT INVESTMENT ADVISOR)

Less than 5%

No

Individual

04/2009

Yes

2475029







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

Indirect Owners

Firm Profile

EVEREN CAPITAL CORPORATION

SHARE HOLDER

WACHOVIA SECURITIES FINANCIAL HOLDING, LLC

75% or more

No

Domestic Entity

08/2010

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




WELLS FARGO & COMPANY

SHARE HOLDER

WFC HOLDINGS, LLC

75% or more

Yes

Domestic Entity

09/1998

Yes









WFC HOLDINGS, LLC


Domestic Entity









Indirect Owners (continued)

Firm Profile

SHARE HOLDER


75% or more

No

12/2017

Yes












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, 1 SRO 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 01/28/1983

Self-Regulatory Organization Status Date Effective

FINRA Approved 11/03/1983






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/17/1986

Alaska Approved 07/23/1992

Arizona Approved 10/28/1988

Arkansas Approved 12/01/1986

California Approved 01/29/1986

Colorado Approved 01/13/1986

Connecticut Approved 08/05/1986

Delaware Approved 10/28/1986

District of Columbia Approved 02/20/1986

Florida Approved 01/30/1985

Georgia Approved 01/31/1986

Hawaii Approved 11/20/1991

Idaho Approved 11/22/1988

Illinois Approved 04/07/1986

Indiana Approved 04/28/1988

Iowa Approved 08/01/1989

Kansas Approved 05/09/1988

Kentucky Approved 04/18/1989

Louisiana Approved 10/13/1986

Maine Approved 01/28/1992

Maryland Approved 09/17/1987

Massachusetts Approved 04/04/1988

Michigan Approved 07/24/2003

Minnesota Approved 01/12/1988

Mississippi Approved 07/11/1990

Missouri Approved 01/05/1988

Montana Approved 02/11/1994

Nebraska Approved 07/18/1988

Nevada Approved 01/14/1986

New Hampshire Approved 08/09/1989

New Jersey Approved 03/15/1990

New Mexico Approved 12/06/1988

New York Approved 12/04/1984

U.S. States &Territories

Status Date Effective

North Carolina Approved 02/19/1986

North Dakota Approved 02/07/1989

Ohio Approved 03/21/1986

Oklahoma Approved 04/14/1988

Oregon Approved 12/18/1987

Pennsylvania Approved 06/13/1986

Puerto Rico Approved 08/09/1990

Rhode Island Approved 08/03/1989

South Carolina Approved 09/14/1987

South Dakota Approved 04/11/1989

Tennessee Approved 11/05/1986

Texas Approved 05/12/1986

Utah Approved 10/11/1988

Vermont Approved 10/09/1989

Virgin Islands Approved 06/14/2005

Virginia Approved 09/22/1987

Washington Approved 02/16/1988

West Virginia Approved 03/10/1988

Wisconsin Approved 04/25/1988

Wyoming Approved 05/03/1989






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 22 types of businesses.

Types of Business

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

Broker or dealer selling corporate debt securities

Underwriter or selling group participant (corporate securities other than mutual funds)

Mutual fund underwriter or sponsor

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

Real estate syndicator

Broker or dealer selling oil and gas interests

Put and call broker or dealer or option writer

Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals)

Investment advisory services

Broker or dealer selling tax shelters or limited partnerships in primary distributions

Broker or dealer selling tax shelters or limited partnerships in the secondary market

Non-exchange member arranging for transactions in listed securities by exchange member

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: WELLS FARGO CLEARING SERVICES, LLC

Business Address: 1 NORTH JEFFERSONST. LOUIS, MO 63103

CRD #: 19616

Effective Date: 11/11/2016

Description: THE FIRM WILL OPERATE PURSUANT TO A FULLY DISCLOSEDCLEARING AGREEMENT WITH WELLS FARGO CLEARING SERVICES, LLC

Name: ADM INVESTOR SERVICES, INC.

Business Address: CHICAGO BOARD OF TRADE BUILDING141 WEST JACKSON BOULEVARDCHICAGO, IL 60604


Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAILCUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BECARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.






Firm Operations

Industry Arrangements

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

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.



CRD #: 19616









CRD #: 19616





CRD #: 19616


Description: THE FIRM WILL OPERATE PURSUANT TO A FULLY DISCLOSEDCLEARING AGREEMENT WITH WELLS FARGO CLEARING SERVICES, LLC 15©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC





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

10/01/2016

555 WEST FIFTH STREET50TH FLOORLOS ANGELES, CA 90013

104963

ANALYTIC INVESTORS, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS CAPITAL MANAGEMENT, INC.,WHICH IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

Yes

No

12/14/2012

1133 CONNECTICUT AVENUE NWWASHINGTON, DC 20036

117246

THE ROCK CREEK GROUP, LLC is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

Yes

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:


Yes

No

No

12/14/2012

1133 CONNECTICUT AVEWASHINGTON, DC 20036

125409

THE ROCK CREEK GROUP, LP is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

CANADA

Yes

08/01/2012

1235 BAY STREETSUITE 400TORONTO, CANADA M5R 3K4

WELLS FARGO SECURITIES CANADA, LTD. is under common control with the firm.

WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVERENCAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC,WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVERENCAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC,WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

No

Yes

No

08/01/2012

101 CALIFORNIA STREETSUITE 3050SAN FRANCISCO, CA 94111

133068

WELLS FARGO PRIME SERVICES, LLC is under common control with the firm.

AFFILIATE IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLSFARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATEAND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

Yes

CHINA

Yes

09/18/2007

23F / AIA CENTRAL1 CONNAUGHTROAD, CENTRALHONG KONG, HONG KONG

WELLS FARGO SECURITIES ASIA LIMITED is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK,N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENTOF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


Yes

Yes

JAPAN

Yes

05/11/2007

MARUNOUCHI TRUST TOWER MAIN, 24TH FLOOR1-8-3, MARUNOUCHI, CHIYODA-KUTOKYO, JAPAN

WELLS FARGO SECURITIES (JAPAN) CO., LTD. is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

01/01/2009

525 MARKET STREET 12TH FLOORSAN FRANCISCO, CA 94105

133366

WELLS FARGO FUNDS DISTRIBUTOR, LLC is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

SIXTH & MARQUETTEMINNEAPOLIS, MN 55479

106487

GALLIARD CAPITAL MANAGEMENT INC is under common control with the firm.

Business Address:

CRD #:






Firm Operations


Yes

No

No

01/01/2009

SIXTH & MARQUETTEMINNEAPOLIS, MN 55479


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

No

01/01/2009


104973

WELLS CAPITAL MANAGEMENT INC is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

01/01/2009


110841

WELLS FARGO FUNDS MANAGEMENT, LLC is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

No

01/01/2009


Description:



Country:

Foreign Entity:

Effective Date:

Yes

No

ENGLAND

Yes

03/20/2010

34 GROSVENOR STREETLONDON, ENGLAND W1K 4QU

132377

ECM is under common control with the firm.

AFFILIATE IS OWNED 25% BY HADBO INVESTMENTS C.V. AND 75% BYISLAND FINANCE HOLDING COMPANY, BOTH OF WHICH ARE OWNEDDIRECTLY AND INDIRECTLY BY WELLS FARGO FINANCIAL, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE SUBSIDIARY AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

03/20/2010

10715 DAVID TAYLOR DRIVESUITE 150CHARLOTTE, NC 28262

110667

GOLDEN CAPITAL MANAGEMENT, LLC is under common control with the firm.

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

THE AFFILIATE IS 100% OWNED BY WELLS CAPITAL MANAGEMENT, INC.,WHICH IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Yes

No

No

03/20/2010

301 SOUTH COLLEGE STREET, TW-8CHARLOTTE, NC 28288

131539

STRUCTURED ASSET INVESTORS, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO & COMPANY. WELLSFARGO & COMPANY IS THE ULTIMATE PARENT OF THE AFFILIATE AND THEAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

03/20/2010

301 SOUTH COLLEGE STREET7TH FLOORCHARLOTTE, NC 28288

112660

STRUCTURED CREDIT PARTNERS LLC is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

STRUCTURED CREDIT PARTNERS, LLC IS 100% OWNED BY WELLS FARGO& COMPANY. WELLS FARGO & COMPANY IS THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

Description:


Yes

No

No

03/20/2010

401 SOUTH TRYON STREETCHARLOTTE, NC 28202

133204

WELLS FARGO INVESTMENT INSTITUTE, INC. is under common control with the firm.

THE AFFILIATE IS OWNED 100% BY WELLS FARGO BANK, N.A., WHICH ISOWNED 100% BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLSFARGO & COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THEAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

03/20/2010

20 BERKELEY STREETBOSTON, MA 02116-5034

487

GLOBAL ALTERNATIVE INVESTMENT SERVICES, INC. is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO BANK, N.A., WHICH IS100% OWNED BY WFC HOLDINGS, LLC WHICH IS 100% OWNED BY WELLSFARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATEAND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


No

Yes

No

03/20/2010

301 SOUTH COLLEGE STREETCHARLOTTE, NC 28288-0630

126292

WELLS FARGO SECURITIES, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY EVEREN CAPITAL CORPORATION,WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNEDBY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

ENGLAND

Yes

03/20/2010

CENTURION HOUSE24 MONUMENT STREET, 4TH FLOORLONDON, ENGLAND EC3R8A2

109192

FIRST INTERNATIONAL ADVISORS, LLC is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

LECONFIELD HOUSECURZON STREETLONDON, ENGLAND WIJ-5JA

WELLS FARGO SECURITIES INTERNATIONAL LIMITED is under common control with the firm.

Business Address:






Firm Operations


No

Yes

ENGLAND

Yes

03/20/2010

LECONFIELD HOUSECURZON STREETLONDON, ENGLAND WIJ-5JA


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

No

08/01/2010

ONE NORTH JEFFERSON AVENUEST. LOUIS, MO 63103

19616

WELLS FARGO CLEARING SERVICES, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WACHOVIA SECURITIES FINANCIALHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

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






Firm Operations


· savings bank or association· credit union· or foreign bank

Effective Date:

Business Address:

Description: THE AFFILIATE IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

WELLS FARGO BANK, N.A. is a National Bank and controls the firm.

01/01/2009

420 MONTGOMERY STREETSAN FRANCISCO, CA 94104

Effective Date:

Business Address:

Description: ULTIMATE PARENT OF APPLICANT

WELLS FARGO & COMPANY is a Bank Holding Company and controls the firm.

01/01/2009

420 MONTGOMERY STREETSAN FRANCISCO, CA 94163






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 24 0

Arbitration N/A 40 N/A






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

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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 24

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.

Current Status: Final






Initiated By: FINRA

Date Initiated: 10/16/2017

Docket/Case Number: 2014042465601

Principal Product Type: Other






https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2014042465601


Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A


Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS

Resolution Date: 10/16/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLYPAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS

Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.

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

No

Sanctions Ordered: CensureDisgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm








Initiated By: FINRA


Other




Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.








Other


N/A


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLYPAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS

Firm Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.



Disclosure 2 of 24

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM FORMAT IS INTENDED TOPREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALERRECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THATFOR APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THEOTHER TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATEDEXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEWSTORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS.FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEMFOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT.FINRA ALSO FOUND THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTYVENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOADINFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. IN ADDITION,FINRA DETERMINED THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATESUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTENPROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONICBROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS INWORM FORMAT.







Initiated By: FINRA


Other


N/A



Principal Product Type: No Product

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM FORMAT IS INTENDED TOPREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALERRECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THATFOR APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THEOTHER TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATEDEXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEWSTORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS.FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEMFOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT.FINRA ALSO FOUND THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTYVENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOADINFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. IN ADDITION,FINRA DETERMINED THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATESUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTENPROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONICBROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS INWORM FORMAT.


Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF THEREMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THECONDUCT ADDRESSED IN THE AWC.


No

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00







www.finra.org/brokercheck User GuidanceTHE FIRM WAS CENSURED, FINED $1,500,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF THEREMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THECONDUCT ADDRESSED IN THE AWC.


Initiated By: FINRA


Other


N/A





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM FORMAT IS INTENDED TOPREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALERRECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THATFOR APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THEOTHER TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATEDEXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEWSTORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS.FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEMFOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT.FINRA ALSO FOUND THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTYVENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOADINFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. IN ADDITION,FINRA DETERMINED THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATESUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTENPROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONICBROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS INWORM FORMAT.


Resolution: Acceptance, Waiver & Consent(AWC)35©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF THEREMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THECONDUCT ADDRESSED IN THE AWC.



Disclosure 3 of 24

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTERINFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETSAND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE,WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THATINFORMATION FROM THE TABLE TO POPULATE THE APPLICATIONREPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS'CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATEDID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OFTHE APPLICATION REPORTS, INCLUDING INFORMATION ABOUTCUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSOINCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURESWERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWINGTHEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULDHAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.







Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTERINFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETSAND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE,WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THATINFORMATION FROM THE TABLE TO POPULATE THE APPLICATIONREPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS'CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATEDID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OFTHE APPLICATION REPORTS, INCLUDING INFORMATION ABOUTCUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSOINCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURESWERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWINGTHEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULDHAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY ANDSEVERALLY.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TOMANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNALACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS ANDLIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATIONWOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THEAPPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TOTHE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OFONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITSAFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THECONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATIONABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGSALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS ANDPROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISMALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATIONREPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICHSHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TOMANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNALACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS ANDLIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATIONWOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THEAPPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TOTHE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OFONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITSAFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THECONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATIONABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGSALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS ANDPROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISMALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATIONREPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICHSHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.


Resolution:










Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY ANDSEVERALLY.


Disclosure 4 of 24

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Reporting Source: Firm

Initiated By: COMPTROLLER OF THE CURRENCY (OCC)


Cease and Desist


COMPLIANCE AND RISK MANAGEMENT PLAN; PAY REIMBURSEMENT TOAFFECTED CONSUMERS; CIVIL MONEY PENALTY.


Docket/Case Number: AA-EC-2016-66 AND AA-EC-2016-67

Principal Product Type: Banking Products (Other than CD(s))


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITSCOMMUNITY BANK GROUP HAD UNSAFE OR UNSOUND PRACTICES INRISK MANAGEMENT AND OVERSIGHT OF SALES PRACTICES, AND UNSAFEOR UNSOUND SALES PRACTICES BY SELLING UNWANTED DEPOSIT ORCREDIT CARD ACCOUNTS, THE UNAUTHORIZED OPENING OF SUCHACCOUNTS, THE TRANSFER OF FUNDS TO UNAUTHORIZED ACCOUNTS,AND UNAUTHORIZED CREDIT INQUIRIES TO OPEN THE ACCOUNTS.



Resolution:

Other Sanctions Ordered: ESTABLISH A COMPLIANCE PLAN; CREATE RISK MANAGEMENT AND AUDITOVERSIGHT, PROVIDE REIMBURSEMENT PLAN AND ASSESSMENT.

Sanction Details: FINE PAID OF $35,000,000.00

Sanctions Ordered: Monetary/Fine $35,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 5 of 24

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Disclosure 5 of 24


Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB)


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


CIVIL MONEY PENALTIES OF $100,000,000.00; COMPLIANCE AND REDRESSPLANS; INDEPENDENT CONSULTANT REVIEW, PAY REDRESS TO AFFECTEDCONSUMERS.


Docket/Case Number: 2016-CFPB-0015

Principal Product Type: Banking Products (Other than CD(s))


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITSCOMMUNITY BANK GROUP ENGAGED IN UNFAIR AND ABUSIVE PRACTICESBY OPENING DEPOSIT ACCOUNTS, TRANSFERRING FUNDS BETWEENACCOUNTS, APPLYING FOR CREDIT CARDS, ISSUING DEBIT CARDS ANDENROLLING CUSTOMERS IN ON-LINE BANKING SERVICES WITHOUT THECUSTOMERS' CONSENT.



Resolution:

Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING.

Sanction Details: $100,000,000.00 FINE PAID


Consent

Disclosure 6 of 24

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT UNDERCERTAIN SCENARIOS AND IN CERTAIN TIMEFRAMES ITS EDUCATIONFINANCIAL SERVICES BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS,AGGREGATED PARTIAL PAYMENTS, AND CHARGED LATE FEES IN WAYSTHAT WERE ALLEGED TO BE UNLAWFUL.







Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB)


Cease and Desist


COMPLIANCE PLAN, REMEDIATION TO BORROWERS, PAY CIVIL MONEYPENALTIES OF $3,600,000 AND PROVIDE A QUARTERLY/ANNUAL TRACKINGREPORT TO CFPB.


Docket/Case Number: 2016-CFPB-0013


Other Product Type(s): STUDENT LOAN SERVICING

WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT UNDERCERTAIN SCENARIOS AND IN CERTAIN TIMEFRAMES ITS EDUCATIONFINANCIAL SERVICES BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS,AGGREGATED PARTIAL PAYMENTS, AND CHARGED LATE FEES IN WAYSTHAT WERE ALLEGED TO BE UNLAWFUL.


Resolution:

Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING.

Sanction Details: $3,600,000.00 FINE PAID


Consent

Disclosure 7 of 24

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.







Initiated By: FINRA


Other


N/A



Principal Product Type: Mutual Fund(s)


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.


Resolution:


Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TOCUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUSINTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THATPURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES INAN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THEOPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS ASHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASSB OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BEPROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH ANEQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLEFUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NOEXPENSE TO THE CUSTOMER.


No



iReporting Source:








Initiated By: FINRA


Other


N/A





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.



Resolution:


Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TOCUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUSINTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THATPURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES INAN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THEOPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS ASHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASSB OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BEPROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH ANEQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLEFUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NOEXPENSE TO THE CUSTOMER.








www.finra.org/brokercheck User GuidanceTHE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TOCUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUSINTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THATPURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES INAN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THEOPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS ASHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASSB OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BEPROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH ANEQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLEFUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NOEXPENSE TO THE CUSTOMER.

Disclosure 8 of 24

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERALYEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THEANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICHIT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEWACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WASDEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TOIDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THERELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSINGSYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEWSECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERSPREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHENTHIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS ANDTREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONETHROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANTCUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROMTHE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEMDID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEWACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'SCIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITHRECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TOCONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATEDTHAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITYVERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHENTHE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVERSUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERESTILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERESUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRMEVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FORWHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED.







Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERALYEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THEANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICHIT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEWACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WASDEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TOIDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THERELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSINGSYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEWSECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERSPREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHENTHIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS ANDTREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONETHROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANTCUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROMTHE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEMDID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEWACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'SCIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITHRECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TOCONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATEDTHAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITYVERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHENTHE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVERSUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERESTILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERESUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRMEVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FORWHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY,$1,500,000.

FINE PAID IN FULL ON JANUARY 12, 2015.

Regulator Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGHTHE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST,INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATIONCIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THATREMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEMAND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, ANDREPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE4530(B).


No



i45©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Allegations: FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THEFINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRYOF FINDINGS THAT FORSEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECTOF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN ACUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIESTHE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND,DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THATIT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITYVERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANTPERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THEBETASYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIESACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLYASSIGNED TOACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIPSYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEWACCOUNTSAS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVENTHOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH ASCUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OFBIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITYVERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERSASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION.FORTHAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIESOF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED INTHE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATIONFOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THEFINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOTSUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WEREALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESEACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THEACCOUNTSTHAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAWWERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THEFIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTSFOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).







Initiated By: FINRA


Other


N/A





FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THEFINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRYOF FINDINGS THAT FORSEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECTOF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN ACUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIESTHE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND,DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THATIT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITYVERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANTPERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THEBETASYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIESACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLYASSIGNED TOACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIPSYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEWACCOUNTSAS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVENTHOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH ASCUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OFBIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITYVERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERSASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION.FORTHAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIESOF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED INTHE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATIONFOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THEFINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOTSUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WEREALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESEACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THEACCOUNTSTHAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAWWERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THEFIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTSFOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY,$1,500,000.

Firm Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGHTHEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).



Disclosure 9 of 24

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Initiated By: NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES


Other


STIPULATION


Docket/Case Number: 2012-0184-S

Principal Product Type: Insurance


Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGEDTHAT DURING THE APPROXIMATE PERIOD OF JANUARY 2007 THROUGHDECEMBER 2010 WELLS FARGO ADVISORS, LLC, AN UNLICENSED ENTITY,ACCEPTED INSURANCE COMMISSIONS FROM WELLS FARGO ADVISORSINSURANCE AGENCY LLC, IN VIOLATION OF NEW YORK INSURANCE LAW.THE DEPARTMENT FURTHER ALLEGED THAT BOTH WELLS FARGOADVISORS LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK LLCPROVIDED MATERIALLY INCOMPLETE INFORMATION IN THEIR RESPECTIVEINSURANCE LICENSE APPLICATIONS SUBMITTED TO THE STATE ON ORABOUT JANUARY 27, 2012.



Resolution:


Sanction Details: WELLS FARGO FINANCIAL ADVISORS JOINTLY WITH AN AFFILIATES PAID A$50,000 FINE AND AGREED TO TAKE ALL NECESSARY STEPS TO PREVENTTHE REOCCURRENCE OF SIMILAR VIOLATIONS.

Sanctions Ordered: Monetary/Fine $50,000.00

Stipulation and Consent

Disclosure 10 of 24

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Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, FINANCIAL NETWORK, LLC FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES,REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD ANDFINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONALEXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRMPROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS ANDTHE FIRM FAILED TO PROVIDE ADEQUATE FORMAL TRAINING ANDGUIDANCE TO ITS REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITSREGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONALETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. CERTAINFIRM REGISTERED REPRESENTATIVES MADE UNSUITABLERECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERSWITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOMEINVESTMENT OBJECTIVES AND/OR RISK TOLERANCES.







Initiated By: FINRA






Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS

FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, FINANCIAL NETWORK, LLC FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES,REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD ANDFINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONALEXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRMPROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS ANDTHE FIRM FAILED TO PROVIDE ADEQUATE FORMAL TRAINING ANDGUIDANCE TO ITS REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITSREGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONALETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. CERTAINFIRM REGISTERED REPRESENTATIVES MADE UNSUITABLERECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERSWITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOMEINVESTMENT OBJECTIVES AND/OR RISK TOLERANCES.


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 $2.1 MILLION AND ORDEREDTO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY.


No

Sanctions Ordered: CensureMonetary/Fine $2,100,000.00Disgorgement/Restitution







www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $2.1 MILLION AND ORDEREDTO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)




CENSURERESTITUTION




Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS

Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, FINANCIAL NETWORK, LLC FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES,REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD ANDFINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONALEXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRMPROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS ANDTHE FIRM FAILED TO PROVIDE ADEQUATE FORMAL TRAINING ANDGUIDANCE TO ITS REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITSREGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONALETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. CERTAINFIRM REGISTERED REPRESENTATIVES MADE UNSUITABLERECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERSWITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOMEINVESTMENT OBJECTIVES AND/OR RISK TOLERANCES.









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 WITH ITS AFFILIATE WELLSFARGO ADVISORS, LLC IS FINED $2.1 MILLION AND ORDERED TO PAY$641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. A REGISTERED FIRMPRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OFRESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY.

Sanctions Ordered: CensureMonetary/Fine $2,100,000.00Disgorgement/Restitution


Disclosure 11 of 24

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Allegations: SCHEDULE A, SECTION 1, OF THE NASD AND FINRA BY-LAWS, FINRA RULE2010 NASD RULE 2110: UNTIL THE END OF CALENDAR YEAR 2009, THEFIRM REPORTED REVENUE ON ITS FOCUS REPORTS NET OF ITS PAYOUTTO ITS FINANCIAL ADVISORS, RATHER THAN AS GROSS REVENUE, HAVINGDETERMINED - BASED PARTLY ON THE EMERGING ISSUES TASK FORCE(EITF) 99-19 - THAT ITS NET-BASIS REVENUE REPORTING COMPLIED WITHGENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP). THE FIRM HADFOLLOWED THIS ACCOUNTING PROTOCOL SINCE AT LEAST 2001, AND HADALLUDED TO IT IN ITS AUDITED FINANCIAL STATEMENTS. AT THEBEGINNING OF 2009, A COMPANY ACQUIRED THE FIRM AS PART OF THECOMPANY'S ACQUISITION OF ANOTHER COMPANY, AND THEREAFTERPROCEEDED TO EVALUATE THE FIRM'S BUSINESS PRACTICES INRELATION TO A SEPARATE EXISTING MEMBER FIRM THAT THE ACQUIRINGCOMPANY OWNED. AS A RESULT OF THAT PROCESS, THE FIRM CHANGEDITS PRACTICES TO REFLECT AND REPORT ITS REVENUE ON A GROSSBASIS. THE FIRM CONTACTED FINRA IN NOVEMBER 2009 TO ADVISE THATTHE FIRM'S UPCOMING AUDITED ANNUAL FINANCIAL STATEMENT ANDFOCUS REPORT WOULD REFLECT A SIGNIFICANT CHANGE IN REVENUESFOR CALENDAR YEAR 2009. THESE YEAR-END 2009 REPORTS REFLECTEDAPPROXIMATELY $200 MILLION IN ADDITIONAL REVENUES AND EXPENSESFOR THE YEAR. FOR EACH CALENDAR YEAR FROM 2001 THROUGH 2008,FINRA SENT THE FIRM AN INVOICE FOR THE FIRM'S GROSS INCOMEASSESSMENT, WHICH FINRA MEMBER FIRMS ARE REQUIRED TO PAYPURSUANT TO SCHEDULE A, SECTION 1 OF FINRA'S BY-LAWS. DURINGTHAT PERIOD, NASD AND FINRA CALCULATED THE FIRM'S GROSS INCOMEASSESSMENTS (GIA) ACCORDING TO THE REVENUE THAT THE FIRMREPORTED FOR THE PREVIOUS YEAR IN ITS FOCUS FILINGS. THE FIRMPAID THESE INVOICES IN FULL. AFTER LEARNING OF THE FIRM'S HISTORYOF REPORTING ITS REVENUE ON A NET BASIS, FINRA DETERMINED THATTHE FIRM HAD UNDERPAID ITS GROSS INCOME ASSESSMENTS BY ATOTAL OF $595,301.84 BETWEEN 2001 AND 2008. THE FIRM HAS SINCE PAIDTHAT AMOUNT IN FULL.







Initiated By: FINRA


Other


N/A





SCHEDULE A, SECTION 1, OF THE NASD AND FINRA BY-LAWS, FINRA RULE2010 NASD RULE 2110: UNTIL THE END OF CALENDAR YEAR 2009, THEFIRM REPORTED REVENUE ON ITS FOCUS REPORTS NET OF ITS PAYOUTTO ITS FINANCIAL ADVISORS, RATHER THAN AS GROSS REVENUE, HAVINGDETERMINED - BASED PARTLY ON THE EMERGING ISSUES TASK FORCE(EITF) 99-19 - THAT ITS NET-BASIS REVENUE REPORTING COMPLIED WITHGENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP). THE FIRM HADFOLLOWED THIS ACCOUNTING PROTOCOL SINCE AT LEAST 2001, AND HADALLUDED TO IT IN ITS AUDITED FINANCIAL STATEMENTS. AT THEBEGINNING OF 2009, A COMPANY ACQUIRED THE FIRM AS PART OF THECOMPANY'S ACQUISITION OF ANOTHER COMPANY, AND THEREAFTERPROCEEDED TO EVALUATE THE FIRM'S BUSINESS PRACTICES INRELATION TO A SEPARATE EXISTING MEMBER FIRM THAT THE ACQUIRINGCOMPANY OWNED. AS A RESULT OF THAT PROCESS, THE FIRM CHANGEDITS PRACTICES TO REFLECT AND REPORT ITS REVENUE ON A GROSSBASIS. THE FIRM CONTACTED FINRA IN NOVEMBER 2009 TO ADVISE THATTHE FIRM'S UPCOMING AUDITED ANNUAL FINANCIAL STATEMENT ANDFOCUS REPORT WOULD REFLECT A SIGNIFICANT CHANGE IN REVENUESFOR CALENDAR YEAR 2009. THESE YEAR-END 2009 REPORTS REFLECTEDAPPROXIMATELY $200 MILLION IN ADDITIONAL REVENUES AND EXPENSESFOR THE YEAR. FOR EACH CALENDAR YEAR FROM 2001 THROUGH 2008,FINRA SENT THE FIRM AN INVOICE FOR THE FIRM'S GROSS INCOMEASSESSMENT, WHICH FINRA MEMBER FIRMS ARE REQUIRED TO PAYPURSUANT TO SCHEDULE A, SECTION 1 OF FINRA'S BY-LAWS. DURINGTHAT PERIOD, NASD AND FINRA CALCULATED THE FIRM'S GROSS INCOMEASSESSMENTS (GIA) ACCORDING TO THE REVENUE THAT THE FIRMREPORTED FOR THE PREVIOUS YEAR IN ITS FOCUS FILINGS. THE FIRMPAID THESE INVOICES IN FULL. AFTER LEARNING OF THE FIRM'S HISTORYOF REPORTING ITS REVENUE ON A NET BASIS, FINRA DETERMINED THATTHE FIRM HAD UNDERPAID ITS GROSS INCOME ASSESSMENTS BY ATOTAL OF $595,301.84 BETWEEN 2001 AND 2008. THE FIRM HAS SINCE PAIDTHAT AMOUNT IN FULL.


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 $90,000. FINE PAID INFULL FEBRUARY 22, 2012.


No

Sanctions Ordered: CensureMonetary/Fine $90,000.00








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 $90,000. FINE PAID INFULL FEBRUARY 22, 2012.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)



Allegations: SCHEDULE A, SECTION 1, OF THE NASD AND FINRA BY-LAWS,FINRA RULE 2010 NASD RULE 2110: UNTIL THE END OF CALENDAR YEAR2009, THE FIRM REPORTED REVENUE ON ITS FOCUS REPORTS NET OF ITSPAYOUT TO ITS FINANCIAL ADVISORS, RATHER THAN AS GROSS REVENUE,HAVING DETERMINED - BASED PARTLY ON THE EMERGING ISSUES TASKFORCE (EITF) 99-19 - THAT ITS NET-BASIS REVENUE REPORTINGCOMPLIED WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES(GAAP). THE FIRM HAD FOLLOWED THIS ACCOUNTING PROTOCOL SINCEAT LEAST 2001, AND HAD ALLUDED TO IT IN ITS AUDITED FINANCIALSTATEMENTS. AT THE BEGINNING OF 2009, A COMPANY ACQUIRED THEFIRM AS PART OF THE COMPANY'S ACQUISITION OF ANOTHER COMPANY,AND THEREAFTER PROCEEDED TO EVALUATE THE FIRM'S BUSINESSPRACTICES IN RELATION TO A SEPARATE EXISTING MEMBER FIRM THATTHE ACQUIRING COMPANY OWNED. AS A RESULT OF THAT PROCESS, THEFIRM CHANGED ITS PRACTICES TO REFLECT AND REPORT ITS REVENUEON A GROSS BASIS. THE FIRM CONTACTED FINRA IN NOVEMBER 2009 TOADVISE THAT THE FIRM'S UPCOMING AUDITED ANNUAL FINANCIALSTATEMENT AND FOCUS REPORT WOULD REFLECT A SIGNIFICANTCHANGE IN REVENUES FOR CALENDAR YEAR 2009. THESE YEAR-END2009 REPORTS REFLECTED APPROXIMATELY $200 MILLION IN ADDITIONALREVENUES AND EXPENSES FOR THE YEAR. FOR EACH CALENDAR YEARFROM 2001 THROUGH 2008, FINRA SENT THE FIRM AN INVOICE FOR THEFIRM'S GROSS INCOME ASSESSMENT, WHICH FINRA MEMBER FIRMS AREREQUIRED TO PAY PURSUANT TO SCHEDULE A, SECTION 1 OF FINRA'S BY-LAWS. DURING THAT PERIOD, NASD AND FINRA CALCULATED THE FIRM'SGROSS INCOME ASSESSMENTS (GIA) ACCORDING TO THE REVENUE THATTHE FIRM REPORTED FOR THE PREVIOUS YEAR IN ITS FOCUS FILINGS.THE FIRM PAID THESE INVOICES IN FULL. AFTER LEARNING OF THE FIRM'SHISTORY OF REPORTING ITS REVENUE ON A NET BASIS, FINRADETERMINED THAT THE FIRM HAD UNDERPAID ITS GROSS INCOMEASSESSMENTS BY A TOTAL OF $595,301.84 BETWEEN 2001 AND 2008. THEFIRM HAS SINCE PAID THAT AMOUNT IN FULL.








Other


N/A




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 $90,000.

Firm Statement SCHEDULE A, SECTION 1, OF THE NASD AND FINRA BY-LAWS,FINRA RULE 2010 NASD RULE 2110: UNTIL THE END OF CALENDAR YEAR2009, THE FIRM REPORTED REVENUE ON ITS FOCUS REPORTS NET OF ITSPAYOUT TO ITS FINANCIAL ADVISORS, RATHER THAN AS GROSS REVENUE,HAVING DETERMINED - BASED PARTLY ON THE EMERGING ISSUES TASKFORCE (EITF) 99-19 - THAT ITS NET-BASIS REVENUE REPORTINGCOMPLIED WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES(GAAP). THE FIRM HAD FOLLOWED THIS ACCOUNTING PROTOCOL SINCEAT LEAST 2001, AND HAD ALLUDED TO IT IN ITS AUDITED FINANCIALSTATEMENTS. AT THE BEGINNING OF 2009, A COMPANY ACQUIRED THEFIRM AS PART OF THE COMPANY'S ACQUISITION OF ANOTHER COMPANY,AND THEREAFTER PROCEEDED TO EVALUATE THE FIRM'S BUSINESSPRACTICES IN RELATION TO A SEPARATE EXISTING MEMBER FIRM THATTHE ACQUIRING COMPANY OWNED. AS A RESULT OF THAT PROCESS, THEFIRM CHANGED ITS PRACTICES TO REFLECT AND REPORT ITS REVENUEON A GROSS BASIS. THE FIRM CONTACTED FINRA IN NOVEMBER 2009 TOADVISE THAT THE FIRM'S UPCOMING AUDITED ANNUAL FINANCIALSTATEMENT AND FOCUS REPORT WOULD REFLECT A SIGNIFICANTCHANGE IN REVENUES FOR CALENDAR YEAR 2009. THESE YEAR-END2009 REPORTS REFLECTED APPROXIMATELY $200 MILLION IN ADDITIONALREVENUES AND EXPENSES FOR THE YEAR. FOR EACH CALENDAR YEARFROM 2001 THROUGH 2008, FINRA SENT THE FIRM AN INVOICE FOR THEFIRM'S GROSS INCOME ASSESSMENT, WHICH FINRA MEMBER FIRMS AREREQUIRED TO PAY PURSUANT TO SCHEDULE A, SECTION 1 OF FINRA'S BY-LAWS. DURING THAT PERIOD, NASD AND FINRA CALCULATED THE FIRM'SGROSS INCOME ASSESSMENTS (GIA) ACCORDING TO THE REVENUE THATTHE FIRM REPORTED FOR THE PREVIOUS YEAR IN ITS FOCUS FILINGS.THE FIRM PAID THESE INVOICES IN FULL. AFTER LEARNING OF THE FIRM'SHISTORY OF REPORTING ITS REVENUE ON A NET BASIS, FINRADETERMINED THAT THE FIRM HAD UNDERPAID ITS GROSS INCOMEASSESSMENTS BY A TOTAL OF $595,301.84 BETWEEN 2001 AND 2008. THEFIRM HAS SINCE PAID THAT AMOUNT IN FULL.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 $90,000.








SCHEDULE A, SECTION 1, OF THE NASD AND FINRA BY-LAWS,FINRA RULE 2010 NASD RULE 2110: UNTIL THE END OF CALENDAR YEAR2009, THE FIRM REPORTED REVENUE ON ITS FOCUS REPORTS NET OF ITSPAYOUT TO ITS FINANCIAL ADVISORS, RATHER THAN AS GROSS REVENUE,HAVING DETERMINED - BASED PARTLY ON THE EMERGING ISSUES TASKFORCE (EITF) 99-19 - THAT ITS NET-BASIS REVENUE REPORTINGCOMPLIED WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES(GAAP). THE FIRM HAD FOLLOWED THIS ACCOUNTING PROTOCOL SINCEAT LEAST 2001, AND HAD ALLUDED TO IT IN ITS AUDITED FINANCIALSTATEMENTS. AT THE BEGINNING OF 2009, A COMPANY ACQUIRED THEFIRM AS PART OF THE COMPANY'S ACQUISITION OF ANOTHER COMPANY,AND THEREAFTER PROCEEDED TO EVALUATE THE FIRM'S BUSINESSPRACTICES IN RELATION TO A SEPARATE EXISTING MEMBER FIRM THATTHE ACQUIRING COMPANY OWNED. AS A RESULT OF THAT PROCESS, THEFIRM CHANGED ITS PRACTICES TO REFLECT AND REPORT ITS REVENUEON A GROSS BASIS. THE FIRM CONTACTED FINRA IN NOVEMBER 2009 TOADVISE THAT THE FIRM'S UPCOMING AUDITED ANNUAL FINANCIALSTATEMENT AND FOCUS REPORT WOULD REFLECT A SIGNIFICANTCHANGE IN REVENUES FOR CALENDAR YEAR 2009. THESE YEAR-END2009 REPORTS REFLECTED APPROXIMATELY $200 MILLION IN ADDITIONALREVENUES AND EXPENSES FOR THE YEAR. FOR EACH CALENDAR YEARFROM 2001 THROUGH 2008, FINRA SENT THE FIRM AN INVOICE FOR THEFIRM'S GROSS INCOME ASSESSMENT, WHICH FINRA MEMBER FIRMS AREREQUIRED TO PAY PURSUANT TO SCHEDULE A, SECTION 1 OF FINRA'S BY-LAWS. DURING THAT PERIOD, NASD AND FINRA CALCULATED THE FIRM'SGROSS INCOME ASSESSMENTS (GIA) ACCORDING TO THE REVENUE THATTHE FIRM REPORTED FOR THE PREVIOUS YEAR IN ITS FOCUS FILINGS.THE FIRM PAID THESE INVOICES IN FULL. AFTER LEARNING OF THE FIRM'SHISTORY OF REPORTING ITS REVENUE ON A NET BASIS, FINRADETERMINED THAT THE FIRM HAD UNDERPAID ITS GROSS INCOMEASSESSMENTS BY A TOTAL OF $595,301.84 BETWEEN 2001 AND 2008. THEFIRM HAS SINCE PAID THAT AMOUNT IN FULL.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 $90,000.

Disclosure 12 of 24

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Initiated By: FINRA







Allegations: FINRA RULE 2010, NASD RULES 2110, 3010, 3070 - WELLS FARGOADVISORS FINANCIAL NETWORK, LLC FAILED TO FILE SUMMARY ANDSTATISTICAL INFORMATION FOR CUSTOMER COMPLAINTS BY THE 15THDAY OF THE MONTH FOLLOWING THE CALENDAR QUARTER IN WHICHTHEY WERE RECEIVED BY THE FIRM. THE FIRM'S SUPERVISORY SYSTEMWAS NOT REASONABLY DESIGNED TO ENSURE THAT SUMMARY ANDSTATISTICAL INFORMATION OF CUSTOMER COMPLAINTS WAS FILED INACCORDANCE WITH NASD RULE 3070. THE FIRM'S SUPERVISORY SYSTEMFAILED TO PROVIDE FOR REASONABLE FOLLOW-UP AND REVIEW TOENSURE THAT REQUIRED CUSTOMER COMPLAINT FILINGS WERE MADE.



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 $15,000.


No



Initiated By: FINRA




CENSURE





Allegations: FINRA RULE 2010, NASD RULES 2110, 3010, 3070 - WELLS FARGOADVISORS FINANCIAL NETWORK, LLC FAILED TO FILE SUMMARY ANDSTATISTICAL INFORMATION FOR CUSTOMER COMPLAINTS BY THE 15THDAY OF THE MONTH FOLLOWING THE CALENDAR QUARTER IN WHICHTHEY WERE RECEIVED BY THE FIRM. THE FIRM'S SUPERVISORY SYSTEMWAS NOT REASONABLY DESIGNED TO ENSURE THAT SUMMARY ANDSTATISTICAL INFORMATION OF CUSTOMER COMPLAINTS WAS FILED INACCORDANCE WITH NASD RULE 3070. THE FIRM'S SUPERVISORY SYSTEMFAILED TO PROVIDE FOR REASONABLE FOLLOW-UP AND REVIEW TOENSURE THAT REQUIRED CUSTOMER COMPLAINT FILINGS WERE MADE.



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 $15,000.


Disclosure 13 of 24

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Initiated By: FINRA




Docket/Case Number: E9A2005013001



Allegations: NASD RULES 2110, 2310, 3010: WACHOVIA SECURITIES FINANCIAL DID NOTADEQUATELY CONSIDER, ON A CONSISTENT BASIS, PERTINENTELEMENTS, SUCH AS BREAKPOINTS, FEES AND EXPENSES, WHENMAKING RECOMMENDATIONS TO CUSTOMERS TO PURCHASE CLASS BSHARES IN MUTUAL FUNDS INSTEAD OF CLASS A SHARES. WACHOVIARECOMMENDED AND SOLD CLASS B SHARES TO CUSTOMERS WHO,DEPENDING UPON AMONG OTHER THINGS, THE AMOUNT OF THEINVESTMENT AND THE CUSTOMER'S CONTEMPLATED HOLDING PERIOD,WOULD HAVE BENEFITED HAD THEY PURCHASED CLASS A SHARESINSTEAD. AS A RESULT, WACHOVIA RECEIVED GREATER COMMISSIONSTOTALING $150,500 MORE THAT IT WOULD HAVE RECEIVED HAD IT SOLDCLASS A SHARES IN THE SAME MUTUAL FUNDS. WACHOVIA FAILED TOESTABLISH, MAINTAIN AND ENFORCE ADEQUATE SUPERVISORY ANDCOMPLIANCE POLICIES AND PROCEDURES THAT WERE REASONABLYDESIGNED TO IDENTIFY PURCHASES OF CLASS B SHARES BYCUSTOMERS FOR WHOM CLASS A SHARES WOULD HAVE BEEN MOREECONOMICALLY BENEFICIAL, NOR WERE THE FIRM'S PROCEDURESSUFFICIENT ENOUGH TO ENSURE THAT REGISTERED REPRESENTATIVESMADE ADEQUATE DISCLOSURES TO CUSTOMERS ABOUT THE VARIOUSCLASSES OF MUTUAL FUNDS.






https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=e9a2005013001




Resolution:

Other Sanctions Ordered: UNDERTAKINGS: WACHOVIA WILL ALSO UNDERTAKE TO PROVIDEREMEDIATION TO CUSTOMERS WHO PURCHASED CLASS B SHARES OFMUTUAL FUNDS WHEN THE PURCHASE OF CLASS A SHARES WOULD HAVEBEEN MORE BENEFICIAL, EXCLUDING CUSTOMERS WHO SETTLED,CANCELLED THEIR PURCHASES, WERE NOT SUBJECT TO HIGHERCHARGES OR FEES THAN CLASS A SHARES, WERE NOT ELIGIBLE FORBREAKPOINTS, OR WHERE THERE WAS NO DISCERNABLE MATERIALBENEFIT IN PURCHASING CLASS A SHARES OVER CLASS B SHARES.WITHIN 120 DAYS, WACHOVIA WILL ALSO PROVIDE CURRENT CLASS BSHARE OWNERS THE OPTION TO CONVERT TO CLASS A SHAREOWNERSHIP. WITHIN 60 DAYS OF ACCEPTANCE OF THE AWC, WACHOVIAWILL PROVIDE FINRA WITH A SAMPLE LETTERS TO CUSTOMERS WISHINGTO CONVERT CLASS B SHARES INTO CLASS A SHARES THE OFFER, ANEXPLANATION OF THE ADVANTAGES AND DISADVANTAGES, AND ADVICETO CONSULT A TAX ADVISOR. ALSO, WITHIN 60 SAYS, WACHOVIA WILLTRAIN STAFF TO FIELD CUSTOMER INQUIRES, RETAIN A THIRD-PARTYEXAMINER TO EXAMINE THE FIRM'S PERFORMANCE OF ITS OBLIGATIONSUNDER THE TERMS OF THE AWC, BEAR THE EXAMINER'S COSTS ANDCOOPERATE WITH THE EXAMINER. WACHOVIA SHALL COMPLETE THEREMEDIATION PROCESS WITHIN 270 DAYS OF THE AWC AND WITHIN 330DAYS OF THE EFFECTIVE DATE OF THE AWC FILED A DETAILED REPORTWITH FINRA REGARDING THE RESULTS OF THE REMEDIATION PLAN. THETHIRD PARTY EXAMINER SHALL FILE A FINAL REPORT NO LATER THAN 420DAYS AFTER THE EFFECTIVE DATE OF THE AWC.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIESFINANCIAL CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED$150,500, AND REQUIRED TO UNDERTAKE A REMEDIATION PLAN.


No



iReporting Source: 58©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC






Initiated By: FINRA





Docket/Case Number: E9A2005013001



Allegations: ALLEGATIONS THAT THE FIRM (1) MADE RECOMMENDATIONS THROUGHITS REGISTERED REPRESENTATIVES TO CUSTOMERS TO PURCHASECLASS B AND CLASS C MUTUAL FUND SHARES WHERE AN EQUALINVESTMENT IN CLASS A SHARES WOULD HAVE BEEN MOREADVANTAGEOUS FOR CERTAIN CLIENTS IN VIOLATION OF NASD RULE 2310AND (2) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SUPERVISORYSYSTEMS AND PROCEDURES REASONABLY DESIGNED TO PROVIDECONSIDERATION, ON A CONSISTENT BASIS, OF THE BENEFITS OFVARIOUS MUTUAL FUND CLASSES AS THEY APPLIED TO INDIVIDUALCUSTOMERS.



Resolution:

Other Sanctions Ordered: UNDERTAKINGS THAT INCLUDE REMEDIATION TO CERTAIN CUSTOMERSWHO PURCHASED CLASS B AND CLASS C MUTUAL FUNDS FROM JANUARY1, 2003 THROUGH THE NOTICE OF ACCEPTANCE OF THIS AWC.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AS OUTLINED ABOVE.



Disclosure 14 of 24

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Allegations: THE SUPERVISORY SYSTEM WAS INADEQUETE WITH RESPECT TO THESUPERVISION OF RECCOMENDATIONS BY ITS REPS THAT CLIENTSSWITCH FROM ONE MUTUAL FUND TO THE OTHER.






https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=e9a2005013001


Initiated By: FLORIDA


Cease and Desist



Docket/Case Number: 0221-S-7/05

URL for Regulatory Action:



Allegations: THE SUPERVISORY SYSTEM WAS INADEQUETE WITH RESPECT TO THESUPERVISION OF RECCOMENDATIONS BY ITS REPS THAT CLIENTSSWITCH FROM ONE MUTUAL FUND TO THE OTHER.


Resolution:


Sanction Details: NA

Regulator Statement FAILURE TO SUPERVISE.


No

Sanctions Ordered: Monetary/Fine $50,000.00Cease and Desist/Injunction



Allegations: THE OFFICE OF FINANCIAL REGULATION ALLEGED THAT THE FIRM'SSUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO THESUPERVISION OF RECOMMENDATIONS BY ITS ASSOCIATED PERSONSTHAT CLIENTS SWITCH FROM ONE MUTUAL FUND TO ANOTHER INFLORIDA. AS NOTED IN THE STIPULATION AND CONSENT, SINCE THEOFFICE'S EXAMINATION, THE FIRM REVISED IT SUPERVISORY SYSTEMAND IMPLEMENTED A NEW COMPUTERIZED SUPERVISORY ANDSURVEILLANCE SYSTEM.







Initiated By: STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION




CEASE AND DESIST AND RESTITUTION


Docket/Case Number: 0221-S7/05



THE OFFICE OF FINANCIAL REGULATION ALLEGED THAT THE FIRM'SSUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO THESUPERVISION OF RECOMMENDATIONS BY ITS ASSOCIATED PERSONSTHAT CLIENTS SWITCH FROM ONE MUTUAL FUND TO ANOTHER INFLORIDA. AS NOTED IN THE STIPULATION AND CONSENT, SINCE THEOFFICE'S EXAMINATION, THE FIRM REVISED IT SUPERVISORY SYSTEMAND IMPLEMENTED A NEW COMPUTERIZED SUPERVISORY ANDSURVEILLANCE SYSTEM.


Resolution:


Sanction Details: THE FIRM PAID A $50,000 FINE ON FEBRUARY 3, 2006. THE FIRM AGREEDTO UNDERTAKE A REVIEW AND RESTITUTION PROCESS IN CONNECTIONWITH FLORIDA MUTUAL FUND TRANSACTIONS EFFECTED BETWEENJANUARY 1, 2002 AND DECEMBER 31, 2004 FOR FLORIDA RESIDENTS WHOMAY HAVE BEEN ELIGIBLE FOR, BUT DID NOT RECEIVE AN NAV PRICINGSPECIAL. THE FIRM IS REQUIRED TO COMPLETE THE REVIEW ANDRESTITUTION PROCESS WITHIN 270 DAYS OF THE DATE OF THE FINALORDER.

Sanctions Ordered: Monetary/Fine $50,000.00Disgorgement/RestitutionCease and Desist/Injunction


Disclosure 15 of 24

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Allegations: NASD RULES 2110 AND 3010 - RESPONDENT MEMBER, CONTRARY TO FIRMPROCEDURES, FAILED TO SEND ACTIVITY ("HAPPINESS") LETTERS TOCLIENTS WHEN THE ACCOUNT INITIALLY APPEARED ON THE MONTHLYACTIVE ACCOUNT REPORT(MAR), NO CUSTOMER CONTACT WAS MADE TOADDRESS THE INCREASING ACTIVITY IN THE ACCOUNTS AND THE LOSSESASSOCIATED THEREIN, FAILED TO REVIEW ACCOUNTS DURING BRANCHAUDITS, INCURRING LOSSES TO CUSTOMERS IN EXCESS OF $350,000;FAILED TO HAVE AN ADEQUATE SYSTEM OF FOLLOW-UP AND REVIEW TOENSURE THAT PERSONS ASSIGNED TO REVIEW ACTIVE ACCOUNTACTIVITY ACTUALLY PERFORMED THE REVIEWS AND THAT "HAPPINESS"LETTERS WERE SENT, CUSTOMER CONTACT MADE, AND THAT ACTIVEACCOUNTS WERE REVIEWED DURING BRANCH AUDITS. THE FIRM FAILEDTO DEVOTE SUFFICIENT RESOURCES TO SUPERVISE ADEQUATELY THEGROWING NUMBER OF REGISTERED REPRESENTATIVES AND CUSTOMERACCOUNTS, AND TO DEVOTE SUFFICIENT RESOURCES TO ITSSUPERVISORY SYSTEM TO DETECT AND PREVENT UNSUITABLE TRADINGACTIVITY IN CUSTOMER ACCOUNTS.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C11010029



NASD RULES 2110 AND 3010 - RESPONDENT MEMBER, CONTRARY TO FIRMPROCEDURES, FAILED TO SEND ACTIVITY ("HAPPINESS") LETTERS TOCLIENTS WHEN THE ACCOUNT INITIALLY APPEARED ON THE MONTHLYACTIVE ACCOUNT REPORT(MAR), NO CUSTOMER CONTACT WAS MADE TOADDRESS THE INCREASING ACTIVITY IN THE ACCOUNTS AND THE LOSSESASSOCIATED THEREIN, FAILED TO REVIEW ACCOUNTS DURING BRANCHAUDITS, INCURRING LOSSES TO CUSTOMERS IN EXCESS OF $350,000;FAILED TO HAVE AN ADEQUATE SYSTEM OF FOLLOW-UP AND REVIEW TOENSURE THAT PERSONS ASSIGNED TO REVIEW ACTIVE ACCOUNTACTIVITY ACTUALLY PERFORMED THE REVIEWS AND THAT "HAPPINESS"LETTERS WERE SENT, CUSTOMER CONTACT MADE, AND THAT ACTIVEACCOUNTS WERE REVIEWED DURING BRANCH AUDITS. THE FIRM FAILEDTO DEVOTE SUFFICIENT RESOURCES TO SUPERVISE ADEQUATELY THEGROWING NUMBER OF REGISTERED REPRESENTATIVES AND CUSTOMERACCOUNTS, AND TO DEVOTE SUFFICIENT RESOURCES TO ITSSUPERVISORY SYSTEM TO DETECT AND PREVENT UNSUITABLE TRADINGACTIVITY IN CUSTOMER ACCOUNTS.


Resolution:


Sanction Details: CENSURED AND FINED $50,000

Regulator Statement .




Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATION.CORPORATE SECURITIES GROUP ACCEPTED AND CONSENTED TOTHE ENTRY OF THE FOLLOWING BY THE NASD.

DURING 1997 AND 1998, CORPORATE SECURITIES GROUP FAILED TOESTABLISH AN ADEQUATE SUPERVISORY SYSTEM OFFOLLOW-UP AND REVIEW TO ENSURE REVIEW OF ACTIVE ACCOUNTS ANDFAILED TO DEVOTE SUFFICIENT RESOURCES TO ITSSUPERVISORY SYSTEM TO DETECT AND PREVENT UNSUITABLE ACTIVITYIN CUSTOMER ACCOUNTS.







Initiated By: NASD REGULATION, INC. - DISTRICT 11


Censure


CENSURE AND FINE





WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATION.CORPORATE SECURITIES GROUP ACCEPTED AND CONSENTED TOTHE ENTRY OF THE FOLLOWING BY THE NASD.

DURING 1997 AND 1998, CORPORATE SECURITIES GROUP FAILED TOESTABLISH AN ADEQUATE SUPERVISORY SYSTEM OFFOLLOW-UP AND REVIEW TO ENSURE REVIEW OF ACTIVE ACCOUNTS ANDFAILED TO DEVOTE SUFFICIENT RESOURCES TO ITSSUPERVISORY SYSTEM TO DETECT AND PREVENT UNSUITABLE ACTIVITYIN CUSTOMER ACCOUNTS.


Resolution:


Sanction Details: $50,000 CENSURE AND FINE. CHECK ISSUED 10/2/2001

Firm Statement THE ACCEPTANCE, WAIVER AND CONSENT WAS MADE FINAL ON 9/17/2001.THE FIRM WAS CENSURED ANDFINED $50,000.



Disclosure 16 of 24

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Allegations: VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 21 & 27 OF RULES OF FAIRPRACTICE IN THAT STEVENS RECOMMENDED PURCHASE OF SECURITIESUNSUITABLE FOR CUSTOMERS; PREPARED OR CAUSED AND SUBMITTEDOR CAUSED TO BE SUBMITTED TO CSG A NEW ACCOUNT CARD FOR THETRUST ACCOUNT IN WHICH CERTAIN INFORMATION CONCERNING THECUSTOMER WAS STATED INACCURATELY CAUSING CSG'S BOOKS ANDRECORDS TO BE INACCURATE WITH RESPECT TO THIS ACCOUNT; CSGFAILED TO SUPERVISE RESPONDENT STEVENS IN A MANNERREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULESPERTAINING TO SUITABILITY WITH RESPECT TORECOMMENDATIONS AND TRANSACTIONS EFFECTED BY STEVENS; AND,FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHALL APPLICABLE RULES AND REGULATIONS, IN THAT CSG'S PROCEDURESDID NOT PROVIDE FOR SUPERVISORY REVIEW OF TRANSACTIONSEFFECTED BY MANAGERS WHO WERE REGISTERED PRINCIPALS, SUCHAS STEVENS.











Docket/Case Number: C3A960009



VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 21 & 27 OF RULES OF FAIRPRACTICE IN THAT STEVENS RECOMMENDED PURCHASE OF SECURITIESUNSUITABLE FOR CUSTOMERS; PREPARED OR CAUSED AND SUBMITTEDOR CAUSED TO BE SUBMITTED TO CSG A NEW ACCOUNT CARD FOR THETRUST ACCOUNT IN WHICH CERTAIN INFORMATION CONCERNING THECUSTOMER WAS STATED INACCURATELY CAUSING CSG'S BOOKS ANDRECORDS TO BE INACCURATE WITH RESPECT TO THIS ACCOUNT; CSGFAILED TO SUPERVISE RESPONDENT STEVENS IN A MANNERREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULESPERTAINING TO SUITABILITY WITH RESPECT TORECOMMENDATIONS AND TRANSACTIONS EFFECTED BY STEVENS; AND,FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHALL APPLICABLE RULES AND REGULATIONS, IN THAT CSG'S PROCEDURESDID NOT PROVIDE FOR SUPERVISORY REVIEW OF TRANSACTIONSEFFECTED BY MANAGERS WHO WERE REGISTERED PRINCIPALS, SUCHAS STEVENS.


Resolution:

Other Sanctions Ordered: ASSESSED COSTS

Sanction Details: CSG ASSESSED COSTS OF $1,260; FINED $5,000

Regulator Statement [TOP] COMPLAINT #C3A960009 FILED 3/8/96 BY DISTRICT 3 AGAINSTRESPONDENTS CORPORATE SECURITIES GROUP, INC. (CSG) AND ROBERTL. STEVENS ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 21 & 27OF RULES OF FAIR PRACTICE IN THAT STEVENS RECOMMENDEDPURCHASE OF SECURITIES UNSUITABLE FOR CUSTOMERS; PREPAREDOR CAUSED AND SUBMITTED OR CAUSED TO BE SUBMITTED TO CSG ANEW ACCOUNT CARD FOR THE TRUST ACCOUNT IN WHICH CERTAININFORMATION CONCERNING THE CUSTOMER WAS STATEDINACCURATELY CAUSING CSG'S BOOKS AND RECORDS TO BEINACCURATE WITH RESPECT TO THIS ACCOUNT; CSG FAILED TOSUPERVISE RESPONDENT STEVENS IN A MANNER REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULES PERTAINING TOSUITABILITY WITH RESPECT TORECOMMENDATIONS AND TRANSACTIONS EFFECTED BY STEVENS; AND,FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHALL APPLICABLE RULES AND REGULATIONS, IN THAT CSG'S PROCEDURESDID NOT PROVIDE FOR SUPERVISORY REVIEW OF TRANSACTIONSEFFECTED BY MANAGERS WHO WERE REGISTERED PRINCIPALS, SUCHAS STEVENS. DECISION 8/8/97 WHERE THIS SERVES AS A LETTER OFCAUTION TO CSG. IN ADDITION, CSG ASSESSED COSTS OF $1,260.STEVENS CENSURED, FINED $25,565, ORDERED TO PROVIDE PROOF OFRESTITUTION TO CUSTOMER OF $12,308 PLUS ACCRUED INTEREST, ANDSUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANYCAPACITY FOR 60 BUSINESS DAYS. 9/22/97 - CALLED FOR REVIEW. 6/10/97- NAC AFFIRMED DBCC'S FINDINGS CONCERNING STEVENS AND CSG BUTDISMISSED FINDING THAT CSG FAILED TO MAINTAIN WRITTENSUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS. NAC AFFIRMED DBCC'SIMPOSITION OF SANCTIONS AS TO STEVENS, BUT MODIFIED DBCC'SSANCTIONS AS TO CSG AND ORDERED IT BE CENSURED AND FINED$5,000. 7/10/98 - DECISION FINAL. $6,260.00 PAID ON 7/24/98, INVOICE #98-3A-655***


Decision






[TOP] COMPLAINT #C3A960009 FILED 3/8/96 BY DISTRICT 3 AGAINSTRESPONDENTS CORPORATE SECURITIES GROUP, INC. (CSG) AND ROBERTL. STEVENS ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 21 & 27OF RULES OF FAIR PRACTICE IN THAT STEVENS RECOMMENDEDPURCHASE OF SECURITIES UNSUITABLE FOR CUSTOMERS; PREPAREDOR CAUSED AND SUBMITTED OR CAUSED TO BE SUBMITTED TO CSG ANEW ACCOUNT CARD FOR THE TRUST ACCOUNT IN WHICH CERTAININFORMATION CONCERNING THE CUSTOMER WAS STATEDINACCURATELY CAUSING CSG'S BOOKS AND RECORDS TO BEINACCURATE WITH RESPECT TO THIS ACCOUNT; CSG FAILED TOSUPERVISE RESPONDENT STEVENS IN A MANNER REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULES PERTAINING TOSUITABILITY WITH RESPECT TORECOMMENDATIONS AND TRANSACTIONS EFFECTED BY STEVENS; AND,FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHALL APPLICABLE RULES AND REGULATIONS, IN THAT CSG'S PROCEDURESDID NOT PROVIDE FOR SUPERVISORY REVIEW OF TRANSACTIONSEFFECTED BY MANAGERS WHO WERE REGISTERED PRINCIPALS, SUCHAS STEVENS. DECISION 8/8/97 WHERE THIS SERVES AS A LETTER OFCAUTION TO CSG. IN ADDITION, CSG ASSESSED COSTS OF $1,260.STEVENS CENSURED, FINED $25,565, ORDERED TO PROVIDE PROOF OFRESTITUTION TO CUSTOMER OF $12,308 PLUS ACCRUED INTEREST, ANDSUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANYCAPACITY FOR 60 BUSINESS DAYS. 9/22/97 - CALLED FOR REVIEW. 6/10/97- NAC AFFIRMED DBCC'S FINDINGS CONCERNING STEVENS AND CSG BUTDISMISSED FINDING THAT CSG FAILED TO MAINTAIN WRITTENSUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS. NAC AFFIRMED DBCC'SIMPOSITION OF SANCTIONS AS TO STEVENS, BUT MODIFIED DBCC'SSANCTIONS AS TO CSG AND ORDERED IT BE CENSURED AND FINED$5,000. 7/10/98 - DECISION FINAL. $6,260.00 PAID ON 7/24/98, INVOICE #98-3A-655***


Initiated By: NASD - DISTRICT 3 (DENVER, CO)


Censure






Allegations: FAILURE TO SUPERVISE, INADEQUATE WRITTEN SUPERVISORYPROCEDURES



Resolution:


Sanction Details: THE NASD DISTRICT 3 ISSUED A LETTER OF CAUTION, NO FINE ORSUSPENSION WERE LEVIED. ON APPEAL, THE NATIONAL ADJUDICATORYCOUNCIL ISSUED A CENSURE AND A FINE OF $5,000.


Settled






Sanction Details: THE NASD DISTRICT 3 ISSUED A LETTER OF CAUTION, NO FINE ORSUSPENSION WERE LEVIED. ON APPEAL, THE NATIONAL ADJUDICATORYCOUNCIL ISSUED A CENSURE AND A FINE OF $5,000.

Firm Statement ON AUGUST 8, 1997 DISTRICT 3 ENTERED A DECISION IN WHICH IT ISSUEDA LETTER OF CAUTION TO JWGENESIS FINANCIAL SERVICES, INC. THEDISTRICT DETERMINED THAT JWGENESIS FINANCIAL SERVICES, INC.REASONABLY SUPERVISED ITS BRANCH MANAGERS BUT FOUND THATTHE FIRM DID NOT HAVE THE REQUISITE WRITTEN SUPERVISORYPROCEDURES IN PLACE. ON APPEAL, THE NATIONAL ADJUDICATORYCOUNCIL REVERSE DISTRICT 3 DECISION AND FOUND THAT JWGENESISFINANCIAL SERVICES, INC. DID NOT RESONABLE SUPERVISE BUT DIDHAVE PROPER WRITTEN SUPERVISORY PROCEDURES

Disclosure 17 of 24

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Initiated By: ILLINOIS SECURITIES DEPARTMENT


Suspension


AND/OR REVOCATION





Other Product Type(s): A NON-DISCRETIONARY CASH ACCOUNT

Allegations: JUSTYN S. FELDMAN BY AND THROUGH JWGENESIS FINANCIAL SERVICES,INC., FORMERLY KNOWN AS CORPORATE SECURITIES GROUP, INC.INDUCED ILLINOIS RESIDENTS TO ESTABLISH A NON-DISCRETIONARY,CASH ACCOUNT AT CORPORATE SECURITIES GROUP, INC. MR. FELDMAN'SHANDELING OF THE ACCOUNT REFLECTS CHURNING. RESPONDENTFORMERLY KNOWN AS CORPORATE SECURITIES GROUP, INC. FAILED TOREASONABLY SUPERVISE THE SECURITIES ACTIVITIES OF JUSTYN S.FELDMAN.



Resolution:



Decision & Order of Offer of Settlement







Sanction Details: RESPONDENT SHALL WILL UITILIZE THE NEW ACCOUNT CARD WHENSENDING OUT ITS INITIAL LETTER TO NEW CUSTOMERS, AND INCUDE ACOPY, ASKING THEM IF THE INFORMATION SHOULD BE ADJUSTED TOBETTER REFLECT THEIR INVESTMENT OBJECTIVES OR FINANCIALSITUATION. CONFIRM THAT THE INVESTOR UNDERSTANDS CLEARLYTHEIR INVESTMENT OBJECTIVES. INCLUDE A STATEMENT OF THEREASON WHY A CUSTOMER'S ACCOUNT WAS REVIEWED IN THE LETTERSENT TO THE CUSTOMER AS A RESULT OF THE REVIEW.THE NOTICE OF HEARING IN THIS MATTER IS DISMISSED.

Regulator Statement A NOTICE OF HEARING, ISSUED JULY 29, 1999. THE HEARING WILL BEHELD OCTOBER 13, 1999.

A SETTLEMENT AGREEMENT, DATED MARCH 11, 2000.

CONTACT: 217 785-4948


Initiated By: STATE OF ILLINOIS


Other






Allegations: THE STATE OF ILLINOIS INITIATED AN ADMINISTRATIVE PROCEDINGAGAINST JWGENESIS FINANCIAL SERVICES, INC. ALLEGING FAILURE TOSUPERVISE REGISTERED REPRESENTATIVE, JUSTYN FELDMAN



Resolution:


Sanction Details: THE MATTER WAS RESOLVED FOR $3,000 REPRESENTING THE COST OFTHE INVESTIGATION. NO ORDER WAS ENTERED OR CONSENTED TO BYTHE COMPANY.


Settled






Sanction Details: THE MATTER WAS RESOLVED FOR $3,000 REPRESENTING THE COST OFTHE INVESTIGATION. NO ORDER WAS ENTERED OR CONSENTED TO BYTHE COMPANY.

Disclosure 18 of 24

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Initiated By: ST OF MICHIGAN DEPT OF COMMERCE, CORP & SECURITIES BUREAU


Revocation



Docket/Case Number:



Allegations: THE STATE ISSUED A FINAL ORDER TO REVOKE BROKER/DEALERREGISTRATION FOR FAILURE TO TIMELY FILE ANNUAL REPORT



Resolution:


Sanction Details: AS AN ORDER TO SHOW CAUSE HAD NOT BEEN PROPERLY FILED AND THEFIRM WAS IN COMPLIANCE WITH FILING REQUIREMENTS UNDERMICHIGAN LAW. AN ORDER OF DISMISSAL VACATING THE REVOCATIONORDER AND THE DISMISSING THE MATTER WITHOUT PREJUDICE WASISSUED BY THE BROKER/DEALER

Sanctions Ordered:

Settled

Disclosure 19 of 24

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Initiated By: FLORIDA DIVISION OF SECURITIES

Allegations: NOT PROVIDED















Resolution:


Sanction Details: RESPONDENT CORPORATE SECURITIES GROUP AGREES TONOT VIOLATE FLORIDA SECURITIES LAWS AND AGREES TO MAINTAIN AMAXIMUM OF TWELVE (12) BRANCH OFFICES IN FLORIDA UNTIL APRIL 1,1991 AND THAT ALL FRANCHISE BRANCH OFFICES IN FLORIDA WILLOPERATE FROM REGISTERED BUSINESS LOCATIONS.

Regulator Statement NOT PROVIDED


Consent


Initiated By: FLORIDA DIVISION OF SECURITIES


Other






Allegations: ALLEGED BREACH OF TERMS OF REGISTRATION AGREEMENT WHICH ITAND ONE OF ITS REGISTERED REPRESENTATIVE ENTERED INTO WITHTHE DIVISION









Resolution:


Sanction Details: WITHOUT ADMITTING GUILT, JWGENESIS FINANCIAL SERVICES, INCAGREED TO CERTAIN FUTURE BRANCH OFFICES AND BRANCH MANAGERRESTRICTIONS AND WAS FINED $5,000 BY THE STATE. ALL CONDITIONS OFTHE SETTLEMENT HAVE BEEN MET.


Settled

Disclosure 20 of 24

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Allegations: NASD RULE 2110 - RESPONDENT MEMBER EXECUTED A SETTLEMENTAGREEMENT WITH A PUBLIC CUSTOMER CONTAINING A CONFIDENTIALITYCLAUSE WHICH PRECLUDED THE CUSTOMER FROMCOOPERATING WITH ANY SECURITIES REGULATORS ABSENT A SUBPOENAOR COURT ORDER, AND OPERATED TO PREVENT NASD FROM BRINGING ADISCIPLINARY ACTION AGAINST ONE OF THE FIRM'S FORMERREGISTERED REPRESENTATIVES FOR ALLEGEDLY MISUSING CUSTOMERFUNDS BECAUSE THE CUSTOMER IN QUESTION COULD NOT COOPERATEWITH NASD.AFTER BEING INFORMED BY NASD STAFF THAT THECONFIDENTIALITY CLAUSE VIOLATED CONDUCT RULE 2110, THE FIRMRESCINDED THE CLAUSE.



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THEREFORE, THE FIRM IS CENSURED, FINED$2,500, AND ORDERED TO UNDERTAKE THE FOLLOWING:WITHIN 90 DAYSFROM THE EFFECTIVE DATE OF THIS AWC, THE FIRM SHALL REVIEW ALLOF ITS SETTLEMENT AGREEMENTS WITH CUSTOMERSSINCE THE ISSUANCE OF NOTICE TO MEMBERS 95-87 ("NTM") TO ENSURETHAT THEY DO NOT CONTAIN ANY CONFIDENTIALITY CLAUSES WHICH AREPRECLUDED BY THAT NTM AND CONDUCT RULE 2110. IF THE FIRMIDENTIFIES ANY SETTLEMENT AGREEMENTS WHICH CONTAIN SUCHCLAUSES, IT SHALL RESCIND THEM PROMPTLY (I.E., WITHIN FIVEBUSINESS DAYS) -



Initiated By: NASD REGULATION, INC.


Censure


CENSURE AND FINE





Allegations: RESPONDENT MEMBER EXECUTED SETTLEMENT AND RELEASEAGREEMENTS WITH A PUBLIC CUSTOMER CONTAINING ACONFIDENTIALITYCLAUSE WHICH PRECLUDED THE CUSTOMER FROMCOOPERATING WITH ANY SECURITIES REGULATOR ABSENTA SUBPEONA OR COURT ORDER AND OPERATED TO PREVENT THE NASDRFROM BRINGING A DISCIPLINARY ACTION AGAINSTONE OF THE FIRM'S FORMER REGISTERED REPRESENTATIVES BECAUSETHE CUSTOMER COULD NOT COOPERATE WITH THENASDR.


Resolution: Acceptance, Waiver & Consent(AWC) 71©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC






Resolution:


Sanction Details: CENSURE AND FINE $2,500.00. FIRM WAS REQUIRED TO ENSURE THAT ALLSETTLEMENT AGREEMENTSWITH CUSTOMERS NOT CONTAIN CONFIDENTIALITY CLAUSES.

Firm Statement THE AWC WAS ACCEPTED ON 2/22/1999. THE FIRM WAS CENSURED ANDFINED $2,500.00



Disclosure 21 of 24

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Docket/Case Number: MS-483-AWC(A)

Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-483-AWC(A):

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WSA FILED ONMARCH 19, 1987, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c)OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENTFAILED TO REPORT ITS NASDAQ VOLUME IN NINE SECURITIES ON5/28/86, AND IN ELEVEN SECURITIES ON 10/31/86. THE AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON MARCH 6,1987AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 7,1987. FINE $250 RECEIVED 2/17/87

Sanctions Ordered: Monetary/Fine $250.00






www.finra.org/brokercheck User GuidanceMARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-483-AWC(A):

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WSA FILED ONMARCH 19, 1987, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c)OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENTFAILED TO REPORT ITS NASDAQ VOLUME IN NINE SECURITIES ON5/28/86, AND IN ELEVEN SECURITIES ON 10/31/86. THE AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON MARCH 6,1987AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 7,1987. FINE $250 RECEIVED 2/17/87


Initiated By: NASD


Other



Docket/Case Number: MS-483-AWC (A)



Allegations: FAILURE TO REPORT ITS NASDAQ VOLUME IN 9 SECURITIES ON MAY 28,1986 AND 11 SECURITIES ON OCTOBER 31, 1986



Resolution:


Sanction Details: THE FIRM WAS FINED $250 PURSUANT TO THE ACCEPTANCE, WAIVER ANDCONSENT PROCEDURES

Sanctions Ordered: Monetary/Fine $250.00


Disclosure 22 of 24

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Allegations: RESPONDENT'S FORMER AGENT, JOSE A. DANCEL,JR., FAILED TO OBTAIN SUITABILITY INFORMATION AND ENGAGEDD INUNAUTHORIZED, UNSUITABLE AND EXCESSIVE TRDES (INCLUDINGMARGINAND OPTIONS PURCHASES) FOR AT LEAST TWO MARYLAND CUSTOMERS.RESPONDENT FAILED TO REASONABLY SUPERVISE DANCEL WITHIN THEMEANING OF SECTION 11-412(A)(10) OF THE MARYLAND SECURITIESACT.







Initiated By: THE MARYLAND DIVISION OF SECURITIES




Docket/Case Number: S-93-047




RESPONDENT'S FORMER AGENT, JOSE A. DANCEL,JR., FAILED TO OBTAIN SUITABILITY INFORMATION AND ENGAGEDD INUNAUTHORIZED, UNSUITABLE AND EXCESSIVE TRDES (INCLUDINGMARGINAND OPTIONS PURCHASES) FOR AT LEAST TWO MARYLAND CUSTOMERS.RESPONDENT FAILED TO REASONABLY SUPERVISE DANCEL WITHIN THEMEANING OF SECTION 11-412(A)(10) OF THE MARYLAND SECURITIESACT.


Resolution:


Sanction Details: ON DECEMBER 22, 1994, RESPONDENT WAS THE SUBJECTOF A CONSENT ORDER ISSUED BY THE MARYLAND SECURITIESCOMMISSIONER, WHEREBY RESPONDENT AGREED TO PAY A $5,000 FINEAND TO CONTINUE SUPERVISION OF MARYLAND-RELATED ACCOUNTACTIVITIES BY WAY OF CERTAIN COMPLIANCE MEASURES.

Regulator Statement FOR FURTHER INFORMATION, PLEASE CONTACTASSISTANT ATTORNEY GENERAL JULIE L. TEWEY AT (410) 576-7037.


Consent


Initiated By: MARYLAND DIVISION OF SECURITIES


Allegations: FAILURE TO REASONABLE SUPERVISE FORMER AGENT, JOSE DANCEL,FAILURE TO OBTAIN SUITABILITY INFORMATION AND ENGAGED INUNAUTHORIZED, UNSUITABLE AND EXCESSIVE TRADES FOR TWOCUSTOMERS.








Other



Docket/Case Number: S-93-047




Resolution:


Sanction Details: JWGENESIS FINANCIAL SERVICES, INC. AGREED TO PAY A FINE OF $5,000AND CONTINUE SUPERVISION OF MARYLAND RELATED ACCOUNTACTIVITIES BY WAY OF CERTAIN COMPLIANCE MEASURES. ALLCONDITIONS OF THE AGREEMENT HAVE BEEN MET.


Settled

Disclosure 23 of 24

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Allegations:



Resolution: Decision








Sanction Details:

Regulator Statement COMPLAINT NO. C3A940061 FILED DECEMBER 14, 1994 BY DISTRICT NO.3 AGAINST RESPONDENTS CORPORATE SECURITIES GROUP, INC., BETHELLEN WEICKUM, AND ROBERT L. STEVENS ALLEGING VIOLATIONS OFARTICLE III, SECTIONS 1, 2 AND 27 OF THE RULES OF FAIR PRACTICEIN THAT RESPONDENT WEICKUM MADE UNSUITABLE RECOMMENDATIONSTOPUBLIC CUSTOMERS TO PURCHASE STOCK; FAILED TO TIMELY AMENDEDHIS FORM U-4 TO KEEP INFORMATION CURRENT; AND, RESPONDENTSMEMBER, ACTING THROUGH RESPONDENT STEVENS, FAILED TOSUPERVISEWEICKUM'S ACTIVITIES ADEQUATELY REGARDING MAKING UNSUITABLERECOMMENDATIONS TO CUSTOMERS; AND, RESPONDENT MEMBERFAILED TOTIMELY FILE AN ACCURATE FORM U-5 ON BEHALF OF RESPONDENTWEICKUM.

DECISION RENDERED AUGUST 9, 1995 WHEREIN RESPONDENT MEMBERISCENSURED AND FINED $1,000 AND RESPONDENT STEVENS IS CENSURED,FINED $10,000, AND REQUIRED TO REQUALIFY BY EXAMINATION IN ANYCAPACITY IN WHICH HE WISHES TO BECOME ASSOCIATED WITH AMEMBERIN THE FUTURE. IN ADDITION, RESPONDENTS MEMBER AND STEVENSEACHARE ASSESSED ONE-HALF OF THE COSTS TOTALING $1,571.50. THETHIRD CAUSE OF COMPLAINT WAS DISMISSED AS TO RESPONDENTMEMBERREGARDING FAILURE TO SUPERVISE IN THAT THE COMMITTEEDETERMINEDTHAT THE FIRM INSTITUTED AND IMPLEMENTED A SUPERVISORY SYSTEMAND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITHTHE SUITABILITY RULES. IF NO FURTHER ACTION, DECISION IS FINALSEPTEMBER 25, 1995.

ON AUGUST 17, 1995, THE DECISION AND ORDER OF ACCEPTANCE, OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENT WEICKUM WASISSUED;THEREFORE, SHE IS CENSURED AND FINED $5,000.

SEPTEMBER 25, 1995 - DECISION IS FINAL.

**$1,785.75 PAID ON 10/17/95, INVOICE # 95-3A-593**







COMPLAINT NO. C3A940061 FILED DECEMBER 14, 1994 BY DISTRICT NO.3 AGAINST RESPONDENTS CORPORATE SECURITIES GROUP, INC., BETHELLEN WEICKUM, AND ROBERT L. STEVENS ALLEGING VIOLATIONS OFARTICLE III, SECTIONS 1, 2 AND 27 OF THE RULES OF FAIR PRACTICEIN THAT RESPONDENT WEICKUM MADE UNSUITABLE RECOMMENDATIONSTOPUBLIC CUSTOMERS TO PURCHASE STOCK; FAILED TO TIMELY AMENDEDHIS FORM U-4 TO KEEP INFORMATION CURRENT; AND, RESPONDENTSMEMBER, ACTING THROUGH RESPONDENT STEVENS, FAILED TOSUPERVISEWEICKUM'S ACTIVITIES ADEQUATELY REGARDING MAKING UNSUITABLERECOMMENDATIONS TO CUSTOMERS; AND, RESPONDENT MEMBERFAILED TOTIMELY FILE AN ACCURATE FORM U-5 ON BEHALF OF RESPONDENTWEICKUM.

DECISION RENDERED AUGUST 9, 1995 WHEREIN RESPONDENT MEMBERISCENSURED AND FINED $1,000 AND RESPONDENT STEVENS IS CENSURED,FINED $10,000, AND REQUIRED TO REQUALIFY BY EXAMINATION IN ANYCAPACITY IN WHICH HE WISHES TO BECOME ASSOCIATED WITH AMEMBERIN THE FUTURE. IN ADDITION, RESPONDENTS MEMBER AND STEVENSEACHARE ASSESSED ONE-HALF OF THE COSTS TOTALING $1,571.50. THETHIRD CAUSE OF COMPLAINT WAS DISMISSED AS TO RESPONDENTMEMBERREGARDING FAILURE TO SUPERVISE IN THAT THE COMMITTEEDETERMINEDTHAT THE FIRM INSTITUTED AND IMPLEMENTED A SUPERVISORY SYSTEMAND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITHTHE SUITABILITY RULES. IF NO FURTHER ACTION, DECISION IS FINALSEPTEMBER 25, 1995.

ON AUGUST 17, 1995, THE DECISION AND ORDER OF ACCEPTANCE, OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENT WEICKUM WASISSUED;THEREFORE, SHE IS CENSURED AND FINED $5,000.

SEPTEMBER 25, 1995 - DECISION IS FINAL.

**$1,785.75 PAID ON 10/17/95, INVOICE # 95-3A-593**


Initiated By: NASD DISTICT 3 (DENVER, CO)


Other






Allegations: FAILURE TO SUPERVISE, FAILURE TO TIMELY FILE FORM U-5



Resolution:


Sanction Details: THE DISTRICT BUSINESS CONDUCT COMMITTEE FOUND THAT JWGENESISFINANCIAL SERVICES, INC. VIOLATED ARTICLE III SECTION 1 OF THE NASDRULES OF FAIR PRACTICE IN THAT IT DID NOT TIMELY FILE A FORM U-5DISCLOSURE FORM. THE FIRM WAS FINED $1,000.

Firm Statement THE CLAIMS AGAINST THE FIRM FOR FAILURE TO SUPERVISE WEREDISMISSED IN THEIR ENTIRETY


Other

Disclosure 24 of 24

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Allegations: VIOLATION OF SECTION 15(A) OF THE EXCHANGE ACT. THE ORDERFURTHER ALLEGES THAT RIZOS AIDED AND ABETTED AND CAUSEDMAUSSER'S VIOLATIONS OF SECTION 15(A)







Initiated By: SECURITIES AND EXCHANGE COMMISSION




Docket/Case Number:



Allegations: VIOLATION OF SECTION 15(A) OF THE EXCHANGE ACT. THE ORDERFURTHER ALLEGES THAT RIZOS AIDED AND ABETTED AND CAUSEDMAUSSER'S VIOLATIONS OF SECTION 15(A)


Resolution:


Sanction Details: IT IS ORDERED THAT CSG BE AND HEREBY CENSURED.

Regulator Statement [TOP] [10/12/94] SEC NEWS DIGEST, ISSUE 94-190 DATED 10/5/1994 SECANNOUNCED THAT IT INSTITUTED PUBLIC ADMINISTRATIVEPROCEEDINGS AGAINST CORPORATE SECURITIES GROUP, INC., (CSG) AREGISTERED BROKER-DEALER; MATTHEW ZAHN, A REGISTEREDREPRESENTATIVE; DR. GEORGE M. RIZIO, AN UNREGISTERED INDIVIDUAL;AND CANDIA L. MAUSSER, A REGISTERED REPRESENTATVE; THE ORDERINSTITUTING PROCEEDINGS ALLEGES THAT MAUSSER MADE MATERIALMISSTATEMENTS AND OMISSIONS OF FACT IN CONNECTION WITH ANOFFERING OF GOLDSTAR CORPORATION SECURITIES, IN VIOLATION OFTHE ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. THEORDER ALSO ALLEGES THAT MAUSSER EFFECTED SALES OF GOLDSTARSECURITIES WITHOUT THE APPROVAL OF CORPORATE SECURITIES, INVIOLATION OF SECTION 15(A) OF THE EXCHANGE ACT. THE ORDERFURTHER ALLEGES THAT RIZOS AIDED AND ABETTED AND CAUSEDMAUSSER'S VIOLATIONS OF SECTION 15(A) BY ARRANGING FOR THEMAUSSER TO PARTICIPATE IN AN OFFERING OF GOLDSTAR SECURITIES AND ASSISTING MAUSSER IN SELLING THE SECURITIES, AND THAT ZAHN AND CORORATE SECURITIESFAILED REASONABLY TO SUPERVISE MAUSSER WITH A VIEW TOPREVENTING MAUSSER'S VIOLATIONS OF SECTION 15(A) OF THEEXCHANGE ACT. 04/14/97 SEC DOCKET, VOLUME 59, NO. 7, DATED6/13/1995, PAGE 1007, DISCLOSES; SEC ISSUED AN ORDER FOR PUBLICADMINISTRATIVE PROCEEDINGS AND CEASE AND DESIST PROCEEDINGS(THE "ORDER FOR PROCEEDINGS") AGAINST RESPONDENTS CORPORATESECURITIES GROUP, INC. ("CSG"), MATTHEW ZAHN ("ZAHN"), DR. GEORGEM. RIZOS ("RIZOS") AND CANDIA L. MAUSSER ("MAUSSER"), PURSUANT TOSECTIONS 15(B), 19(H) AND 21C OF THE SECURITIES EXCHANGE ACT OF1934 . RESPONDENTS HAVE SUBMITTED OFFERS OF SETTLEMENT("OFFERS") WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WHICHSEC HAS DETERMINED TO ACCEPT AND IMPOSE THE REMEDIALSANCTIONS. ACCORDINGLY, IT IS ORDERED THATCSG BE AND HEREBY CENSURED.

Sanctions Ordered: Censure

Decision & Order of Offer of Settlement






[TOP] [10/12/94] SEC NEWS DIGEST, ISSUE 94-190 DATED 10/5/1994 SECANNOUNCED THAT IT INSTITUTED PUBLIC ADMINISTRATIVEPROCEEDINGS AGAINST CORPORATE SECURITIES GROUP, INC., (CSG) AREGISTERED BROKER-DEALER; MATTHEW ZAHN, A REGISTEREDREPRESENTATIVE; DR. GEORGE M. RIZIO, AN UNREGISTERED INDIVIDUAL;AND CANDIA L. MAUSSER, A REGISTERED REPRESENTATVE; THE ORDERINSTITUTING PROCEEDINGS ALLEGES THAT MAUSSER MADE MATERIALMISSTATEMENTS AND OMISSIONS OF FACT IN CONNECTION WITH ANOFFERING OF GOLDSTAR CORPORATION SECURITIES, IN VIOLATION OFTHE ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. THEORDER ALSO ALLEGES THAT MAUSSER EFFECTED SALES OF GOLDSTARSECURITIES WITHOUT THE APPROVAL OF CORPORATE SECURITIES, INVIOLATION OF SECTION 15(A) OF THE EXCHANGE ACT. THE ORDERFURTHER ALLEGES THAT RIZOS AIDED AND ABETTED AND CAUSEDMAUSSER'S VIOLATIONS OF SECTION 15(A) BY ARRANGING FOR THEMAUSSER TO PARTICIPATE IN AN OFFERING OF GOLDSTAR SECURITIES AND ASSISTING MAUSSER IN SELLING THE SECURITIES, AND THAT ZAHN AND CORORATE SECURITIESFAILED REASONABLY TO SUPERVISE MAUSSER WITH A VIEW TOPREVENTING MAUSSER'S VIOLATIONS OF SECTION 15(A) OF THEEXCHANGE ACT. 04/14/97 SEC DOCKET, VOLUME 59, NO. 7, DATED6/13/1995, PAGE 1007, DISCLOSES; SEC ISSUED AN ORDER FOR PUBLICADMINISTRATIVE PROCEEDINGS AND CEASE AND DESIST PROCEEDINGS(THE "ORDER FOR PROCEEDINGS") AGAINST RESPONDENTS CORPORATESECURITIES GROUP, INC. ("CSG"), MATTHEW ZAHN ("ZAHN"), DR. GEORGEM. RIZOS ("RIZOS") AND CANDIA L. MAUSSER ("MAUSSER"), PURSUANT TOSECTIONS 15(B), 19(H) AND 21C OF THE SECURITIES EXCHANGE ACT OF1934 . RESPONDENTS HAVE SUBMITTED OFFERS OF SETTLEMENT("OFFERS") WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WHICHSEC HAS DETERMINED TO ACCEPT AND IMPOSE THE REMEDIALSANCTIONS. ACCORDINGLY, IT IS ORDERED THATCSG BE AND HEREBY CENSURED.


Initiated By: US SECURITIES & EXCHANGE COMMISSION


Cease and Desist



Docket/Case Number: 3-8493



Allegations: FAILURE TO REASONABLE SUPERVISE CANDIA MAUSER, A BROKER, TOPREVENT HER FROM VIOLATING SECTIONS 15(A) OF THE EXCHANGE ACT.



Resolution: Settled








Sanction Details: JWGENESIS FINANCIAL SERVICES, INC. ENTERED INTO A CONSENTAGREEMENT IN WHICH IT WAS CENSURED. AGREED TO PAY $30,000 ANDAGREED TO EMPLOY AN INDEPENDENT CONSULTANT TO REVIEWPROCEDURES AND PREPARE A WRITTEN REPORT. ALL CONDITIONS OFTHE AGREEMENT HAVE BEEN MET







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 40


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

05/04/2000

00-01194

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$21,374.00

AWARD AGAINST PARTY

11/16/2000

$212.50

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 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

06/08/2000

00-01223

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES 81©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC




www.finra.org/awardsonline

https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=00-01194





Disposition:

Disposition Date:


DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES

$42,958.00

AWARD AGAINST PARTY

08/01/2001

$12,958.01


Disclosure 3 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/10/2000

00-02860

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$499,700.00

AWARD AGAINST PARTY

11/14/2001

$32,155.00


Disclosure 4 of 40

i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

10/10/2000

00-04082

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;PREFERRED STOCK

$1,000,000.00

AWARD AGAINST PARTY

03/21/2002

$90,000.00


Disclosure 5 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/15/2001

01-00609

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE


$500,000.00

AWARD AGAINST PARTY

04/17/2002

$5,437,537.00


Disclosure 6 of 40

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/05/2001

01-00623

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$25,000.00

AWARD AGAINST PARTY

11/27/2001

$12,025.00


Disclosure 7 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/15/2001

01-00754

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-ERRORS-CHARGES

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES

$1,994.68

AWARD AGAINST PARTY

09/28/2001

$1,619.69









Disclosure 8 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/19/2001

01-04223

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE


$5,883,000.00

AWARD AGAINST PARTY

09/23/2003

$142,201.43


Disclosure 9 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/29/2001

01-04491

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-COMMISSIONS

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$17,316.00

AWARD AGAINST PARTY

10/08/2002

$11,500.0185©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Sum of All Relief Awarded: $11,500.01


Disclosure 10 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/09/2002

01-06117

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-UNAUTHORIZED TRADING


$38,398.00

AWARD AGAINST PARTY

09/08/2003

$25,000.01


Disclosure 11 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

01/15/2004

03-08593

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE










Disposition:

Disposition Date:


$66,000,000.00

AWARD AGAINST PARTY

03/20/2006

$375,600.00


Disclosure 12 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/11/2005

05-03586

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


$12,000,000.00

AWARD AGAINST PARTY

05/23/2006

$2,021,200.00


Disclosure 13 of 40

i



Arbitration Forum:

Case Initiated:

Allegations:

FINRA

01/15/2010

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE







Case Initiated:

Case Number:



Disposition:

Disposition Date:


01/15/2010

09-07236

ANNUITIES; COMMON STOCK; MUTUAL FUNDS

$2,575.00

AWARD AGAINST PARTY

07/20/2010

$37.50


Disclosure 14 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

05/11/2011

11-01815

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; MUTUAL FUNDS; VARIABLE ANNUITIES

$394,423.00

AWARD AGAINST PARTY

09/12/2012

$8,500.00


Disclosure 15 of 40

i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/13/2013

13-00138

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

MUNICIPAL BOND FUNDS

$500,000.00

AWARD AGAINST PARTY

08/25/2014

$195,000.00


Disclosure 16 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/12/2014

14-00712

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; TRADING DISPUTES-TRANSFERS

VARIABLE ANNUITIES

$481,191.87

AWARD AGAINST PARTY

07/07/2015

$60,400.00


Disclosure 17 of 40

i








Disclosure 17 of 40



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

10/21/2014

14-02953

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-OTHER;TRADING DISPUTES-OTHER

MUTUAL FUNDS

$150,000.01

AWARD AGAINST PARTY

07/18/2016

$181,757.12


Disclosure 18 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

FINRA

08/13/2015

15-01617

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

VARIABLE ANNUITIES

$41,600.00

AWARD AGAINST PARTY








Disposition Date:


04/07/2016

$600.00


Disclosure 19 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

04/19/2016

16-01008

ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

$9,603.15

AWARD AGAINST PARTY

08/29/2016

$9,603.15


Disclosure 20 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



FINRA

05/02/2017

17-00852

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

OTHER TYPES OF SECURITIES

$150,000.01 91©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC








Disposition:

Disposition Date:


$150,000.01

AWARD AGAINST PARTY

02/16/2018

$116,155.81


Disclosure 21 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/02/1991

91-02300

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-NEGLIGENCE


$277,425.00

AWARD AGAINST PARTY

05/27/1992

$29,554.00


Disclosure 22 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

11/04/1991

91-03321

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED








Case Number:



Disposition:

Disposition Date:


91-03321

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$33,755.00

AWARD AGAINST PARTY

07/23/1992

$10,500.00


Disclosure 23 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/03/1991

91-03638

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOTUSE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; UNKNOWN TYPE OF SECURITIES

$26,004.50

AWARD AGAINST PARTY

06/11/1993

$15,000.00


Disclosure 24 of 40

i



Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

05/20/1993

93-01334


Unspecified Damages

AWARD AGAINST PARTY

06/08/1994

$18,000.00


Disclosure 25 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/11/1994

93-04399

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS

$100,000.00

AWARD AGAINST PARTY

02/01/1995

$19,000.00


Disclosure 26 of 40

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/21/1994

94-02952

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$9,305.87

AWARD AGAINST PARTY

04/21/1995

$3,456.00


Disclosure 27 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/21/1994

94-04583

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSYINVOLVED


$9,999.00

AWARD AGAINST PARTY

10/05/1995

$451.22


i95©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Disclosure 28 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/29/1996

96-00033

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$6,903.81

AWARD AGAINST PARTY

07/19/1996

$6,903.81


Disclosure 29 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/14/1996

96-01717

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURETO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$15,000.00

AWARD AGAINST PARTY

12/05/1996

$15,150.00

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








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

Disclosure 30 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/08/1996

96-01841

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;WARRANTS/RIGHTS

$7,502.62

AWARD AGAINST PARTY

12/06/1996

$2,573.58


Disclosure 31 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

09/19/1996

96-03688

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES

$95,027.00

AWARD AGAINST PARTY

07/30/199797©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Disposition Date:


07/30/1997

$70,500.00


Disclosure 32 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/18/1996

96-04744

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$2,519.00

AWARD AGAINST PARTY

05/02/1997

$2,644.00


Disclosure 33 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

11/21/1996

96-04787

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$2,075.29

AWARD AGAINST PARTY98©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC







Disposition:

Disposition Date:


AWARD AGAINST PARTY

06/23/1997

$1,682.29


Disclosure 34 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/30/1997

97-00092



$9,394.13

AWARD AGAINST PARTY

06/25/1997

$9,394.13


Disclosure 35 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

04/28/1997

97-02057

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS 99©2018 FINRA. All rights reserved. Report about WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC









Disposition:

Disposition Date:


COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$120,000.00

AWARD AGAINST PARTY

03/11/1998

$750.00


Disclosure 36 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/28/1997

97-03209

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$87,824.00

AWARD AGAINST PARTY

06/08/1998

$35,000.00


Disclosure 37 of 40

i



Arbitration Forum:

Case Initiated:

Allegations:

NASD

11/12/1997

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED







Case Initiated:

Case Number:



Disposition:

Disposition Date:


11/12/1997

97-05245


$56,928.08

AWARD AGAINST PARTY

09/08/1999

$31,400.00


Disclosure 38 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/16/1998

98-00121



$2,850.00

AWARD AGAINST PARTY

06/26/1998

$625.00


Disclosure 39 of 40

i



Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-MARGINCALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

04/07/1999

99-01464


$65,419.87

AWARD AGAINST PARTY

04/14/2000

$20,225.00


Disclosure 40 of 40

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/02/1999

99-04213

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$4,500,000.00

AWARD AGAINST PARTY

01/24/2003

$16,475,116.00









End of Report

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