wells fargo securities, llc - finra · wells fargo securities, llc sec# 126292 8-65876 main office...

BrokerCheck Report

WELLS FARGO SECURITIES, LLC

Section Title

Report Summary

Firm History

CRD# 126292

1

11

Firm Profile 2 - 10

Page(s)

Firm Operations 12 - 26

Disclosure Events 27

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CRD# 126292

SEC# 8-65876

Main Office Location

550 SOUTH TRYON STREET, 6TH FLOORD1086-060CHARLOTTE, NC 28202Regulated by FINRA Atlanta Office

Mailing Address

550 SOUTH TRYON STREET, 6TH FLOORD1086-060CHARLOTTE, NC 28202

Business Telephone Number

704-410-1913

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 141

Civil Event 1

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/05/2003.

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 17 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• 23 Self-Regulatory Organizations• 53 U.S. states and territories

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1©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC


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This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/05/2003.

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.


SEC#

126292

8-65876

Main Office Location

Mailing Address

Business Telephone Number

Doing business as WELLS FARGO SECURITIES, LLC

704-410-1913

Regulated by FINRA Atlanta Office



Other Names of this Firm

Name Where is it used

WELLS FARGO CORPORATE AND/& INVESTMENT BANKING AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VI, VT, WA,WI, WV, WY 2©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC





AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VI, VT, WA,WI, WV, WY

WELLS FARGO SECURITIES AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VT, WA, WI,WV, WY





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?

EVEREN CAPITAL CORPORATION

PARENT

75% or more

No

Domestic Entity

05/2003

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ALLEN, RENEE MCLAUGHLIN

DEPUTY CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

12/2012

Yes

1671337



Position


Position Start Date

CHURCH, DUANE

CHIEF FINANCIAL OFFICER

Less than 5%

Individual

04/2019

7075686








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


DOLHARE, WALTER ERNESTO

PRESIDENT/CEO/MANAGER

Less than 5%

No

Individual

09/2018

Yes

2071314



Position



Position Start Date


ENGEL, ROBERT ANDREW

DIRECTOR/MANAGER

Less than 5%

No

Individual

09/2018

Yes

1972255



KIKER, STEVEN MATTHEW

5373298








Firm Profile

Position



Position Start Date


CHIEF OPERATING OFFICER/MANAGER

Less than 5%

No

Individual

09/2018

Yes

5373298


Position



Position Start Date


MCGEOUGH, LISA MARIE

DIRECTOR/MANAGER

Less than 5%

No

Individual

07/2019

Yes

1296590



Position


Position Start Date


MULLIGAN, ROBERT JOHN JR

CHIEF COMPLIANCE OFFICER/MANAGER

Less than 5%

Individual

12/2012

Yes

1584973









Firm Profile



No

Yes

Position



Position Start Date


PINK, CHRISTOPHER WILLIAM

DIRECTOR/MANAGER

Less than 5%

No

Individual

03/2015

Yes

4564921



Position



Position Start Date


PRIMAVERA, TODD GERALD

CHIEF OPERATIONS OFFICER

Less than 5%

No

Individual

02/2013

No

2416001



SHREWSBERRY, JOHN RICHARD

Individual

2264673









Firm Profile

Position



Position Start Date


DIRECTOR/MANAGER

Less than 5%

No

Individual

07/2014

No


Position



Position Start Date


SMITH, JEREMY B

DIRECTOR/MANAGER

Less than 5%

No

Individual

04/2016

Yes

6288628



Position



Position Start Date


THOMAS, DANIEL JEROME JR

DIRECTOR/MANAGER

Less than 5%

No

Individual

07/2019

Yes









Firm Profile


No






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

Indirect Owners

Firm Profile

WELLS FARGO & COMPANY

STOCKHOLDER

WFC HOLDINGS, LLC

75% or more

Yes

Domestic Entity

12/2017

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




WFC HOLDINGS, LLC

STOCKHOLDER

EVEREN CAPITAL CORPORATION

75% or more

No

Domestic Entity

12/2017

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

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

No information reported.






Firm Operations

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

This firm is currently registered with the SEC, 23 SROs and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

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

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 05/29/2003

Self-Regulatory Organization Status Date Effective

FINRA Approved 05/29/2003

BOX Exchange LLC Approved 05/07/2012

Cboe BYX Exchange, Inc. Approved 10/11/2010

Cboe BZX Exchange, Inc. Approved 08/18/2008

Cboe C2 Exchange, Inc. Approved 04/01/2014

Cboe EDGA Exchange, Inc. Approved 06/09/2010

Cboe EDGX Exchange, Inc. Approved 06/09/2010

Cboe Exchange, Inc. Approved 06/29/2007

Investors' Exchange LLC Approved 07/25/2016

MIAX Emerald, LLC Approved 03/06/2019

MIAX PEARL, LLC Approved 02/06/2017

Miami International Securities Exchange,LLC

Approved 04/21/2014

NYSE American LLC Approved 07/01/2003

NYSE Arca, Inc. Approved 07/18/2011

NYSE Chicago, Inc. Approved 06/26/2003






NYSE National, Inc. Approved 09/17/2018

Nasdaq BX, Inc. Approved 01/13/2009

Nasdaq GEMX, LLC Approved 01/02/2014

Nasdaq ISE, LLC Approved 06/27/2003

Nasdaq MRX, LLC Approved 02/10/2016

Nasdaq PHLX LLC Approved 06/25/2003

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 07/01/2003





Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 06/11/2003

Alaska Approved 06/04/2003

Arizona Approved 06/02/2003

Arkansas Approved 06/05/2003

California Approved 05/30/2003

Colorado Approved 06/02/2003

Connecticut Approved 06/02/2003

Delaware Approved 06/12/2003

District of Columbia Approved 05/05/2003

Florida Approved 06/03/2003

Georgia Approved 06/04/2003

Hawaii Approved 06/23/2003

Idaho Approved 06/03/2003

Illinois Approved 06/03/2003

Indiana Approved 06/04/2003

Iowa Approved 06/04/2003

Kansas Approved 06/06/2003

Kentucky Approved 06/02/2003

Louisiana Approved 06/19/2003

Maine Approved 06/12/2003

Maryland Approved 06/09/2003

Massachusetts Approved 06/23/2003

Michigan Approved 06/26/2003

Minnesota Approved 06/03/2003

Mississippi Approved 06/04/2003

Missouri Approved 06/11/2003

Montana Approved 04/17/2003

Nebraska Approved 06/27/2003

Nevada Approved 06/13/2003

New Hampshire Approved 06/09/2003

New Jersey Approved 06/04/2003

New Mexico Approved 06/02/2003

New York Approved 06/04/2003

U.S. States &Territories

Status Date Effective

North Carolina Approved 05/30/2003

North Dakota Approved 06/06/2003

Ohio Approved 06/09/2003

Oklahoma Approved 06/02/2003

Oregon Approved 06/09/2003

Pennsylvania Approved 06/16/2003

Puerto Rico Approved 06/03/2003

Rhode Island Approved 06/18/2003

South Carolina Approved 06/11/2003

South Dakota Approved 06/04/2003

Tennessee Approved 06/16/2003

Texas Approved 06/23/2003

Utah Approved 06/02/2003

Vermont Approved 06/26/2003

Virgin Islands Approved 09/09/2010

Virginia Approved 06/03/2003

Washington Approved 05/30/2003

West Virginia Approved 06/02/2003

Wisconsin Approved 06/16/2003

Wyoming Approved 06/04/2003






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.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.

Non-Securities Business Description: 13B-APPLICANT ENGAGES IN LOAN SYNDICATION

This firm currently conducts 17 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer making inter-dealer markets in corporation securities over-the-counter

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 retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Solicitor of time deposits in a financial institution

Put and call broker or dealer or option writer

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

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables

Other - 12Z-SOLICITS & EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSE PURCHASEAGREEMENTS, BANKER'S ACCEPTANCE, DEPOSIT NOTES & OTHER EXEMPT SECURITIES TRANSACTIONSFOR AFFILIATED AND NON-AFFILIATED ENTITIES. APPLICANT PRODUCES RESEARCH, OFFERS MERGERS &ACQUISITION SERVICES; ENGAGES IN STOCK LOAN/STOCK BORROWED ACTIVITIES, SECURITIESLENDING, MARGIN LENDING, PRIME BROKER SERVICES. APPLICANT ENGAGES IN MERGERS &ACQUISITIONS ADVISORY BUSINESS. APPLICANT IS A PRIMARY DEALER OF THE FEDERAL RESERVE BANKOF NY.






Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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

Name: WELLS FARGO CLEARING SERVICES, LLC

Business Address: ONE NORTH JEFFERSON AVENUESAINT LOUIS, MO 63103

CRD #: 19616

Effective Date: 02/05/2017

Description: WELLS FARGO SECURITIES, LLC, ("WFS,LLC") INTRODUCES SOME OFITS CUSTOMER TRANSACTIONS TO WELLS FARGO CLEARINGSERVICES, LLC ON A FULLY DISCLOSED BASIS. THIS OCCURS ONLYWHEN WFS,LLC DOES NOT HAVE THE INFRASTRUCTURE OR SYSTEMSTO MAINTAIN AND CLEAR THESE TRANSACTIONS.






Firm Operations

Industry Arrangements

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

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

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

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

Name: WELLS FARGO & COMPANY

Business Address: 301 S. COLLEGE STREETCHARLOTTE, NC 28202


Description: WELLS FARGO & CO.PROVIDES OPERATIONAL FACILITIES ANDSUPPORT, DATA PROCESSING AND RECORD-KEEPING FUNCTIONS FORAPPLICANT.

Name: WELLS FARGO CLEARING SERVICES, LLC

Business Address: ONE NORTH JEFFERSON AVENUESAINT LOUIS, MO 63103

CRD #: 19616


Description: WELLS FARGO SECURITIES, LLC, ("WFS,LLC") INTRODUCES SOME OFITS CUSTOMER TRANSACTIONS TO WELLS FARGO CLEARINGSERVICES, LLC ON A FULLY DISCLOSED BASIS. THIS OCCURS ONLYWHEN WFS,LLC DOES NOT HAVE THE INFRASTRUCTURE OR SYSTEMSTO MAINTAIN AND CLEAR THESE TRANSACTIONS.






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.

No

Yes

SINGAPORE

Yes

09/12/2019

30/F CAPITAGREEN 138 MARKET STREET048946SINGAPORE, SINGAPORE

WELLS FARGO SECURITIES SINGAPORE PTE. LTD is under common control with the firm.

WELLS FARGO SECURITIES SINGAPORE PTE, LIMITED AND WELLS FARGOSECURITIES, LLC ARE SUBSIDIARIES OF EVEREN CAPITAL CORPORATION,WHICH IS A WHOLLY OWNED SUBSIDIARY OF WELLS FARGO & COMPANY.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

CANADA

Yes

08/01/2012

40 KING STREET WEST, SUITE 2100SCOTIA PLAZATORONTO, CANADA M5H 3C2

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

WELLS FARGO SECURITIES, LLC AND WELLS FARGO SECURITIES CANADA,LTD. ARE BOTH WHOLLY OWNED BY WELLS FARGO & COMPANY, THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)WELLS FARGO SECURITIES, LLC AND WELLS FARGO SECURITIES CANADA,LTD. ARE BOTH WHOLLY OWNED BY WELLS FARGO & COMPANY, THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

No

Yes

No

08/01/2012

45 FREMONT STREET30TH FLOORSAN FRANCISCO, CA 94105

133068

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

WELLS FARGO SECURITIES, LLC AND WELLS FARGO PRIME SERVICES,LLC ARE BOTH WHOLLY OWNED BY WELLS FARGO & COMPANY, THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

ENGLAND

Yes

03/20/2010

34 GROSVENOR STREETLONDON, ENGLAND W1K 4QU

132377

EUROPEAN CREDIT MANAGEMENT LIMITED is under common control with the firm.

THE AFFILIATE IS OWNED BY AFFILATES WHOLLY OWNED BY EVERENCAPITAL CORPORATION. EVEREN CAPITAL CORPORATION IS WHOLLYOWNED BY WELLS FARGO & COMPANY. WELLS FARGO & COMPANY IS THEULTIMATE PARENT OF THE AFFILATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

MARUNOUCHI TRUST TOWER MAIN 24TH FLOOR8-1 MARUNOUCHI-1-CHROMETOKYO, JAPAN

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

Business Address:






Firm Operations

Organization Affiliates (continued)

Yes

Yes

JAPAN

Yes

12/31/2008

MARUNOUCHI TRUST TOWER MAIN 24TH FLOOR8-1 MARUNOUCHI-1-CHROMETOKYO, JAPAN

THE AFFILIATE IS WHOLLY OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION WHICH IS WHOLLY OWNED BY WELLS FARGOBANK, NATIONAL ASSOCIATION. WELLS FARGO BANK, NATIONALASSOCIATION IS ULTIMATELY WHOLLY OWNED BY WELLS FARGO &COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Yes

Yes

CHINA

Yes

12/31/2008

27/F THREE PACIFIC PLACE1 QUEEN'S ROAD EASTWAN CHAI, HONG KONG

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

THE AFFILIATE IS WHOLLY OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION WHICH IS WHOLLY OWNED BY WELLS FARGOBANK, NATIONAL ASSOCIATION. WELLS FARGO BANK, NATIONALASSOCIATION IS ULTIMATELY WHOLLY OWNED BY WELLS FARGO &COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

UNITED KINGDOM

Yes

01/01/2009

LECONFIELD HOUSECURZON STREETLONDON, ENGLAND WIJ-5JA

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

Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

UNITED KINGDOM

THE AFFILIATE IS OWNED BY WELLS FARGO INTERNATIONAL BANKINGCORPORATION WHICH IS WHOLLY OWNED BY WELLS FARGO BANK, N.A.WHICH IS 100% OWNED BY WFC HOLDINGS CORPORATION, WHICH ISWHOLLY OWNED BY WELLS FARGO & COMPANY. WELLS FARGO &COMPANY IS THE ULTIMATE PARENT OF THE AFFILATE AND THEAPPLICANT.

Description:



Country:

No

Yes

No

01/01/2009

525 MARKET STREET12TH FLOORSAN FRANCISCO, CA 94105

133366

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

WELLS FARGO FUNDS DISTRIBUTOR, LLC AND WELLS FARGOINVESTMENTS, LLC ARE SUBSIDIARIES OF WELLS FARGO INVESTMENTGROUP, INC., WHICH IS A WHOLLY OWNED SUBSIDIARY OF WELLS FARGO& COMPANY.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

No

01/01/2009

SIXTH & MARQUETTEMINNEAPOLIS, MN 55479

106487

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


Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

GALLIARD CAPITAL MANAGEMENT, INC. IS WHOLLY OWNED BY WELLSFARGO BANK, N.A.

Description:



Yes

No

No

01/01/2009


104973

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

WELLS CAPITAL MANAGEMENT, INC IS A WHOLLY-OWNED SUBSIDIARY OFWELLS FARGO BANK, N.A.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

01/01/2009


110841

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

WELLS FARGO FUNDS MANAGEMENT, INC. AND WELLS FARGOINVESTMENTS, LLC ARE SUBSIDIARIES OF WELLS FARGO INVESTMENTGROUP, INC., WHICH IS A WHOLLY OWNED SUBSIDIARY OF WELLS FARGO& COMPANY.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

No

04/12/2005

401 SOUTH TRYON STREETCHARLOTTE, NC 28202

133204

ALTERNATIVE STRATEGIES GROUP, INC. is under common control with the firm.

THE APPLICANT 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

07/06/2004

301 SOUTH COLLEGE STREETTW-8CHARLOTTE, NC 28288

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

STRUCTURED ASSET INVESTORS, LLC IS A WHOLLY OWNED SUBSIDIARYOF WELLS FARGO & COMPANY. SAI ACTIVITY EXEMPTS IT FROM IAREGISTRATION.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

03/24/2010

420 MONTGOMERY STREETSAN FRANCISCO, CA 94104

WELLS FARGO BANK, N.A. is under common control with the firm.

Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

100% OWNED BY WELLS FARGO & COMPANYDescription:



Country:

No

Yes

BERMUDA

Yes

03/05/2003

CLARENDON HOUSE, 2 CHURCH STREETHAMILTON HM11, BERMUDA

EVERGREEN WORLDWIDE DISTRIBUTORS, LTD. is under common control with the firm.

THE AFFILIATE IS WHOLLY OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION, WHICH IS WHOLLY OWNED BY WELLS FARGO &COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/05/2003

200 BERKLEY STREETBOSTON, MA 02116

487

ALTERNATIVE STRATEGIES BROKERAGE SERVICES, INC. is under common control with the firm.

SUBSIDIARY OF WELLS FARGO & COMPANY, APPLICANT'S ULTIMATEPARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

11025

WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC is under common control with the firm.

CRD #:24©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC





Firm Operations


Yes

Yes

No

03/05/2003

ONE NORTH JEFFERSON AVENUEST LOUIS, MO 63103

11025

AFFILIATE OWNED BY WELLS FARGO & COMPANY (PARENT) THROUGHINTERMEDIATE SUBS.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

03/05/2003

6802 PARAGON PLACESUITE 200RICHMOND, VA 23230-1720

TATTERSALL ADVISORY GROUP, INC. is under common control with the firm.

SUBSIDIARY OF WELLS FARGO & COMPANY, APPLICANT'S ULTIMATEPARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

03/05/2003

ONE NORTH JEFFERSON AVENUEST. LOUIS, MO 63103

19616

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


Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

BOTH APPLICANT AND AFFILIATE ARE 100% OWNED BY WELLS FARGO &COMPANY

Description:


Yes

No

ENGLAND

Yes

03/05/2003

CENTURION HOUSE24 MONUMENT STREET, 4TH FLOORLONDON, ENGLAND EC348A2

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

SUBSIDIARY OF WELLS FARGO INTERNATIONAL BANKING CORPORATIONDescription:



Country:

Foreign Entity:

Effective Date:

Business Address:

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

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

Effective Date:

Business Address:

Description: WELLS FARGO & COMPANY IS THE INDIRECT OWNER OF WELLS FARGOSECURITIES, LLC.

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

01/01/2009

420 MONTGOMERY STREETSAN FRANCISCO, CA 94104






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 0 141 0

Civil Event 0 1 0






Disclosure Event Details

What you should know about reported disclosure events:

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

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

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

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

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

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

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

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

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

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

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

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

Regulatory - Final

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

Disclosure 1 of 141

Reporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT ORCONCLUSIONS OF LAW, WELLS FARGO SECURITIES, LLC ("WFS")CONSENTED TO THE ISSUANCE OF AN ORDER IN WHICH THE CBOTBUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON AUGUST 25,2015 AND JANUARY 15, 2016, WFS PRE-HEDGED BLOCK TRADES INTREASURIES FUTURES PRIOR TO CONSUMMATION OF THE BLOCKTRADES. THE PANEL ALSO FOUND THAT WFS FAILED TO TIMELY REPORT ABLOCK TRADE TO THE CME, AND TO DILIGENTLY SUPERVISE ITS TRADERIN THE CONDUCT OF ITS BUSINESS RELATING TO THE EXCHANGE, BYFAILING TO PROVIDE SUFFICIENT TRAINING REGARDING THEPROHIBITION ON PRE-HEDGING BLOCK TRADES, ALL IN VIOLATION OFCME RULES.

Current Status: Final






Initiated By: CHICAGO BOARD OF TRADE (CBOT)

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

DISGORGEMENT

Date Initiated: 05/25/2018

Docket/Case Number: CBOT-16-0477-BC

Principal Product Type: Futures - Financial

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT ORCONCLUSIONS OF LAW, WELLS FARGO SECURITIES, LLC ("WFS")CONSENTED TO THE ISSUANCE OF AN ORDER IN WHICH THE CBOTBUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON AUGUST 25,2015 AND JANUARY 15, 2016, WFS PRE-HEDGED BLOCK TRADES INTREASURIES FUTURES PRIOR TO CONSUMMATION OF THE BLOCKTRADES. THE PANEL ALSO FOUND THAT WFS FAILED TO TIMELY REPORT ABLOCK TRADE TO THE CME, AND TO DILIGENTLY SUPERVISE ITS TRADERIN THE CONDUCT OF ITS BUSINESS RELATING TO THE EXCHANGE, BYFAILING TO PROVIDE SUFFICIENT TRAINING REGARDING THEPROHIBITION ON PRE-HEDGING BLOCK TRADES, ALL IN VIOLATION OFCME RULES.

Resolution Date: 05/25/2018

Resolution:

Other Sanctions Ordered: DISGORGEMENT OF $117,187.50

Sanction Details: $70,000. FINE PAID

Sanctions Ordered: Monetary/Fine $70,000.00Disgorgement/Restitution

Decision & Order of Offer of Settlement

Disclosure 2 of 141

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Reporting Source: Regulator

Allegations: WELLS FARGO: (I) FAILED TO RECORD AN ACCURATE ORDERTRANSMISSION TIME FOR ONE (SAMPLED) MANUAL OPTIONS ORDERROUTED TO THE EXCHANGE; AND (II) FAILED TO ESTABLISH, MAINTAIN,AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEMFOR APPLYING SUCH PROCEDURES, REASONABLY DESIGNED TOPREVENT AND DETECT VIOLATIONS OF SECURITIES LAWS ANDREGULATIONS GOVERNING BOOKS AND RECORDS REQUIREMENTSCONCERNING DOCUMENTING TRANSMISSION TIMES FOR ORDERS SENTTO THIRD-PARTY BROKER-DEALERS FOR EXECUTION BY FLOORBROKERS. (VIOLATIONS OF EXCHANGE RULES 4.2, 4.24 AND 15.1, SECTION17(A) OF THE EXCHANGE ACT AND RULE 17A 3 THEREUNDER)







Initiated By: CBOE EXCHANGE, INC.





Docket/Case Number: 17-0061/ 20160487737

Principal Product Type: Options


WELLS FARGO: (I) FAILED TO RECORD AN ACCURATE ORDERTRANSMISSION TIME FOR ONE (SAMPLED) MANUAL OPTIONS ORDERROUTED TO THE EXCHANGE; AND (II) FAILED TO ESTABLISH, MAINTAIN,AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEMFOR APPLYING SUCH PROCEDURES, REASONABLY DESIGNED TOPREVENT AND DETECT VIOLATIONS OF SECURITIES LAWS ANDREGULATIONS GOVERNING BOOKS AND RECORDS REQUIREMENTSCONCERNING DOCUMENTING TRANSMISSION TIMES FOR ORDERS SENTTO THIRD-PARTY BROKER-DEALERS FOR EXECUTION BY FLOORBROKERS. (VIOLATIONS OF EXCHANGE RULES 4.2, 4.24 AND 15.1, SECTION17(A) OF THE EXCHANGE ACT AND RULE 17A 3 THEREUNDER)


Resolution:

Other Sanctions Ordered: A CENSURE OF WELLS FARGO AND A TOTAL FINE IMPOSED BY CBOE ANDTHE OTHER SECURITIES EXCHANGES REFERENCED ABOVE AND BELOWIN THE AMOUNT OF $54,000, OF WHICH $18,000 SHALL BE PAID TO CBOE.

WELLS FARGO AGREES TO AN UNDERTAKING WHEREBY WELLS FARGOWILL AMEND ITS WRITTEN SUPERVISORY PROCEDURES TO INCLUDESUPERVISOR REVIEW OF ITS MANUAL OPTIONS ORDERS FOR DETAILACCURACY AND TO ENSURE THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN.WITHIN THIRTY (30) DAYS OF THE ISSUANCE OF A DECISION ACCEPTINGTHIS LETTER OF CONSENT BY THE BUSINESS CONDUCT COMMITTEE ANDTHE SELF-REGULATORY ORGANIZATIONS LISTED IN FOOTNOTE 2, AREGISTERED PRINCIPAL OF WELLS FARGO SHALL SUBMIT TO THECOMPLIANCE ASSISTANT, LEGAL SECTION, MARKET REGULATIONDEPARTMENT, 9509 KEY WEST AVENUE, ROCKVILLE, MD 20850, A SIGNED,DATED ATTESTATION PROVIDING THE FOLLOWING INFORMATION: (1) AREFERENCE TO THIS MATTER; (2) A REPRESENTATION THAT WELLSFARGO HAS IMPLEMENTED REVISED SUPERVISORY PROCEDURES TOADDRESS THE ISSUES DESCRIBED ABOVE; AND (3) THE DATES THAT THISWAS COMPLETED.

ACCEPTANCE OF THIS LETTER OF CONSENT IS CONDITIONED UPONACCEPTANCE OF SIMILAR SETTLEMENT AGREEMENTS IN RELATEDMATTERS BETWEEN THE FIRM AND EACH OF THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: NYSE AMERICAN, NYSE ARCA AND PHLX.THE AGGREGATE FINE ACROSS ALL MARKETS IS $75,000.

Sanctions Ordered: CensureMonetary/Fine $18,000.00

Consent






A CENSURE OF WELLS FARGO AND A TOTAL FINE IMPOSED BY CBOE ANDTHE OTHER SECURITIES EXCHANGES REFERENCED ABOVE AND BELOWIN THE AMOUNT OF $54,000, OF WHICH $18,000 SHALL BE PAID TO CBOE.



Sanction Details: A CENSURE OF WELLS FARGO AND A TOTAL FINE IMPOSED BY CBOE ANDTHE OTHER SECURITIES EXCHANGES REFERENCED ABOVE AND BELOWIN THE AMOUNT OF $54,000, OF WHICH $18,000 SHALL BE PAID TO CBOE.



iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THAT DURINGA 2016 EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUAL OPTIONORDER RECORDS FOR TIMESTAMP ACCURACY AND DETERMINED THATTHE FIRM DID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR 21ORDERS (APPROXIMATELY 53 PERCENT OF THE SAMPLE OF 40) SENT TOFLOOR BROKERS DURING THE EXAM REVIEW PERIOD. DURING THESUPERVISION REVIEW PERIOD, ALTHOUGH THE FIRM'S WRITTENSUPERVISORY PROCEDURES (WSPS) REQUIRED THAT REGISTEREDREPRESENTATIVES RECORD TRANSMISSION TIMES INTO THE FIRM'SORDER MANAGEMENT SYSTEM, THE FIRM'S WSPS FAILED TO INCLUDESUPERVISORY REVIEWS TO ENSURE THE ACCURACY OF ITS MANUALOPTIONS ORDER TICKETS. THUS, THE FIRM WAS UNABLE TO PRODUCEEVIDENCE THAT TRANSMISSION TIMES WERE THE SUBJECT OFSUPERVISORY REVIEWS. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE A SYSTEM REASONABLY DESIGNED TOSUPERVISE THE OPERATIONS OF ITS BUSINESS AND ENSURECOMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS ANDREGULATIONS AND THE SRO RULES PERTAINING TO BOOKS ANDRECORDS.







Initiated By: CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE)




CENSURE AND FINE OF $18,000.


Docket/Case Number: 17-0061 (STAR 20160487737)



WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THAT DURINGA 2016 EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUAL OPTIONORDER RECORDS FOR TIMESTAMP ACCURACY AND DETERMINED THATTHE FIRM DID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR 21ORDERS (APPROXIMATELY 53 PERCENT OF THE SAMPLE OF 40) SENT TOFLOOR BROKERS DURING THE EXAM REVIEW PERIOD. DURING THESUPERVISION REVIEW PERIOD, ALTHOUGH THE FIRM'S WRITTENSUPERVISORY PROCEDURES (WSPS) REQUIRED THAT REGISTEREDREPRESENTATIVES RECORD TRANSMISSION TIMES INTO THE FIRM'SORDER MANAGEMENT SYSTEM, THE FIRM'S WSPS FAILED TO INCLUDESUPERVISORY REVIEWS TO ENSURE THE ACCURACY OF ITS MANUALOPTIONS ORDER TICKETS. THUS, THE FIRM WAS UNABLE TO PRODUCEEVIDENCE THAT TRANSMISSION TIMES WERE THE SUBJECT OFSUPERVISORY REVIEWS. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE A SYSTEM REASONABLY DESIGNED TOSUPERVISE THE OPERATIONS OF ITS BUSINESS AND ENSURECOMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS ANDREGULATIONS AND THE SRO RULES PERTAINING TO BOOKS ANDRECORDS.


Resolution:

Other Sanctions Ordered: REVIEW WRITTEN SUPERVISORY PROCEDURES AND IMPLEMENTPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE RULES AND REQUIREMENTS.

Sanction Details: $18,000.00 FINE PAID


Acceptance, Waiver & Consent(AWC)

Disclosure 3 of 141

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Allegations: DURING THE 2016 EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUALOPTION ORDER RECORDS FOR TIMESTAMP ACCURACY AND DETERMINEDTHAT THE FIRM DID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR21 ORDERS (APPROXIMATELY 53% OF THE SAMPLE OF 40) SENT TOFLOOR BROKERS DURING FEBRUARY 22, 2016 THROUGH FEBRUARY 26,2016 (THE EXAM REVIEW PERIOD). OF THESE 21 ORDERS, 14 WEREEXECUTED ON NASDAQ PHLX LLC (THE EXCHANGE). THE FIRM VIOLATEDSECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A) AND EXCHANGE RULE760. FROM THE BEGINNING OF 2014 THROUGH THE PRESENT (THESUPERVISION REVIEW PERIOD), ALTHOUGH THE FIRM'S WRITTENSUPERVISOR PROCEDURES (WSPS) REQUIRED THAT REGISTEREDREPRESENTATIVES RECORD TRANSMISSION TIMES INTO THE FIRM'SORDER MANAGEMENT SYSTEM, THE FIRM'S WSPS FAILED TO INCLUDESUPERVISORY REVIEWS TO ENSURE THE ACCURACY OF ITS MANUALOPTIONS ORDER TICKETS. THUS, THE FIRM WAS UNABLE TO PRODUCEEVIDENCE THAT TRANSMISSION TIMES WERE THE SUBJECT OFSUPERVISORY REVIEWS. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE A SYSTEM REASONABLY DESIGNED TOSUPERVISE THE OPERATIONS OF ITS BUSINESS AND ENSURECOMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS ANDREGULATIONS AND EXCHANGE RULES PERTAINING TO BOOKS ANDRECORDS. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULE 748.







Initiated By: NASDAQ PHLX LLC


Other


N/A


Docket/Case Number: 2016048773703



Allegations: DURING THE 2016 EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUALOPTION ORDER RECORDS FOR TIMESTAMP ACCURACY AND DETERMINEDTHAT THE FIRM DID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR21 ORDERS (APPROXIMATELY 53% OF THE SAMPLE OF 40) SENT TOFLOOR BROKERS DURING FEBRUARY 22, 2016 THROUGH FEBRUARY 26,2016 (THE EXAM REVIEW PERIOD). OF THESE 21 ORDERS, 14 WEREEXECUTED ON NASDAQ PHLX LLC (THE EXCHANGE). THE FIRM VIOLATEDSECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A) AND EXCHANGE RULE760. FROM THE BEGINNING OF 2014 THROUGH THE PRESENT (THESUPERVISION REVIEW PERIOD), ALTHOUGH THE FIRM'S WRITTENSUPERVISOR PROCEDURES (WSPS) REQUIRED THAT REGISTEREDREPRESENTATIVES RECORD TRANSMISSION TIMES INTO THE FIRM'SORDER MANAGEMENT SYSTEM, THE FIRM'S WSPS FAILED TO INCLUDESUPERVISORY REVIEWS TO ENSURE THE ACCURACY OF ITS MANUALOPTIONS ORDER TICKETS. THUS, THE FIRM WAS UNABLE TO PRODUCEEVIDENCE THAT TRANSMISSION TIMES WERE THE SUBJECT OFSUPERVISORY REVIEWS. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE A SYSTEM REASONABLY DESIGNED TOSUPERVISE THE OPERATIONS OF ITS BUSINESS AND ENSURECOMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS ANDREGULATIONS AND EXCHANGE RULES PERTAINING TO BOOKS ANDRECORDS. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULE 748.


Resolution:

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

No








Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM MADE AND ENTERED INTO AN OFFER OF SETTLEMENT,STIPULATION TO FINDINGS AND CONSENT TO SANCTIONS (THE OFFER,)PURSUANT TO EXCHANGE RULE 960.7, SOLELY FOR THE PURPOSES OFTHESE PROCEEDINGS AND TO SETTLE AND CONCLUDE ALL DISCIPLINARYACTIONS BY THE EXCHANGE BASED ON OR ARISING OUT OF THEFINDINGS HEREINAFTER STIPULATED. THE FIRM STIPULATES TO THEENTRY OF FINDINGS, CONSENTS TO THE CONCLUSION OF VIOLATIONS OFCERTAIN FEDERAL SECURITIES LAWS AND EXCHANGE RULES, ANDCONSENTS TO THE IMPOSITION OF SANCTIONS SPECIFICALLY INCLUDING,BUT NOT LIMITED TO, CONSENTING TO PAY THE FINE IMPOSED BY THEBUSINESS CONDUCT COMMITTEE CONSISTENT WITH THE OFFER, AND TOCOMPLY WITH ALL OTHER SANCTIONS, ALL AS HEREINAFTER SET FORTH,WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR CONCLUSIONSIN THE STATEMENT OF CHARGES. THE COMMITTEE CONCURS IN THESANCTIONS CONSENTED TO BY THE FIRM, AND ORDERS THE IMPOSITIONOF THE FOLLOWING SANCTIONS: A CENSURE; AN AGGREGATE FINE OF$54,000, OF WHICH $18,000 SHALL BE DUE TO THE EXCHANGE; AND ANUNDERTAKING REQUIRING THE FIRM TO AMEND ITS WSPS TO INCLUDESUPERVISORY REVIEW OF ITS MANUAL OPTIONS ORDERS FOR ORDERDETAIL ACCURACY, AND TO ENSURE THAT THAT THE FIRM HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITEDHEREIN. THE BALANCE OF THE SANCTION WILL BE PAID TO NYSE ARCA,INC., NYSE AMERICAN LLC, AND CBOE EXCHANGE, INC. (ASSOCIATEDCASE: ENFORCEMENT NO. 2017-15)










Initiated By: NASDAQ PHLX LLC










Resolution:





Disclosure 4 of 141

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING A 2016EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUAL OPTION ORDERRECORDS FOR TIMESTAMP ACCURACY AND DETERMINED THAT THE FIRMDID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR 21 ORDERS(APPROXIMATELY 53 PERCENT OF THE SAMPLE OF 40) SENT TO FLOORBROKERS DURING THE EXAM REVIEW PERIOD. OF THESE 21 ORDERS,FOUR WERE EXECUTED ON NYSE AMERICAN. THIS CONDUCTCONSTITUTES A VIOLATION OF EXCHANGE ACT RULE 17A-3(A) AND NYSEAMERICAN RULE 956NY. DURING THE SUPERVISION REVIEW PERIOD,ALTHOUGH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS)REQUIRED THAT REGISTERED REPRESENTATIVES RECORDTRANSMISSION TIMES INTO THE FIRM'S ORDER MANAGEMENT SYSTEM,THE FIRM'S WSPS FAILED TO INCLUDE SUPERVISORY REVIEWS TOENSURE THE ACCURACY OF ITS MANUAL OPTIONS ORDER TICKETS.THUS, THE FIRM WAS UNABLE TO PRODUCE EVIDENCE THATTRANSMISSION TIMES WERE THE SUBJECT OF SUPERVISORY REVIEWS.ADDITIONALLY, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEA SYSTEM REASONABLY DESIGNED TO SUPERVISE THE OPERATIONS OFITS BUSINESS AND ENSURE COMPLIANCE WITH APPLICABLE FEDERALSECURITIES LAWS AND REGULATIONS AND NYSE AMERICAN RULESPERTAINING TO BOOKS AND RECORDS. THIS CONDUCT CONSTITUTES AVIOLATION OF NYSE AMERICAN RULE 320.







Initiated By: NYSE AMERICAN LLC







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING A 2016EXAM, STAFF REVIEWED 40 OF THE FIRM'S MANUAL OPTION ORDERRECORDS FOR TIMESTAMP ACCURACY AND DETERMINED THAT THE FIRMDID NOT MAINTAIN ACCURATE TRANSMISSION TIMES FOR 21 ORDERS(APPROXIMATELY 53 PERCENT OF THE SAMPLE OF 40) SENT TO FLOORBROKERS DURING THE EXAM REVIEW PERIOD. OF THESE 21 ORDERS,FOUR WERE EXECUTED ON NYSE AMERICAN. THIS CONDUCTCONSTITUTES A VIOLATION OF EXCHANGE ACT RULE 17A-3(A) AND NYSEAMERICAN RULE 956NY. DURING THE SUPERVISION REVIEW PERIOD,ALTHOUGH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS)REQUIRED THAT REGISTERED REPRESENTATIVES RECORDTRANSMISSION TIMES INTO THE FIRM'S ORDER MANAGEMENT SYSTEM,THE FIRM'S WSPS FAILED TO INCLUDE SUPERVISORY REVIEWS TOENSURE THE ACCURACY OF ITS MANUAL OPTIONS ORDER TICKETS.THUS, THE FIRM WAS UNABLE TO PRODUCE EVIDENCE THATTRANSMISSION TIMES WERE THE SUBJECT OF SUPERVISORY REVIEWS.ADDITIONALLY, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEA SYSTEM REASONABLY DESIGNED TO SUPERVISE THE OPERATIONS OFITS BUSINESS AND ENSURE COMPLIANCE WITH APPLICABLE FEDERALSECURITIES LAWS AND REGULATIONS AND NYSE AMERICAN RULESPERTAINING TO BOOKS AND RECORDS. THIS CONDUCT CONSTITUTES AVIOLATION OF NYSE AMERICAN RULE 320.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $54,000, OF WHICH $9,000SHALL BE PAID TO THE EXCHANGE AND THE REMAINDER OF THE FINEWILL BE PAID TO EACH OF THE FOLLOWING SELF-REGULATORYORGANIZATIONS: CBOE EXCHANGE, INC.; NYSE ARCA, INC., AND NASDAQPHLX LLC, AND UNDERTAKES TO REVISE THE ITS WSPS.


No








Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $54,000, OF WHICH $9,000SHALL BE PAID TO THE EXCHANGE AND THE REMAINDER OF THE FINEWILL BE PAID TO EACH OF THE FOLLOWING SELF-REGULATORYORGANIZATIONS: CBOE EXCHANGE, INC.; NYSE ARCA, INC., AND NASDAQPHLX LLC, AND UNDERTAKES TO REVISE THE ITS WSPS.


Initiated By: NYSE AMERICAN LLC




CENSURE AND FINE OF $9,000.








Resolution: Acceptance, Waiver & Consent(AWC)







Other Sanctions Ordered: UNDERTAKING THAT INCLUDES REVIEW WRITTEN SUPERVISORYPROCEDURES AND IMPLEMENT PROCEDURES REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH THE RULES AND REQUIREMENTS.



Disclosure 5 of 141

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Allegations: DECEMBER 20, 2017, WELLS FARGO SECURITIES, LLC AND NYSE ARCA,INC. ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THESOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUTADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TOIN THE OFFER OF SETTLEMENT. THE HEARING OFFICER ACCEPTS THEOFFER OF SETTLEMENT AND CONSENT AND ISSUE THIS DECISION INACCORDANCE WITH NYSE ARCA RULES. ON BEHALF OF THE EXCHANGE,FINRA'S STAFF CONDUCTED A REVIEW (THE "2016 EXAM") OF WELLSFARGO'S COMPLIANCE WITH SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"), AND RULE17A-3 THEREUNDER, IN ADDITION TO NYSE ARCA OPTIONS RULE 6.68,WHICH FOCUSED ON MANUAL OPTIONS ORDERS ON TRADE DATES FROMFEBRUARY 22, 2016, THROUGH FEBRUARY 26, 2016 (THE "EXAM REVIEWPERIOD"). THE STAFF ALSO REVIEWED THE FIRM'S COMPLIANCE WITHNYSE ARCA RULE 11.18 AND THE FIRM'S PROCEDURES RELATED TO THEHANDLING OF MANUAL OPTIONS ORDERS THAT IT HAD IN PLACE FROMTHE BEGINNING OF 2014 THROUGH THE PRESENT (THE "SUPERVISIONREVIEW PERIOD"). IN A LETTER DATED JULY 18, 2017, WHICH WELLSFARGO RECEIVED, FINRA, ON BEHALF OF THE EXCHANGE, NOTIFIEDWELLS FARGO THAT IT WAS INVESTIGATING WHETHER THE FIRMVIOLATED EXCHANGE ACT RULE 17A-3 AND NYSE ARCA OPTION RULE 6.68AND NYSE ARCA RULE 11.18 DURING THE EXAM REVIEW PERIOD. AS ARESULT OF ITS REVIEW, THE STAFF DETERMINED THAT WELLS FARGOVIOLATED EXCHANGE ACT RULE 17A-3(A) AND NYSE ARCA OPTIONS RULE6.68 BY FAILING TO MAINTAIN ACCURATE BOOKS AND RECORDS OFMANUAL OPTIONS ORDERS HANDLED BY THE FIRM DURING THE EXAMREVIEW PERIOD. ADDITIONALLY, WELLS FARGO VIOLATED NYSE ARCARULE 11.18 DURING THE SUPERVISION REVIEW PERIOD BY FAILING TOESTABLISH, MAINTAIN, ENFORCE, AND KEEP CURRENT A SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS"), OFCOMPLIANCE AND SUPERVISORY CONTROLS, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS AND NYSE ARCA RULES PERTAINING TO RECORDKEEPINGREQUIREMENTS. DURING THE 2016 EXAM, THE STAFF REVIEWED 40 OFWELLS FARGO'S MANUAL OPTION ORDER RECORDS FOR TIMESTAMPACCURACY AND DETERMINED THAT THE FIRM DID NOT MAINTAINACCURATE TRANSMISSION TIMES FOR 21 ORDERS (APPROXIMATELY 53%OF THE SAMPLE OF 40) SENT TO FLOOR BROKERS DURING THE EXAMREVIEW PERIOD. OF THESE 21 ORDERS, 2 WERE EXECUTED ON THEEXCHANGE. THE CONDUCT DESCRIBED HEREIN CONSTITUTES AVIOLATION OF EXCHANGE ACT RULE 17A-3(A) AND NYSE ARCA OPTIONSRULE 6.68. DURING THE SUPERVISION REVIEW PERIOD, ALTHOUGHWELLS FARGO'S WSPS REQUIRED REGISTERED REPRESENTATIVES TORECORD TRANSMISSION TIMES INTO THE FIRM'S ORDER MANAGEMENTSYSTEM THE WSPS FAILED TO INCLUDE SUPERVISORY REVIEWS TOENSURE THE ACCURACY OF ITS MANUAL OPTIONS ORDER TICKETS.THUS, THE FIRM WAS UNABLE TO PRODUCE EVIDENCE THATTRANSMISSION TIMES WERE THE SUBJECT OF SUPERVISORY REVIEWS.ADDITIONALLY, WELLS FARGO FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE A SYSTEM REASONABLY DESIGNED TO SUPERVISE THEOPERATIONS OF ITS BUSINESS AND ENSURE COMPLIANCE WITHAPPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS ANDEXCHANGE RULES PERTAINING TO BOOKS AND RECORDS. THE CONDUCTDESCRIBED IN PARAGRAPHS 12 AND 13 CONSTITUTES A VIOLATION OFNYSE ARCA RULE 11.18.







Initiated By: NYSE ARCA, INC.


Other


N/A



Principal Product Type: No Product


DECEMBER 20, 2017, WELLS FARGO SECURITIES, LLC AND NYSE ARCA,INC. ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THESOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUTADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TOIN THE OFFER OF SETTLEMENT. THE HEARING OFFICER ACCEPTS THEOFFER OF SETTLEMENT AND CONSENT AND ISSUE THIS DECISION INACCORDANCE WITH NYSE ARCA RULES. ON BEHALF OF THE EXCHANGE,FINRA'S STAFF CONDUCTED A REVIEW (THE "2016 EXAM") OF WELLSFARGO'S COMPLIANCE WITH SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"), AND RULE17A-3 THEREUNDER, IN ADDITION TO NYSE ARCA OPTIONS RULE 6.68,WHICH FOCUSED ON MANUAL OPTIONS ORDERS ON TRADE DATES FROMFEBRUARY 22, 2016, THROUGH FEBRUARY 26, 2016 (THE "EXAM REVIEWPERIOD"). THE STAFF ALSO REVIEWED THE FIRM'S COMPLIANCE WITHNYSE ARCA RULE 11.18 AND THE FIRM'S PROCEDURES RELATED TO THEHANDLING OF MANUAL OPTIONS ORDERS THAT IT HAD IN PLACE FROMTHE BEGINNING OF 2014 THROUGH THE PRESENT (THE "SUPERVISIONREVIEW PERIOD"). IN A LETTER DATED JULY 18, 2017, WHICH WELLSFARGO RECEIVED, FINRA, ON BEHALF OF THE EXCHANGE, NOTIFIEDWELLS FARGO THAT IT WAS INVESTIGATING WHETHER THE FIRMVIOLATED EXCHANGE ACT RULE 17A-3 AND NYSE ARCA OPTION RULE 6.68AND NYSE ARCA RULE 11.18 DURING THE EXAM REVIEW PERIOD. AS ARESULT OF ITS REVIEW, THE STAFF DETERMINED THAT WELLS FARGOVIOLATED EXCHANGE ACT RULE 17A-3(A) AND NYSE ARCA OPTIONS RULE6.68 BY FAILING TO MAINTAIN ACCURATE BOOKS AND RECORDS OFMANUAL OPTIONS ORDERS HANDLED BY THE FIRM DURING THE EXAMREVIEW PERIOD. ADDITIONALLY, WELLS FARGO VIOLATED NYSE ARCARULE 11.18 DURING THE SUPERVISION REVIEW PERIOD BY FAILING TOESTABLISH, MAINTAIN, ENFORCE, AND KEEP CURRENT A SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS"), OFCOMPLIANCE AND SUPERVISORY CONTROLS, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS AND NYSE ARCA RULES PERTAINING TO RECORDKEEPINGREQUIREMENTS. DURING THE 2016 EXAM, THE STAFF REVIEWED 40 OFWELLS FARGO'S MANUAL OPTION ORDER RECORDS FOR TIMESTAMPACCURACY AND DETERMINED THAT THE FIRM DID NOT MAINTAINACCURATE TRANSMISSION TIMES FOR 21 ORDERS (APPROXIMATELY 53%OF THE SAMPLE OF 40) SENT TO FLOOR BROKERS DURING THE EXAMREVIEW PERIOD. OF THESE 21 ORDERS, 2 WERE EXECUTED ON THEEXCHANGE. THE CONDUCT DESCRIBED HEREIN CONSTITUTES AVIOLATION OF EXCHANGE ACT RULE 17A-3(A) AND NYSE ARCA OPTIONSRULE 6.68. DURING THE SUPERVISION REVIEW PERIOD, ALTHOUGHWELLS FARGO'S WSPS REQUIRED REGISTERED REPRESENTATIVES TORECORD TRANSMISSION TIMES INTO THE FIRM'S ORDER MANAGEMENTSYSTEM THE WSPS FAILED TO INCLUDE SUPERVISORY REVIEWS TOENSURE THE ACCURACY OF ITS MANUAL OPTIONS ORDER TICKETS.THUS, THE FIRM WAS UNABLE TO PRODUCE EVIDENCE THATTRANSMISSION TIMES WERE THE SUBJECT OF SUPERVISORY REVIEWS.ADDITIONALLY, WELLS FARGO FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE A SYSTEM REASONABLY DESIGNED TO SUPERVISE THEOPERATIONS OF ITS BUSINESS AND ENSURE COMPLIANCE WITHAPPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS ANDEXCHANGE RULES PERTAINING TO BOOKS AND RECORDS. THE CONDUCTDESCRIBED IN PARAGRAPHS 12 AND 13 CONSTITUTES A VIOLATION OFNYSE ARCA RULE 11.18.


Resolution:


No








Sanction Details: THE FIRM IS CENSURED, FINED $9,000, AND REQUIRED TO AMEND ITSWSPS.

Regulator Statement WELLS FARGO SECURITIES, LLC VIOLATED: EXCHANGE ACT RULES 17A-3(A) AND NYSE ARCA OPTIONS RULE 6.68 BY FAILING TO MAINTAINACCURATE BOOKS AND RECORDS; AND NYSE ARCA RULE 11.18 BYFAILING TO ESTABLISH, MAINTAIN, AND ENFORCE A SYSTEM, INCLUDINGWRITTEN PROCEDURES, REASONABLY DESIGNED TO SUPERVISE THEOPERATIONS OF ITS BUSINESS AND ENSURE COMPLIANCE WITHAPPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS ANDEXCHANGE RULES PERTAINING TO BOOKS AND RECORDS, AS DESCRIBEDABOVE. ACCORDINGLY, WELLS FARGO SECURITIES, LLC IS CENSUREDAND FINED $9,000. WELLS FARGO SHALL AMEND ITS WSPS TO INCLUDESUPERVISORY REVIEW OF ITS MANUAL OPTIONS ORDERS FOR ORDERDETAIL ACCURACY AND TO ENSURE THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN.


No










Initiated By: NYSE ARCA INC




UNDERTAKING, CENSURE AND FINE OF $9,000.00







Resolution:





Disclosure 6 of 141

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOACCURATELY REPORT TRANSACTIONS TO TRACE IN TRACE-ELIGIBLESECURITIES. THE FINDINGS STATED THAT THE FIRM REPORTEDTRANSACTIONS WITH A COUNTER-PARTY FIRM AS A CUSTOMER INSTEADOF USING THE COUNTER-PARTY'S MPID. THE FINDINGS ALSO STATEDTHAT THE FIRM SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHFINRA RULE 6730. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DIDNOT INCLUDE WSPS TO REVIEW TRADES REPORTED TO TRACE FORACCOUNTS OF BROKER-DEALERS THAT WERE REPORTED AS ACUSTOMER. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TOREPORT TO TRACE THE CORRECT TIME OF EXECUTION FOR 58TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES. THE FIRMALSO FAILED TO REPORT 54 TRANSACTIONS IN TRACE-ELIGIBLE AGENCYDEBT SECURITIES WITHIN THE TIME PERMITTED BY FINRA RULE 6730.FINRA FOUND THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE MEMORANDUM OF 25 BROKERAGE ORDERS. FINRAALSO FOUND THAT FIRM FAILED TO REPORT 81 NEW ISSUE OFFERINGS INTRACE-ELIGIBLE ASSET-BACKED SECURITIES TO TRACE ACCORDING TOTHE TIME FRAMES SET FORTH IN FINRA RULE 6760.







Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOACCURATELY REPORT TRANSACTIONS TO TRACE IN TRACE-ELIGIBLESECURITIES. THE FINDINGS STATED THAT THE FIRM REPORTEDTRANSACTIONS WITH A COUNTER-PARTY FIRM AS A CUSTOMER INSTEADOF USING THE COUNTER-PARTY'S MPID. THE FINDINGS ALSO STATEDTHAT THE FIRM SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHFINRA RULE 6730. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DIDNOT INCLUDE WSPS TO REVIEW TRADES REPORTED TO TRACE FORACCOUNTS OF BROKER-DEALERS THAT WERE REPORTED AS ACUSTOMER. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TOREPORT TO TRACE THE CORRECT TIME OF EXECUTION FOR 58TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES. THE FIRMALSO FAILED TO REPORT 54 TRANSACTIONS IN TRACE-ELIGIBLE AGENCYDEBT SECURITIES WITHIN THE TIME PERMITTED BY FINRA RULE 6730.FINRA FOUND THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE MEMORANDUM OF 25 BROKERAGE ORDERS. FINRAALSO FOUND THAT FIRM FAILED TO REPORT 81 NEW ISSUE OFFERINGS INTRACE-ELIGIBLE ASSET-BACKED SECURITIES TO TRACE ACCORDING TOTHE TIME FRAMES SET FORTH IN FINRA RULE 6760.


Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ONDECEMBER 19, 2017.


No








https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2016049241601


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)





Docket/Case Number: 20160492416-01

Principal Product Type: Debt - Asset Backed


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMFAILED TO REPORT TO TRACE THE CORRECT TIME OF EXECUTION, FAILEDTO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OFBROKERAGE ORDERS, FAILED TO ACCURATELY REPORT TRANSACTIONSIN TRACE, FAILED TO PROVIDE TIMELY NOTICE FOR NEW ISSUEOFFERINGS IN TRACE-ELIGIBLE ABS, AND DID NOT PROVIDE FORSUPERVISION THAT WAS REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULE 6730.



Resolution:


Sanction Details: $30,000 FINE PAID ON 12/19/2017.



Disclosure 7 of 141

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT ALL OF ITS REPORTABLE CONVENTIONAL OPTIONS POSITIONSDUE TO THE FIRM'S FAILURE TO DEVELOP AND IMPLEMENT A LARGEOPTIONS POSITIONS REPORT (LOPR) SYSTEM AFTER DETERMINING THATTHE FIRM HAD BEEN FAILING TO REPORT CERTAIN OPTIONS POSITIONSFOR AN UNKNOWN BUT SIGNIFICANT PERIOD OF TIME BECAUSE OF THEFIRM'S ERRONEOUS BELIEF THAT THE POSITIONS WERE NOTREPORTABLE. THE FINDINGS STATED THAT AFTER IDENTIFYING ANDREMEDIATING THE FIRM'S FAILURE TO REPORT REPORTABLECONVENTIONAL OPTIONS POSITIONS TO LOPR, FINRA DETERMINED THATTHE FIRM STILL FAILED TO ACCURATELY REPORT AN UNKNOWN BUTSIGNIFICANT NUMBER OF CONVENTIONAL OPTIONS POSITIONS TO THELOPR. THE FINDINGS ALSO STATED THAT THE FIRM AND A CUSTOMEREXCEEDED THE OVER-THE-COUNTER (OTC) POSITION LIMIT BY 25% FORAT LEAST 461 TRADING DATES IN OPTIONS RELATED TO ONE SECURITY,AND BY 40% FOR TWO TRADING DATES IN OPTIONS RELATED TOANOTHER SECURITY. THESE VIOLATIONS HAD NOT BEEN DETECTED BYTHE FIRM BECAUSE OF ITS LOPR-RELATED DEFICIENCIES. THE FINDINGSALSO INCLUDED THAT THE FIRM FAILED TO REPORT AN UNKNOWN,ALTHOUGH SMALL, NUMBER OF PHYSICALLY SETTLED OTC EXERCISESTO THE FINRA TRADE REPORTING FACILITY (TRF) WITH AN .RX MODIFIER.FINRA FOUND THAT THE FIRM FAILED TO MAINTAIN ANY TYPE OF SYSTEMOF SUPERVISION, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW,WHICH WERE DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULESGOVERNING THE REPORTING OF CONVENTIONAL OPTIONS POSITIONS TOTHE LOPR SYSTEM. THE FIRM ALSO LACKED ANY RELEVANT WRITTENSUPERVISORY PROCEDURES (WSPS) REQUIRING RELEVANT REVIEWS.AFTER IMPLEMENTING SUPERVISORY SYSTEMS AND WSPS PERTAININGTO THE REPORTING OF CONVENTIONAL OPTIONS TO LOPR, THE FIRMSTILL FAILED TO ADEQUATELY SUPERVISE BY FAILING TO DETECTERRORS IN NUMEROUS CONVENTIONAL OPTIONS POSITIONS REPORTEDTO THE LOPR. THE FIRM DID NOT HAVE AN ADEQUATE SYSTEM OFSUPERVISION, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW ANDRELEVANT WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH RULES RELATED TO THE EXERCISE OF PHYSICALLY SETTLED OTCOPTIONS.







Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT ALL OF ITS REPORTABLE CONVENTIONAL OPTIONS POSITIONSDUE TO THE FIRM'S FAILURE TO DEVELOP AND IMPLEMENT A LARGEOPTIONS POSITIONS REPORT (LOPR) SYSTEM AFTER DETERMINING THATTHE FIRM HAD BEEN FAILING TO REPORT CERTAIN OPTIONS POSITIONSFOR AN UNKNOWN BUT SIGNIFICANT PERIOD OF TIME BECAUSE OF THEFIRM'S ERRONEOUS BELIEF THAT THE POSITIONS WERE NOTREPORTABLE. THE FINDINGS STATED THAT AFTER IDENTIFYING ANDREMEDIATING THE FIRM'S FAILURE TO REPORT REPORTABLECONVENTIONAL OPTIONS POSITIONS TO LOPR, FINRA DETERMINED THATTHE FIRM STILL FAILED TO ACCURATELY REPORT AN UNKNOWN BUTSIGNIFICANT NUMBER OF CONVENTIONAL OPTIONS POSITIONS TO THELOPR. THE FINDINGS ALSO STATED THAT THE FIRM AND A CUSTOMEREXCEEDED THE OVER-THE-COUNTER (OTC) POSITION LIMIT BY 25% FORAT LEAST 461 TRADING DATES IN OPTIONS RELATED TO ONE SECURITY,AND BY 40% FOR TWO TRADING DATES IN OPTIONS RELATED TOANOTHER SECURITY. THESE VIOLATIONS HAD NOT BEEN DETECTED BYTHE FIRM BECAUSE OF ITS LOPR-RELATED DEFICIENCIES. THE FINDINGSALSO INCLUDED THAT THE FIRM FAILED TO REPORT AN UNKNOWN,ALTHOUGH SMALL, NUMBER OF PHYSICALLY SETTLED OTC EXERCISESTO THE FINRA TRADE REPORTING FACILITY (TRF) WITH AN .RX MODIFIER.FINRA FOUND THAT THE FIRM FAILED TO MAINTAIN ANY TYPE OF SYSTEMOF SUPERVISION, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW,WHICH WERE DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULESGOVERNING THE REPORTING OF CONVENTIONAL OPTIONS POSITIONS TOTHE LOPR SYSTEM. THE FIRM ALSO LACKED ANY RELEVANT WRITTENSUPERVISORY PROCEDURES (WSPS) REQUIRING RELEVANT REVIEWS.AFTER IMPLEMENTING SUPERVISORY SYSTEMS AND WSPS PERTAININGTO THE REPORTING OF CONVENTIONAL OPTIONS TO LOPR, THE FIRMSTILL FAILED TO ADEQUATELY SUPERVISE BY FAILING TO DETECTERRORS IN NUMEROUS CONVENTIONAL OPTIONS POSITIONS REPORTEDTO THE LOPR. THE FIRM DID NOT HAVE AN ADEQUATE SYSTEM OFSUPERVISION, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW ANDRELEVANT WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH RULES RELATED TO THE EXERCISE OF PHYSICALLY SETTLED OTCOPTIONS.









Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S SUPERVISORY SYSTEMS

Sanction Details: THE FIRM WAS CENSURED, FINED $3,250,000 AND UNDERTAKE TO REVISEITS SUPERVISORY SYSTEMS. FINES PAID IN FULL ON JULY 12, 2017.

Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,FINRA CONSIDERED THE FOLLOWING: (1) THE FIRM'S PROVISION OFEXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL TO CONDUCT AN EXTENSIVE REVIEW OFTHE FIRM'S OPTIONS REPORTING SYSTEMS, PRACTICES, ANDPROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; (II) THEFIRM'S HIRING OF AN INDEPENDENT CONSULTANT TO CONDUCT ACOMPLETE REVIEW OF THE FIRM'S LOPR SYSTEMS AND TO IDENTIFYDEFICIENCIES, AND CORRECTING THE DEFICIENCIES IDENTIFIED BY THEINDEPENDENT CONSULTANT; AND (III) THE EFFORTS AND ENHANCEMENTSMADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORYPRACTICES AND PROCEDURES.


No

Sanctions Ordered: CensureMonetary/Fine $3,250,000.00





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMFAILED TO REPORT OR MISREPORTED CONVENTIONAL OVER-THE-COUNTER OPTIONS POSITIONS AS REQUIRED BY PERTINENT FINRARULES DURING THE PERIOD OF AT LEAST JANUARY 2008 TO MARCH 2017;AND THAT THE FIRM FAILED TO MAINTAIN A SYSTEM OF SUPERVISIONDESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THEREPORTING OF CONVENTIONAL OPTIONS POSITIONS TO THE LARGEOPTION POSITION REPORTING SYSTEM UNTIL 2014.










CENSURE AND AN UNDERTAKING REQUIRING THE FIRM TO REVIEW ITSSUPERVISORY SYSTEMS.





Resolution:

Other Sanctions Ordered: $3,250,000. THE FIRM MUST COMPLETE AN UNDERTAKING TO REVIEW ITSSUPERVISORY SYSTEMS WITH RESPECT TO REPORTING OFCONVENTIONAL OPTION POSITIONS TO THE LARGE OPTION POSITIONREPORTING SYSTEM.

Sanction Details: FIRM MUST PROVIDE, WITHIN 120 DAYS OF THE AWC, A RESPONSE TOEXPLAIN THE STEPS TAKEN TO REVIEW THE FIRM'S SUPERVISORYSYSTEMS AND PROCESSES TO ADDRESS THE DEFICIENCIES AND THEACTIONS OR REVISED SYSTEMS THE FIRM HAS IMPLEMENTED.

Firm Statement FINE WAS PAID ON JULY 12, 2017.



Disclosure 8 of 141

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOMAINTAIN APPROXIMATELY 350 MILLION ELECTRONIC BROKERAGERECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN ASWORM "WRITE ONCE, READ MANY" FORMAT. THE FINDINGS STATED THATTHE WORM FORMAT IS INTENDED TO PREVENT THE ALTERATION ORDESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY.THE FINDINGS ALSO STATED THAT THE FIRM DID NOT HAVE AN AUDITSYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORMFORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TOOBTAIN AN ATTESTATION FROM SEVERAL OF THEIR THIRD-PARTYVENDORS THAT THEY WILL SUPPLY ELECTRONICALLY STORED RECORDSTO REGULATORY AUTHORITIES IN THE EVENT THE FIRM IS UNABLE TOPROVIDE THE ELECTRONICALLY STORED RECORDS. FINRA FOUND THATTHE FIRM FAILED TO ENFORCE WSPS CONCERNING THE STORAGE OFELECTRONIC BROKER-DEALER RECORDS.







Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOMAINTAIN APPROXIMATELY 350 MILLION ELECTRONIC BROKERAGERECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN ASWORM "WRITE ONCE, READ MANY" FORMAT. THE FINDINGS STATED THATTHE WORM FORMAT IS INTENDED TO PREVENT THE ALTERATION ORDESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY.THE FINDINGS ALSO STATED THAT THE FIRM DID NOT HAVE AN AUDITSYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORMFORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TOOBTAIN AN ATTESTATION FROM SEVERAL OF THEIR THIRD-PARTYVENDORS THAT THEY WILL SUPPLY ELECTRONICALLY STORED RECORDSTO REGULATORY AUTHORITIES IN THE EVENT THE FIRM IS UNABLE TOPROVIDE THE ELECTRONICALLY STORED RECORDS. FINRA FOUND THATTHE FIRM FAILED TO ENFORCE WSPS CONCERNING THE STORAGE OFELECTRONIC BROKER-DEALER RECORDS.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $4,000,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN OR OTHERWISE), INCLUDING A DESCRIPTION OF THE REMEDIALMEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCTADDRESSED IN THE AWC. FINES PAID IN FULL ON 12/30/16.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMSFAILED TO RETAIN ELECTRONIC RECORDS IN WORM FORMAT, FAILED TOIMPLEMENT AN AUDIT SYSTEM REGARDING THE INPUTTING OF RECORDSIN ELECTRONIC STORAGE MEDIA, FAILED TO OBTAIN AN ATTESTATIONFROM THIRD-PARTY VENDORS AND IT'S SUPERVISORY SYSTEM WAS NOTREASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND RULES.
















WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMSFAILED TO RETAIN ELECTRONIC RECORDS IN WORM FORMAT, FAILED TOIMPLEMENT AN AUDIT SYSTEM REGARDING THE INPUTTING OF RECORDSIN ELECTRONIC STORAGE MEDIA, FAILED TO OBTAIN AN ATTESTATIONFROM THIRD-PARTY VENDORS AND IT'S SUPERVISORY SYSTEM WAS NOTREASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND RULES.


Resolution:

Other Sanctions Ordered: $4,000,000. FINE IS TO BE PAID JOINTLY AND SEVERALLY, WITHIN 60 DAYSOF THE AWC, THE CHIEF COMPLIANCE OFFICERS OF THE FIRMS SHALLSUBMIT TO FINRA A WRITTEN PLAN OF HOW THE FIRMS WILL UNDERTAKETO CONDUCT A COMPREHENSIVE REVIEW OF THE POLICIES ANDPROCEDURES INCLUDING A DESCRIPTION OF REMEDIAL MEASURESLEADING TO FULL COMPLIANCE.

Sanction Details: $4,000,000. FINE PAID ON 12/30/2016.



Disclosure 9 of 141

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMFAILED TO DISPLAY IMMEDIATELY 63 CUSTOMER LIMIT ORDERS INNASDAQ SECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) INITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND NASDAQ RULES, CONCERNING THE DISPLAY RULE.SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDEWRITTEN SUPERVISORY PROCEDURES PROVIDING FOR ADEQUATESTEPS THAT THE PERSON(S) RESPONSIBLE FOR SUPERVISION SHOULDTAKE TO ENSURE COMPLIANCE WITH THE DISPLAY RULE.








Initiated By: NASDAQ STOCK MARKET





Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMFAILED TO DISPLAY IMMEDIATELY 63 CUSTOMER LIMIT ORDERS INNASDAQ SECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) INITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND NASDAQ RULES, CONCERNING THE DISPLAY RULE.SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDEWRITTEN SUPERVISORY PROCEDURES PROVIDING FOR ADEQUATESTEPS THAT THE PERSON(S) RESPONSIBLE FOR SUPERVISION SHOULDTAKE TO ENSURE COMPLIANCE WITH THE DISPLAY RULE.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $27,500 AND AN UNDERTAKING TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITHRESPECT TO PROVIDING FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND NASDAQ RULES, CONCERNING THEDISPLAY RULE. WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC,A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRADOCUMENTATION, PROVIDING, AMONG OTHER THINGS, INFORMATIONTHAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURESTO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC AND THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED.


No








THE FIRM WAS CENSURED, FINED $27,500 AND AN UNDERTAKING TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITHRESPECT TO PROVIDING FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND NASDAQ RULES, CONCERNING THEDISPLAY RULE. WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC,A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRADOCUMENTATION, PROVIDING, AMONG OTHER THINGS, INFORMATIONTHAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURESTO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC AND THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED.


Initiated By: THE NASDAQ STOCK MARKET LLC


Censure


FINE OF $27,500.00 AND AN UNDERTAKING TO REVISE THE FIRM'SWRITTEN SUPERVISORY PROCEDURES.



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


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMFAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQSECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY. THE FINDINGS STATED THAT THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASDAQRULES, CONCERNING THE DISPLAY RULE. SPECIFICALLY, THE FIRM'SSUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORYPROCEDURES PROVIDING FOR ADEQUATE STEPS THAT THE PERSON(S)RESPONSIBLE FOR SUPERVISION SHOULD TAKE TO ENSURECOMPLIANCE WITH THE DISPLAY RULE.










Other Sanctions Ordered: UNDERTAKING TO REVISE FIRM'S SUPERVISORY PROCEDURES.

Sanction Details: $27,500.00 FINE PAID.


Disclosure 10 of 141

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Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT EXEMPT TRANSACTIONS AND FAILED TO REPORT EACH OF THESETRANSACTIONS TO FINRA WITH A SHORT EXEMPT MODIFIER. THEFINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLYDESIGNED TO PREVENT THE EXECUTION OR DISPLAY OF A NON-EXEMPTSHORT SALE IN A SECURITY SUBJECT TO A SHORT SALE CIRCUITBREAKER AT A PRICE AT OR BELOW THE NATIONAL BEST BID.



Resolution:


No










Sanction Details: THE FIRM WAS CENSURED AND FINED $25,000. FINE PAID IN FULL ON JULY12, 2016.





Censure


A FINE OF $25,000, CONSISTING OF $10,000 FOR THE SUPERVISIONVIOLATION AND $15,000 FOR THE TRADE REPORTING VIOLATIONS.





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT EXEMPT TRANSACTIONS AND FAILED TO REPORT EACH OF THESETRANSACTIONS TO FINRA WITH A SHORT EXEMPT MODIFIER. THEFINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLYDESIGNED TO PREVENT THE EXECUTION OR DISPLAY OF A NON-EXEMPTSHORT SALE IN A SECURITY SUBJECT TO A SHORT SALE CIRCUITBREAKER AT A PRICE AT OR BELOW THE NATIONAL BEST BID.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $25,000




i















Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODISPLAY IMMEDIATELY 33 CUSTOMER LIMIT ORDERS IN NASDAQSECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY. THIS CONDUCT VIOLATED SECRULE 604 OF REGULATION NMS.



Resolution:


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


No









Initiated By: NASDAQ STOCK MARKET LLC








Allegations: NASDAQ ALLEGED WELLS FARGO SECURITIES, LLC VIOLATED SEC RULE604 OF REGULATION NMS WHEN THE FIRM FAILED TO DISPLAYIMMEDIATELY 33 CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTATION.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATION OF ANY EXCHANGERULES WELLS FARGO SECURITIES AGREES TO THE ACCEPTANCE,WAIVER AND CONSENT.




i


Initiated By: ICE FUTURES U.S., INC.




Allegations: ICE FUTURES U.S., INC ALLEGED WELLS FARGO SECURITIES, LLCVIOLATED EXCHANGE RULE 18.05(A) IN MULTIPLE INSTANCES IN WHICH ITINCORRECTLY REPORTED OPEN INTEREST IN THE HENRY PENULTIMAREFIXED PRICED FUTURE ON THE LAST TRADING DAY FOR THE CONTRACT.













Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATION OF ANY EXCHANGERULE WELLS FARGO SECURITIES AGREES TO THE SETTLEMENTAGREEMENT.

Sanctions Ordered: Monetary/Fine $10,000.00



i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT PROVIDEDCONFIRMATIONS TO CUSTOMERS THAT INACCURATELY REFLECTED THECAPACITY IN WHICH THE FIRM ACTED IN CONNECTION WITH A TOTAL OFAPPROXIMATELY 325,000 TRANSACTIONS, IN VIOLATION OF SECURITIESEXCHANGE ACT OF 1934 SECTION 10 AND RULE 10B-10(A)(2). THEFINDINGS STATED THAT THESE INACCURATE CONFIRMATIONS WEREISSUED DURING A PERIOD OF ABOUT 15 MONTHS. HOWEVER, THE FIRMDISCOVERED THE DESCRIBED FAILURES, INTERNALLY INVESTIGATED THECAUSES AND SCOPE OF THE VIOLATIONS, AND TOOK CORRECTIVEACTION INCLUDING SELF-REPORTING THE MATTER TO FINRA. EXPLICITLY,IN CONNECTION WITH THE DEVELOPMENT OF A NEW BUSINESSPLATFORM, THE FIRM DISCOVERED AN ISSUE WITH THE ACCURACY OFTRADE CONFIRMATIONS IT PROVIDED TO CUSTOMERS. SPECIFICALLY,TRADES WERE NOT PROPERLY BEING DISCLOSED IN THE PROPERCAPACITY IN WHICH THEY WERE EXECUTED, E.G., PRINCIPAL, AGENT ORMIXED CAPACITY. THE FIRM INDICATED THAT THE CAUSE OF THEINACCURACIES WAS A "CODING ISSUE" WITH ITS BACK OFFICE SYSTEM,WHICH IT ROLLED OUT PREVIOUSLY. THE FINDINGS ALSO STATED THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLESUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURESDESIGNED TO ACHIEVE COMPLIANCE WITH ALL APPLICABLE SECURITIESLAWS AND REGULATIONS INCLUDING SUPERVISION OF TRADECONFIRMATIONS AND MONITORING THE ACCURACY OF CONFIRMATIONS.MOREOVER, ALTHOUGH THE FIRM DETECTED INACCURATECONFIRMATIONS IN CONNECTION WITH TRANSACTIONS INVOLVINGMUNICIPAL SECURITIES, IT FAILED TO DETERMINE IF THE INACCURACIESWERE MORE WIDESPREAD AND INVOLVED OTHER SECURITIES. THUS, ITRESULTED IN THE FAILURE TO DELIVER THE ACCURATE TRADECONFIRMATIONS.







Initiated By: FINRA





Principal Product Type: Debt - Municipal

Other Product Type(s): EQUITY SECURITIES

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT PROVIDEDCONFIRMATIONS TO CUSTOMERS THAT INACCURATELY REFLECTED THECAPACITY IN WHICH THE FIRM ACTED IN CONNECTION WITH A TOTAL OFAPPROXIMATELY 325,000 TRANSACTIONS, IN VIOLATION OF SECURITIESEXCHANGE ACT OF 1934 SECTION 10 AND RULE 10B-10(A)(2). THEFINDINGS STATED THAT THESE INACCURATE CONFIRMATIONS WEREISSUED DURING A PERIOD OF ABOUT 15 MONTHS. HOWEVER, THE FIRMDISCOVERED THE DESCRIBED FAILURES, INTERNALLY INVESTIGATED THECAUSES AND SCOPE OF THE VIOLATIONS, AND TOOK CORRECTIVEACTION INCLUDING SELF-REPORTING THE MATTER TO FINRA. EXPLICITLY,IN CONNECTION WITH THE DEVELOPMENT OF A NEW BUSINESSPLATFORM, THE FIRM DISCOVERED AN ISSUE WITH THE ACCURACY OFTRADE CONFIRMATIONS IT PROVIDED TO CUSTOMERS. SPECIFICALLY,TRADES WERE NOT PROPERLY BEING DISCLOSED IN THE PROPERCAPACITY IN WHICH THEY WERE EXECUTED, E.G., PRINCIPAL, AGENT ORMIXED CAPACITY. THE FIRM INDICATED THAT THE CAUSE OF THEINACCURACIES WAS A "CODING ISSUE" WITH ITS BACK OFFICE SYSTEM,WHICH IT ROLLED OUT PREVIOUSLY. THE FINDINGS ALSO STATED THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLESUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURESDESIGNED TO ACHIEVE COMPLIANCE WITH ALL APPLICABLE SECURITIESLAWS AND REGULATIONS INCLUDING SUPERVISION OF TRADECONFIRMATIONS AND MONITORING THE ACCURACY OF CONFIRMATIONS.MOREOVER, ALTHOUGH THE FIRM DETECTED INACCURATECONFIRMATIONS IN CONNECTION WITH TRANSACTIONS INVOLVINGMUNICIPAL SECURITIES, IT FAILED TO DETERMINE IF THE INACCURACIESWERE MORE WIDESPREAD AND INVOLVED OTHER SECURITIES. THUS, ITRESULTED IN THE FAILURE TO DELIVER THE ACCURATE TRADECONFIRMATIONS.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $300,000.FINE PAID IN FULL ON DECEMBER 17, 2015.

Regulator Statement FINRA ACKNOWLEDGES THAT THE FIRM DISCOVERED THE ABOVEDESCRIBED VIOLATIONS, INTERNALLY INVESTIGATED THE CAUSES ANDSCOPE OF THE VIOLATIONS, AND PROACTIVELY TOOK STEPS TOREMEDIATE THE PROBLEMS. THE FIRM FURTHER SELF-REPORTED THEISSUES TO FINRA AND SUBSTANTIALLY ASSISTED FINRA DURING ITSINVESTIGATION, THE FIRM'S SELF-REPORTING OF THE VIOLATIONS,CORRECTIVE ACTION AND SUBSTANTIAL ASSISTANCE WAS TAKEN INTOACCOUNT IN DETERMINING THE AMOUNT OF FINE IMPOSED.ACCORDINGLY, THE FINE IMPOSED IN THIS MATTER WAS REDUCED TOREFLECT CREDIT FOR THE FIRM'S PROACTIVE ACTIONS IN CONNECTIONWITH THIS MATTER.


No









FINRA ACKNOWLEDGES THAT THE FIRM DISCOVERED THE ABOVEDESCRIBED VIOLATIONS, INTERNALLY INVESTIGATED THE CAUSES ANDSCOPE OF THE VIOLATIONS, AND PROACTIVELY TOOK STEPS TOREMEDIATE THE PROBLEMS. THE FIRM FURTHER SELF-REPORTED THEISSUES TO FINRA AND SUBSTANTIALLY ASSISTED FINRA DURING ITSINVESTIGATION, THE FIRM'S SELF-REPORTING OF THE VIOLATIONS,CORRECTIVE ACTION AND SUBSTANTIAL ASSISTANCE WAS TAKEN INTOACCOUNT IN DETERMINING THE AMOUNT OF FINE IMPOSED.ACCORDINGLY, THE FINE IMPOSED IN THIS MATTER WAS REDUCED TOREFLECT CREDIT FOR THE FIRM'S PROACTIVE ACTIONS IN CONNECTIONWITH THIS MATTER.




Censure


FINE




Other Product Type(s): TRADE CONFIRMATIONS FOR CONVERTIBLE BONDS, EQUITY SECURITIES,REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS.

Allegations: THE ALLEGATIONS STATE THAT WELLS FARGO SECURITIES, LLC("WFS,LLC") PROVIDED CONFIRMATIONS TO CUSTOMERS THATINACCURATELY REFLECTED THE CAPACITY IN WHICH THE FIRM ACTED, ,E.G., PRINCIPAL, AGENT OR MIXED CAPACITY, IN VOLATION OF SEASECTION 10, SEA RULE 10B-10(A)(2), AND FINRA RULES 2232(A) AND 2010;AND THAT WFS,LLC FAILED TO ESTABLISH, MAINTAIN AND ENFORCE AREASONABLE SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES DESIGNED TO ACHIEVE COMPLIANCE WITH ALLAPPLICABLE SECURITIES LAWS AND REGULATIONS REGARDINGSUPERVISION OF TRADE CONFIRMATIONS IN VIOLATION OF NASDCONDUCT RULE 3010(A) AND (B) AND FINRA RULE 2010.



Resolution:


Sanction Details: WTHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGOSECURITIES, LLC CONSENTED TO THE SANCTIONS AND ENTRY OF THEFINDINGS (CENSURE AND $300,000.00 FINE).




i









Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS). THE FINDINGS STATED THATTHE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $12,500. FINE PAID IN FULL.


No












Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHOURITY (FINRA)


Censure


FINE OF $12,500.







Resolution:






i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEPERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013, THE FIRM FAILED TODISPLAY IMMEDIATELY 30 CUSTOMER LIMIT ORDERS IN NMS STOCK IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED RULE604 OF REGULATION NMS.















WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEPERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013, THE FIRM FAILED TODISPLAY IMMEDIATELY 30 CUSTOMER LIMIT ORDERS IN NMS STOCK IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED RULE604 OF REGULATION NMS.


Resolution:




No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WFS, LLC CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEPERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013, WFS, LLC FAILED TODISPLAY IMMEDIATELY 30 CUSTOMER LIMIT ORDERS IN NMS STOCK IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO WFS, LLC'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH WFS, LLC'SBID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED RULE604 OF REGULATION NMS.









Censure


FINE OF $7,500.00





WITHOUT ADMITTING OR DENYING THE FINDINGS, WFS, LLC CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEPERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013, WFS, LLC FAILED TODISPLAY IMMEDIATELY 30 CUSTOMER LIMIT ORDERS IN NMS STOCK IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO WFS, LLC'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH WFS, LLC'SBID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED RULE604 OF REGULATION NMS.


Resolution:


Sanction Details: WFS, LLC WAS CENSURED AND FINED $7,500.00




i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMVIOLATED PROVISIONS OF NASD RULE 2711, THROUGH ITS PARTICIPATIONIN A PLANNED INITIAL PUBLIC OFFERING (IPO). THE FINDINGS STATEDTHAT A COMPANY AND ITS PRIVATE EQUITY OWNERS ("SPONSORS")INVITED THE FIRM TO COMPETE FOR A ROLE IN THE COMPANY'S PLANNEDIPO. THE FIRM ALLOWED ITS RESEARCH ANALYST TO PARTICIPATE IN THEFIRM'S SOLICITATION EFFORTS BY MAKING A PRESENTATION TO THECOMPANY AND ITS SPONSORS DURING THE SOLICITATION PERIOD. TOWIN THIS INVESTMENT BANKING BUSINESS FROM THE COMPANY THEFIRM ALLOWED ITS EQUITY RESEARCH ANALYST TO PARTICIPATE IN THEFIRM'S SOLICITATION EFFORTS. THEREFORE, IN THE CONTEXT OF THECOMPANY'S IPO, THIS WAS A CONFLICT OF INTEREST BY THE RESEARCHANALYST AS THEY WERE PROHIBITED FROM PARTICIPATING IN EFFORTSTO SOLICIT INVESTMENT BANKING BUSINESS. ADDITIONALLY, THE FIRMCOMPLIED WITH THE COMPANY'S REQUEST FOR A VALUATION THATINCLUDED THE ANALYST'S VIEWS. THE FINDINGS ALSO STATED THAT THEFIRM OFFERED FAVORABLE RESEARCH COVERAGE TO INDUCE THECOMPANY TO AWARD THE FIRM ITS INVESTMENT BANKING BUSINESS BYCOMPLETING AND SUBMITTING TO THE COMPANY, DURING THESOLICITATION PERIOD, A VALUATION TEMPLATE REQUESTED BY THECOMPANY AND THE SPONSORS. THE FIRM UNDERSTOOD THAT THECOMPANY AND THE SPONSORS WANTED A FINAL VALUATION THAT THEENTIRE FIRM, INCLUDING ITS ANALYST, WOULD SUPPORT IF SELECTED ASAN UNDERWRITER. BY PROVIDING THE COMPANY THE UNIFIEDVALUATION IT SOUGHT, THE FIRM INDICATED TO THE COMPANY THATPOST-IPO RESEARCH COVERAGE WOULD BE POSITIVE AND ALIGNEDWITH INVESTMENT BANKING. SHORTLY THEREAFTER, THE COMPANY ANDTHE SPONSORS SELECTED THE FIRM AS A PASSIVE BOOK-RUNNER FORTHE COMPANY'S IPO. THE COMPANY, HOWEVER, EVENTUALLY DECIDEDNOT TO PROCEED WITH THE OFFERING. THE FINDINGS ALSO INCLUDEDTHAT THE FIRM'S SUPERVISORY POLICIES AND PROCEDURES DID NOTREQUIRE SUFFICIENT OVERSIGHT OF THE DISCLOSURE OF POTENTIALCONFLICTS DURING PUBLIC MEDIA APPEARANCES FOR ITS ANALYSTS BYTHE MEDIA OUTLET INVOLVED. AS A RESULT, REQUIRED DISCLOSURES OFPOTENTIAL CONFLICTS AND CONFLICTS OF INTEREST WERE NOT MADEBY THOSE MEDIA OUTLETS. THEREBY, THE FIRM FAILED TO ESTABLISH,MAINTAIN AND ENFORCE REASONABLY ADEQUATE SUPERVISORY SYSTEMAND WRITTEN SUPERVISORY PROCEDURES TO ENSURE COMPLIANCEWITH THE APPLICABLE RULE.







Initiated By: FINRA


Other


N/A



Principal Product Type: Penny Stock(s)

Other Product Type(s): INITIAL PUBLIC OFFERING

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMVIOLATED PROVISIONS OF NASD RULE 2711, THROUGH ITS PARTICIPATIONIN A PLANNED INITIAL PUBLIC OFFERING (IPO). THE FINDINGS STATEDTHAT A COMPANY AND ITS PRIVATE EQUITY OWNERS ("SPONSORS")INVITED THE FIRM TO COMPETE FOR A ROLE IN THE COMPANY'S PLANNEDIPO. THE FIRM ALLOWED ITS RESEARCH ANALYST TO PARTICIPATE IN THEFIRM'S SOLICITATION EFFORTS BY MAKING A PRESENTATION TO THECOMPANY AND ITS SPONSORS DURING THE SOLICITATION PERIOD. TOWIN THIS INVESTMENT BANKING BUSINESS FROM THE COMPANY THEFIRM ALLOWED ITS EQUITY RESEARCH ANALYST TO PARTICIPATE IN THEFIRM'S SOLICITATION EFFORTS. THEREFORE, IN THE CONTEXT OF THECOMPANY'S IPO, THIS WAS A CONFLICT OF INTEREST BY THE RESEARCHANALYST AS THEY WERE PROHIBITED FROM PARTICIPATING IN EFFORTSTO SOLICIT INVESTMENT BANKING BUSINESS. ADDITIONALLY, THE FIRMCOMPLIED WITH THE COMPANY'S REQUEST FOR A VALUATION THATINCLUDED THE ANALYST'S VIEWS. THE FINDINGS ALSO STATED THAT THEFIRM OFFERED FAVORABLE RESEARCH COVERAGE TO INDUCE THECOMPANY TO AWARD THE FIRM ITS INVESTMENT BANKING BUSINESS BYCOMPLETING AND SUBMITTING TO THE COMPANY, DURING THESOLICITATION PERIOD, A VALUATION TEMPLATE REQUESTED BY THECOMPANY AND THE SPONSORS. THE FIRM UNDERSTOOD THAT THECOMPANY AND THE SPONSORS WANTED A FINAL VALUATION THAT THEENTIRE FIRM, INCLUDING ITS ANALYST, WOULD SUPPORT IF SELECTED ASAN UNDERWRITER. BY PROVIDING THE COMPANY THE UNIFIEDVALUATION IT SOUGHT, THE FIRM INDICATED TO THE COMPANY THATPOST-IPO RESEARCH COVERAGE WOULD BE POSITIVE AND ALIGNEDWITH INVESTMENT BANKING. SHORTLY THEREAFTER, THE COMPANY ANDTHE SPONSORS SELECTED THE FIRM AS A PASSIVE BOOK-RUNNER FORTHE COMPANY'S IPO. THE COMPANY, HOWEVER, EVENTUALLY DECIDEDNOT TO PROCEED WITH THE OFFERING. THE FINDINGS ALSO INCLUDEDTHAT THE FIRM'S SUPERVISORY POLICIES AND PROCEDURES DID NOTREQUIRE SUFFICIENT OVERSIGHT OF THE DISCLOSURE OF POTENTIALCONFLICTS DURING PUBLIC MEDIA APPEARANCES FOR ITS ANALYSTS BYTHE MEDIA OUTLET INVOLVED. AS A RESULT, REQUIRED DISCLOSURES OFPOTENTIAL CONFLICTS AND CONFLICTS OF INTEREST WERE NOT MADEBY THOSE MEDIA OUTLETS. THEREBY, THE FIRM FAILED TO ESTABLISH,MAINTAIN AND ENFORCE REASONABLY ADEQUATE SUPERVISORY SYSTEMAND WRITTEN SUPERVISORY PROCEDURES TO ENSURE COMPLIANCEWITH THE APPLICABLE RULE.


Resolution:


No









Sanction Details: THE FIRM WAS CENSURED AND FINED $4,000,000. FINE PAID IN FULL ONDECEMBER 19, 2014.


No



Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. (FINRA)




CENSURE



Principal Product Type: Penny Stock(s)

Other Product Type(s): INITIAL PUBLIC OFFERING

Allegations: THE ALLEGATIONS STATE WELLS FARGO SECURITIES, LLC VIOLATEDNASD RULES 2711(C)(4), 2711(E), 2711(I), AND FINRA RULE 2010 BYALLOWING ITS RESEARCH ANALYST TO PARTICIPATE IN THE SOLICITATIONOF INVESTMENT BANKING BUSINESS AND BY OFFERING FAVORABLERESEARCH COVERAGE TO INDUCE INVESTMENT BANKING BUSINESS INCONNECTION WITH A 2010 PLANNED INITIAL PUBLIC OFFERING; AND BYFAILING TO IMPLEMENT POLICIES AND PROCEDURES REASONABLYDESIGNED TO PREVENT VIOLATIONS OF NASD RULE 2711(H) INCONNECTION WITH ANALYST PUBLIC APPEARANCES.



Resolution:










Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGOSECURITIES, LLC (WFS LLC) CONSENTED TO THE SANCTIONS AND ENTRYOF THE FINDINGS (CENSURE AND $4,000,000.00 FINE).


i


Initiated By: WISCONSIN DIVISION OF SECURITIES





Docket/Case Number: S-09137 (EX)


Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.



Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON 01/25/2010.

Sanctions Ordered: Monetary/Fine $457,903.77Disgorgement/RestitutionCease and Desist/Injunction

Consent


i









Initiated By: WEST VIRGINIA SECURITIES COMMISSION










Resolution:




Consent


i


Initiated By: VIRGINIA SECURITIES COMMISSION




Docket/Case Number: SEC-2009-00044














Resolution:



Sanctions Ordered: Monetary/Fine $1,220,592.50Disgorgement/RestitutionCease and Desist/Injunction

Consent


i


Initiated By: US VIRGIN ISLAND SECURITIES DIVISION





Docket/Case Number: CASE NO 01-09






Resolution:


Consent








Monetary/Fine $116,748.21Disgorgement/RestitutionCease and Desist/Injunction


i


Initiated By: OHIO SECURITIES DIVISION





Docket/Case Number: OH CONSENT ORDER






Resolution:




Consent


i







Initiated By: NEW MEXICO SECURITIES DIVISION





Docket/Case Number: 09-09-007-040






Resolution:




Consent


i


Initiated By: NEW JERSEY BUREAU OF SECURITIES


Docket/Case Number: NJ CONSENT ORDER















Resolution:




Consent


i


Initiated By: NEW HAMPSHIRE SECRETARY OF STATE, BUREAU OF SECURITIESREGULATION





Docket/Case Number: INV-2009000015






Resolution:


Consent










i


Initiated By: MARYLAND SECURITIES DIVISION











Resolution:




Consent


i







Initiated By: LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS, COMMISSIONER OFSECURITIES





Docket/Case Number: OFI-2010-001






Resolution:




Consent


i


Initiated By: IOWA INSURANCE DIVISION

















Resolution:




Consent


i


Initiated By: ILLINOIS SECRETARY OF STATE, SECURITIES DEPT










Resolution: Consent











i


Initiated By: HAWAII DEPT OF COMMERCE AND CONSUMER AFFAIRS





Docket/Case Number: SEU-2008-069






Resolution:




Consent

i73©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC







Initiated By: DISTRICT OF COLUMBIA DEPT OF INSURANCE, SECURITIES AND BANKING





Docket/Case Number: SB-09-02






Resolution:




Consent


i


Initiated By: ARKANSAS SECURITIES COMMISSIONER


Docket/Case Number: S-09-024-09-CO01















Resolution:


Sanction Details: THE FINE WAS PAID ON 03/21/2010


Consent


i


Initiated By: ALASKA DIVISION OF BANKING AND SECURITIES





Docket/Case Number: 10-07-S





Resolution: Consent











i


Initiated By: FINRA






Other Product Type(s): REPORTABLE SECURITIES

Allegations: FINRA RULE 6182, NASD RULE 6130(D) - WELLS FARGO SECURITIES, LLCFAILED TO REPORT TRANSACTIONS IN REPORTABLE SECURITIES TO THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) AS SHORT.



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 $20,000.FINE PAID IN FULL ON JULY 15, 2013.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. (FINRA)




CENSURE




Other Product Type(s): REPORTABLE SECURITIES

Allegations: FINRA RULE 6182 & NASD RULE 6130(D) - WELLS FARGO SECURITIES, LLCFAILED TO DESIGNATE AS 'SHORT' LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES TO THE FINRA/NASDAQTRADE REPORTING FACILITY (FNTRF).



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGOSECURITIES, LLC (WFS LLC) CONSENTED TO THE SANCTIONS AND ENTRYOF THE FINDINGS. WFS LLC WAS FINED $20,000 AND CENSURED.

Firm Statement THIS MATTER IS FINAL.




i








Initiated By: FINRA


Other


N/A




Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: FINRA RULE 6730(B): THE FIRM FAILED TO REPORT TO THE TRADEREPORTING AND COMPLIANCE ENGINE (TRACE) 176 S1 INTERDEALERTRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIREDTO REPORT. THESE TRANSACTIONS CONSTITUTED 3.4 PERCENT OF THES1 INTERDEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THATTHE FIRM WAS REQUIRED TO REPORT TO TRACE.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $19,500 AND UNDERTAKES TOREPORT TO TRACE THE TRANSACTIONS THAT WERE NOT PREVIOUSLYREPORTED. WITHOUT 30 BUSINESS DAYS OF ACCEPTANCE OF THE AWCBY THE NATIONAL ADJUDICATORY COUNCIL (NAC), A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN EMAIL FROM A WORK-RELATED ACCOUNT OF THEREGISTERED PRINCIPAL, PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THE MATTER; A REPRESENTATION THAT THE FIRM HASREPORTED THE PREVIOUSLY UNREPORTED TRANSACTIONS TO TRACE;AND THE DATE THE TRANSACTIONS WERE REPORTED TO TRACE. FINEPAID IN FULL ON 08/07/2012.


No









WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $19,500 AND UNDERTAKES TOREPORT TO TRACE THE TRANSACTIONS THAT WERE NOT PREVIOUSLYREPORTED. WITHOUT 30 BUSINESS DAYS OF ACCEPTANCE OF THE AWCBY THE NATIONAL ADJUDICATORY COUNCIL (NAC), A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN EMAIL FROM A WORK-RELATED ACCOUNT OF THEREGISTERED PRINCIPAL, PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THE MATTER; A REPRESENTATION THAT THE FIRM HASREPORTED THE PREVIOUSLY UNREPORTED TRANSACTIONS TO TRACE;AND THE DATE THE TRANSACTIONS WERE REPORTED TO TRACE. FINEPAID IN FULL ON 08/07/2012.


Initiated By: FINRA


Censure


$19,500.00 FINE, AND AN UNDERTAKING TO REPORT TO TRACE, THETRANSACTIONS THAT WERE NOT PREVIOUSLY REPORTED.


Docket/Case Number: AWC 20100248753-01

Principal Product Type: Debt - Government


Allegations: THE ALLEGATIONS RELATE TO THE TIMELINESS OF TRANSACTIONREPORTING DURING THE PERIOD OF APRIL 1 - JUNE 30, 2010.



Resolution:

Other Sanctions Ordered: AN UNDERTAKING TO REPORT TO TRACE, THE TRANSACTIONS THATWERE NOT PREVIOUSLY REPORTED.

Sanction Details: $19,500 FINE

Firm Statement THE MATTER IS FINAL AND THE FINE HAS BEEN PAID.




i


Allegations: SEC ADMIN RELEASES 33-9349, 34-67649, INVESTMENT COMPANY ACT OF1940 RELEASE 30167, AUGUST 14, 2012: THE SECURITIES AND EXCHANGECOMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OF THESECURITIES ACT OF 1933 ("SECURITIES ACT") AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT ("EXCHANGE ACT"), AGAINST WELLS FARGOBROKERAGE SERVICES, LLC N/K/A WELLS FARGO SECURITIES, LLC("WELLS FARGO"), AND THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OFTHE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT ANDSECTION 9(B) OF THE INVESTMENT COMPANY ACT OF 1940 ("INVESTMENTCOMPANY ACT") AGAINST A FORMER REGISTERED REPRESENTATIVE("RR").

THE COMMISSION FOUND THAT FROM AT LEAST JANUARY 1, 2007THROUGH AUGUST 14, 2007 ("RELEVANT TIME PERIOD"), WELLS FARGOAND CERTAIN OF ITS REGISTERED REPRESENTATIVES MADERECOMMENDATIONS TO CERTAIN INSTITUTIONAL CUSTOMERS TOPURCHASE ASSET-BACKED COMMERCIAL PAPER ISSUED BY LIMITEDPURPOSE COMPANIES CALLED STRUCTURED INVESTMENT VEHICLES("SIVS"), WHICH WERE COMPLEX INVESTMENT VEHICLES BACKEDLARGELY BY HIGH-RISK MORTGAGE-BACKED SECURITIES ("MBS") ANDCOLLATERAL DEBT OBLIGATIONS ("CDOS"). WELLS FARGO REGISTEREDREPRESENTATIVES IN WELLS FARGO'S INSTITUTIONAL BROKERAGE ANDSALES DIVISION, INCLUDING RR, RECOMMENDED AND SOLD THESEASSET-BACKED COMMERCIAL PAPER INVESTMENTS TO CERTAININSTITUTIONAL CUSTOMERS, INCLUDING MUNICIPALITIES AND NON-PROFIT INSTITUTIONS.

DURING THE RELEVANT TIME PERIOD, WELLS FARGO AND CERTAIN OF ITSREGISTERED REPRESENTATIVES RECOMMENDED AND SOLD COMPLEXFORMS OF SIV-ISSUED ASSET-BACKED COMMERCIAL PAPER TOINSTITUTIONAL CUSTOMERS WITHOUT OBTAINING SUFFICIENTINFORMATION AND UNDERSTANDING ABOUT THE NATURE AND RISK OFTHESE PRODUCTS. AMONG OTHER THINGS, WELLS FARGO AND ITSREGISTERED REPRESENTATIVES DID NOT REVIEW THE COMMERCIALPAPER PRIVATE PLACEMENT MEMORANDA ("PPMS") FOR THEINVESTMENTS AND THE EXTENSIVE RISK DISCLOSURES IN THOSEDOCUMENTS. INSTEAD, WELLS FARGO AND ITS REGISTEREDREPRESENTATIVES RELIED ALMOST EXCLUSIVELY ON THE CREDITRATINGS OF THESE PRODUCTS, DESPITE WARNINGS AGAINST SUCHOVER-RELIANCE ON RATINGS. WELLS FARGO ALSO FAILED TO ESTABLISHANY PROCEDURES TO ENSURE THAT ITS PERSONNEL ADEQUATELYREVIEWED AND UNDERSTOOD THE NATURE AND RISKS OF THESECOMMERCIAL PAPER PROGRAMS. AS A RESULT, WELLS FARGO AND ITSREGISTERED REPRESENTATIVES FAILED TO: (I) HAVE A REASONABLEBASIS FOR THEIR RECOMMENDATIONS; AND (II) IN CONNECTION WITHTHEIR RECOMMENDATIONS, DISCLOSE TO THEIR INSTITUTIONALCUSTOMERS THE RISKS ASSOCIATED WITH THE COMPLEX SIV-ISSUEDASSET-BACKED COMMERCIAL PAPER INVESTMENTS, INCLUDING THENATURE AND VOLATILITY OF THE UNDERLYING ASSETS. A NUMBER OFINSTITUTIONAL CUSTOMERS PURCHASED SIV-ISSUED ASSET-BACKEDCOMMERCIAL PAPER AS A RESULT OF WELLS FARGO'SRECOMMENDATIONS. IN PARTICULAR, RR EXERCISED DISCRETIONARYAUTHORITY IN VIOLATION OF WELLS FARGO'S INTERNAL POLICY ANDSELECTED THE PARTICULAR ISSUER OF ASSET-BACKED COMMERCIALPAPER FOR ONE LONG-STANDING MUNICIPAL CUSTOMER. ALTHOUGHWELLS FARGO RECEIVED A SMALL AMOUNT OF COMMISSIONS FROMTHESE TRANSACTIONS, WELLS FARGO'S MISCONDUCT NEVERTHELESSRESULTED IN, OR CREATED A SIGNIFICANT RISK OF, SUBSTANTIALLOSSES BY THESE CUSTOMERS IN 2007 WHEN THREE SIV-ISSUED ASSET-BACKED COMMERCIAL PAPER PROGRAMS, WHICH WERE BACKEDLARGELY BY MBS AND CDOS, DEFAULTED.

WELLS FARGO AND RR WERE, AT A MINIMUM, NEGLIGENT INRECOMMENDING THE RELEVANT ASSET-BACKED COMMERCIAL PAPERPROGRAMS WITHOUT OBTAINING ADEQUATE INFORMATION ABOUT THEMTO FORM A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTSAND WITHOUT DISCLOSING THE MATERIAL RISKS OF THESE PRODUCTS.AS A RESULT, WELLS FARGO AND RR WILLFULLY VIOLATED SECTIONS17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT.

(CONTINUED IN COMMENT)






www.finra.org/brokercheck User GuidanceSEC ADMIN RELEASES 33-9349, 34-67649, INVESTMENT COMPANY ACT OF1940 RELEASE 30167, AUGUST 14, 2012: THE SECURITIES AND EXCHANGECOMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OF THESECURITIES ACT OF 1933 ("SECURITIES ACT") AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT ("EXCHANGE ACT"), AGAINST WELLS FARGOBROKERAGE SERVICES, LLC N/K/A WELLS FARGO SECURITIES, LLC("WELLS FARGO"), AND THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OFTHE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT ANDSECTION 9(B) OF THE INVESTMENT COMPANY ACT OF 1940 ("INVESTMENTCOMPANY ACT") AGAINST A FORMER REGISTERED REPRESENTATIVE("RR").










Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION






Other Product Type(s): ASSET-BACK COMMERCIAL PAPER INVESTMENTS

SEC ADMIN RELEASES 33-9349, 34-67649, INVESTMENT COMPANY ACT OF1940 RELEASE 30167, AUGUST 14, 2012: THE SECURITIES AND EXCHANGECOMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OF THESECURITIES ACT OF 1933 ("SECURITIES ACT") AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT ("EXCHANGE ACT"), AGAINST WELLS FARGOBROKERAGE SERVICES, LLC N/K/A WELLS FARGO SECURITIES, LLC("WELLS FARGO"), AND THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED, PURSUANT TO SECTION 8A OFTHE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT ANDSECTION 9(B) OF THE INVESTMENT COMPANY ACT OF 1940 ("INVESTMENTCOMPANY ACT") AGAINST A FORMER REGISTERED REPRESENTATIVE("RR").






Resolution:


Yes

Order






Other Sanctions Ordered: PREJUDGEMENT INTEREST

Sanction Details: THE COMMISSION DEEMED IT APPROPRIATE AND IN THE PUBLICINTEREST TO IMPOSE THE SANCTIONS AGREED TO IN WELLS FARGO'SOFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIESACT, SECTION 15(B) OF THE EXCHANGE ACT AND SECTION 9(B) OF THEINVESTMENT COMPANY ACT, IT IS HEREBY ORDERED THAT WELLS FARGOSHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT. WELLS FARGO IS CENSURED. WELLSFARGO SHALL, WITHIN 10 DAYS OF THE ENTRY OF THE ORDER, PAYDISGORGEMENT OF $65,000, PREJUDGMENT INTEREST OF $16,571.96 ANDA CIVIL MONEY PENALTY IN THE AMOUNT OF $6,500,000 TO THESECURITIES AND EXCHANGE COMMISSION.

Regulator Statement (CONTINUED FROM #7)

SINCE 2007, WELLS FARGO HAS TAKEN A NUMBER OF REMEDIALMEASURES DESIGNED TO ENSURE THAT WELLS FARGO AND ITSREGISTERED REPRESENTATIVES HAVE ADEQUATE INFORMATION ABOUTTHE NATURE AND RISK OF THE SECURITIES THAT THEY RECOMMEND TOCUSTOMERS, AND THAT RELEVANT INFORMATION WILL BE DISCLOSED TOTHE CUSTOMERS REGARDING SUCH SECURITIES. THE STEPS INCLUDE:(1) A WELLS FARGO ASSET-BACKED COMMERCIAL PAPER PERMITTED LISTWHEREIN THE OFFERING DOCUMENTS FOR ASSET-BACKED COMMERCIALPAPER ARE REVIEWED BY MONEY MARKET TRADERS AND A LIMITEDNUMBER OF COMMERCIAL PAPER PRODUCTS ARE PERMITTED FOR SALETO INSTITUTIONAL CUSTOMERS; (2) ENHANCED SUPERVISORYPROCEDURES RELATED TO THE ASSESSMENT OF PRODUCT KNOWLEDGEBY REGISTERED REPRESENTATIVES IN THE RELEVANT DESIGNATEDSALES FORCE WHO SELL COMMERCIAL PAPER TO MUNICIPALITIES; (3)QUARTERLY MEETINGS ATTENDED BY THE HEADS OF EACH FIXEDINCOME TRADING DESK, THE NATIONAL SALES MANAGER ANDREPRESENTATIVES OF THE COMPLIANCE DEPARTMENT DURING WHICHPRODUCTS SOLD TO MUNICIPAL AND OTHER CUSTOMERS ANDDEVELOPMENTS IN THOSE PRODUCT TYPES ARE REVIEWED AS ARE THERELEVANT TRADING DESK REPORTS ON VARIATIONS OR MODIFICATIONSIN THE MARKET THAT PRESENTLY RAISE OR ARE EXPECTED TO RAISEMATERIALLY NEW OR DIFFERENT RISKS OR THAT EXHIBIT OTHERCHARACTERISTICS THAT MAY REQUIRE REASSESSMENT OF THE SALESFORCE'S UNDERSTANDING OF THE PRODUCT; AND (4) THE PRACTICE OFDELIVERING, OR PROVIDING ELECTRONIC ACCESS TO, COPIES OFOFFERING MATERIALS TO PURCHASERS OF ASSET-BACKED COMMERCIALPAPER.

IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, WELLSFARGO SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,WELLS FARGO CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, AND SECTION 9(B) OF THEINVESTMENT COMPANY ACT OF 1940, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").


Yes

Sanctions Ordered: CensureMonetary/Fine $6,500,000.00Disgorgement/RestitutionCease and Desist/Injunction






(CONTINUED FROM #7)

SINCE 2007, WELLS FARGO HAS TAKEN A NUMBER OF REMEDIALMEASURES DESIGNED TO ENSURE THAT WELLS FARGO AND ITSREGISTERED REPRESENTATIVES HAVE ADEQUATE INFORMATION ABOUTTHE NATURE AND RISK OF THE SECURITIES THAT THEY RECOMMEND TOCUSTOMERS, AND THAT RELEVANT INFORMATION WILL BE DISCLOSED TOTHE CUSTOMERS REGARDING SUCH SECURITIES. THE STEPS INCLUDE:(1) A WELLS FARGO ASSET-BACKED COMMERCIAL PAPER PERMITTED LISTWHEREIN THE OFFERING DOCUMENTS FOR ASSET-BACKED COMMERCIALPAPER ARE REVIEWED BY MONEY MARKET TRADERS AND A LIMITEDNUMBER OF COMMERCIAL PAPER PRODUCTS ARE PERMITTED FOR SALETO INSTITUTIONAL CUSTOMERS; (2) ENHANCED SUPERVISORYPROCEDURES RELATED TO THE ASSESSMENT OF PRODUCT KNOWLEDGEBY REGISTERED REPRESENTATIVES IN THE RELEVANT DESIGNATEDSALES FORCE WHO SELL COMMERCIAL PAPER TO MUNICIPALITIES; (3)QUARTERLY MEETINGS ATTENDED BY THE HEADS OF EACH FIXEDINCOME TRADING DESK, THE NATIONAL SALES MANAGER ANDREPRESENTATIVES OF THE COMPLIANCE DEPARTMENT DURING WHICHPRODUCTS SOLD TO MUNICIPAL AND OTHER CUSTOMERS ANDDEVELOPMENTS IN THOSE PRODUCT TYPES ARE REVIEWED AS ARE THERELEVANT TRADING DESK REPORTS ON VARIATIONS OR MODIFICATIONSIN THE MARKET THAT PRESENTLY RAISE OR ARE EXPECTED TO RAISEMATERIALLY NEW OR DIFFERENT RISKS OR THAT EXHIBIT OTHERCHARACTERISTICS THAT MAY REQUIRE REASSESSMENT OF THE SALESFORCE'S UNDERSTANDING OF THE PRODUCT; AND (4) THE PRACTICE OFDELIVERING, OR PROVIDING ELECTRONIC ACCESS TO, COPIES OFOFFERING MATERIALS TO PURCHASERS OF ASSET-BACKED COMMERCIALPAPER.

IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, WELLSFARGO SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,WELLS FARGO CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, AND SECTION 9(B) OF THEINVESTMENT COMPANY ACT OF 1940, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").






CEASE AND DESIST, CENSURE, DISGORGEMENT




Other Product Type(s): COMMERCIAL PAPER

Allegations: THE SEC ALLEGED THAT WELLS FARGO SECURITIES, LLC FAILED TODISCLOSE RISKS ASSOCIATED WITH ASSET BACKED COMMERCIAL PAPERIN CONNECTION WITH CUSTOMER RECOMMENDATIONS AND FAILED TOHAVE A REASONABLE BASIS FOR THESE RECOMMENDATIONS.








CEASE AND DESIST, CENSURE, DISGORGEMENT


Resolution:


Sanction Details: THE ORDER ENTERED IN THIS MATTER REQUIRED WELLS FARGOSECURITIES, LLC TO PAY A $6,500,000 CIVIL MONEY PENALTY,DISGORGEMENT OF $65,000 AND $15,571.96 IN PREJUDGMENT INTEREST.THOSE AMOUNTS WERE PAID ON AUGUST 17, 2012.

Firm Statement THE SEC ENTERED THE ORDER ON AUGUST 14, 2012 FINDING THAT WELLSFARGO SECURITIES, LLC AND CERTAIN REGISTERED REPRESENTATIVESRECOMMENDED THE PURCHASE OF ASSET BACKED COMMERCIAL PAPERTO CERTAIN INSTITUTIONAL CLIENTS WITHOUT A REASONABLE BASIS FORTHOSE RECOMMENDATIONS AND WITHOUT DISCLOSING THE RISKSASSOCIATED WITH THOSE INVESTMENTS. WELLS FARGO SECURITIES,LLC CONSENTED TO THE ORDER'S ENTRY AND THE SETTLEMENT TERMSCONTAINED THEREIN WITHOUT ADMITTING OR DENYING THOSEFINDINGS. THE CIVIL MONEY PENALTY, DISGORGEMENT, ANDPREJUDGMENT INTEREST TOTALLING $6,581,571.96 WERE PAID ASREQUIRED BY THE ORDER ON AUGUST 17, 2012.

Sanctions Ordered: CensureMonetary/Fine $6,500,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order


i


Initiated By: FINRA



Allegations: MSRB RULE G-14: WELLS FARGO SECURITIES LLC FAILED TO REPORTINFORMATION REGARDING PURCHASE AND SALE TRANSACTIONSEFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTIONREPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TOREPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTESOF TRADE TIME TO AN RTRS PORTAL.












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 $8,500 FOR VIOLATIONOF MSRB RULE G-14.


No




Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.




CENSURE


Docket/Case Number: AWC NO. 20100227588-01



Allegations: THE ALLEGATIONS CONCERN CERTAIN MUNICIPAL SECURITIES TRADEREPORTING ISSUES IN THE 1ST QUARTER OF 2010.








CENSURE


Resolution:


Sanction Details: CENSURE AND $8500 FINE FOR LATE REPORTING OF MUNICIPALSECURITIES TRANSACTIONS. THE FINE HAS BEEN PAID IN FULL ANDMAILED TO FINRA.

Firm Statement THIS MATTER IS FINAL AND THE FINE HAS BEEN PAID.




i


Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFFICE")


Cease and Desist


RESTITUTION; CIVIL AND ADMINISTRATIVE FINE


Docket/Case Number: 0420-S-2/09

URL for Regulatory Action:


Other Product Type(s): AUCTION RATE SECURITIES ("ARS")

Allegations: ON 4/16/2009, THE OFFICE, SUBSEQUENT TO COORDINATEDINVESTIGATIONS CONDUCTED BY A MULTISTATE TASK FORCECONSISTING OF MEMBER STATES OF THE NORTH AMERICAN SECURITIESADMINISTRATORS ASSOCIATION ("NASAA"), ENTERED INTO A CONSENTAGREEMENT REGARDING WACHOVIA'S ACTIVITIES IN THE MARKETINGAND SALE OF ARS PRIOR TO WIDESPREAD FAILED AUCTIONS BEGINNINGIN FEBRUARY 2008.



Resolution: Order






Other Sanctions Ordered: ON 4/17/2009, THE OFFICE ENTERED A FINAL ORDER ADOPTING THECONSENT AGREEMENT WHEREBY WACHOVIA SECURITIES AND WACHOVIACAPITAL MARKETS AGRRED TO THE FOLLOWING: 1.) AS AGENTS FOR ONEOR MORE AFFILIATED COMPANIES AND NOT AS PRINCIPAL, SHALL MAKEAN OFFER TO BUY "ELIGIBLE" ARS FROM INDIVIDUALS INVESTORS, 2.)WITH RESPECT TO ANY CLAIM FOR CONSEQUENTIAL DAMAGES, TO THEEXTENT SUCH CLAIMS ARE NOT RESOLVED INFORMALLY BY WACHOVIA,SHALL ARBITRATE THE CLAIM OF ANY RELEVANT CLASS MEMBER WHOELECTS TO ARBITRATE, AND; 3.) SHALL REFUND REFINANCING FEESRECEIVED BY IT TO MUNICIPAL ARS ISSUERS THAT ISSUED SUCHSECURITIES.

Sanction Details: THE ADMINISTRATIVE FINE AMOUNT OF $5,673,320.82 REPRESENTS THESTATE OF FLORIDA'S PRO RATA SHARE OF THE TOTAL PENALTY THATWACHOVIA AGREED TO PAY PURSUANT TO THE MULTI-STATESETTLEMENT. AS THE RESULT OF WACHOVIA'S RELIEF EFFORTS, TOTALRESTITUTION PROVIDED TO FLORIDA PURCHASERS OF ARS TOTALED$1,602,293,391.00.

Regulator Statement PER THE OFFICE'S FINAL ORDER DATED 4/17/2009 ADOPTING THECONSENT AGREEMENT, WACHOVIA CONSENTED TO THE ENTRY OF THEOFFICE'S FINDINGS OF FACTS AND CONCLUSIONS OF LAW INCLUDINGCONDUCT IN VIOLATION OF THE PROHIBITION AGAINST DISHONEST ANDUNETHICAL PRACTICES THAT DEMONSTRATE UNWORTHINESS TOTRANSACT THE BUSINESS OF A SECURITIES DEALER AND THATWACHOVIA FAILED TO SUPERVISE ITS EMPLOYEES.


No



Initiated By: STATE OF FLORIDAOFFICE OF FINANCIAL REGULATION

Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.







STATE OF FLORIDAOFFICE OF FINANCIAL REGULATION





Docket/Case Number: NO. 0420-S-2/09




Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON APRIL 28, 2009.


Consent


i


Allegations: SEC ADMIN RELEASES 33-9200 AND 34-64182, APRIL 5, 2011: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTION 15(B) OF THE SECURITIES EXCHANGEACT OF 1934 ("EXCHANGE ACT") AGAINST WELLS FARGO SECURITIES LLC(F/K/A WACHOVIA CAPITAL MARKETS LLC) ("RESPONDENT" OR "WELLSFARGO SECURITIES").

THE COMMISSION FOUND THAT:

WACHOVIA CAPITAL MARKETS ("WACHOVIA CAPITAL MARKETS") WAS AREGISTERED BROKER-DEALER AND WHOLLY-OWNED SUBSIDIARY OF ABANK HOLDING COMPANY DURING THE RELEVANT PERIOD. WACHOVIACAPITAL MARKETS CONDUCTED THE CORPORATE AND INVESTMENTBANKING BUSINESS OF THE BANKS HOLDING COMPANY'S SECURITIESBUSINESS. WACHOVIA CAPITAL MARKETS WAS RENAMED WELLS FARGOSECURITIES, LLC AFTER THE BANK HOLDING COMPANY MERGED WITHANOTHER BANK HOLDING COMPANY ON DECEMBER 31, 2008.

THE PROCEEDINGS CONCERN TWO COLLATERALIZED DEBT OBLIGATIONS("CDOS") TIED TO THE PERFORMANCE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES ("RMBS"). WACHOVIA CAPITAL MARKETS LLCSTRUCTURED AND MARKETED THESE TWO RMBS CDOS IN LATE 2006 ANDEARLY 2007 WHEN THE UNITED STATES HOUSING MARKET WASBEGINNING TO SHOW SIGNS OF DISTRESS.

IN SO DOING, WACHOVIA CAPITAL MARKETS VIOLATED THE ANTIFRAUDPROVISIONS OF THE SECURITIES ACT IN TWO RESPECTS. FIRST,WACHOVIA CAPITAL MARKETS CHARGED UNDISCLOSED EXCESSIVEMARKUPS IN THE SALE OF CERTAIN OF THE PREFERRED SHARES, OREQUITY, OF THE FIRST RMBS CDO TO AN INDIAN TRIBE AND AN INDIVIDUALINVESTOR. SECOND, WACHOVIA CAPITAL MARKETS REPRESENTED TOINVESTORS IN THE SECOND RMBS CDO THAT IT ACQUIRED ASSETS FROMAFFILIATES "ON AN ARM'S-LENGTH BASIS" AND "AT FAIR MARKET PRICES"WHEN IN FACT CERTAIN ASSETS WERE TRANSFERRED FROM ANAFFILIATE AT ABOVE-MARKET PRICES.

WACHOVIA CAPITAL MARKETS CHARGED UNDISCLOSED EXCESSIVEMARKUPS IN THE SALE OF THE FIRST RMBS CDO PREFERRED SHARES TOAN AFFILIATED BROKER-DEALER FOR SUBSEQUENT SALE TO THE INDIANTRIBE AND AN INDIVIDUAL INVESTOR. THESE INVESTORS PAID 90 AND 95.UNBEKNOWNST TO THE INVESTORS OR THE AFFILIATED BROKER-DEALER, THIS REPRESENTED A MARKUP OF OVER 70 PERCENT ABOVEWACHOVIA CAPITAL MARKETS' INTERNAL MARK ON THE FIRST RMBS CDOPREFERRED SHARES, WHICH WAS 52.7. IN SO DOING, WACHOVIA CAPITALMARKETS VIOLATED SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACTUNDER THE SHINGLE THEORY BECAUSE IT KNEW OR SHOULD HAVEKNOWN THAT THE PRICES IT CHARGED WERE EXCESSIVE.

WACHOVIA CAPITAL MARKETS REPRESENTED TO INVESTORS IN THESECOND RMBS CDO THAT IT ACQUIRED ASSETS FROM AN AFFILIATEDCOMPANY "ON AN ARM'S-LENGTH BASIS" AND "AT FAIR MARKET PRICES."THOSE REPRESENTATIONS WERE FALSE AND MISLEADING BECAUSEAPPROXIMATELY $250 MILLION WORTH OF RMBS WERE TRANSFERREDFROM AN AFFILIATE AT PRICES APPROXIMATELY $4.6 MILLION ABOVE THEMARKET VALUE AT THE TIME OF THE TRANSFER INTO THE SECOND RMBSCDO WAREHOUSE. THE PERSONNEL AT THE AFFILIATED COMPANYRESPONSIBLE FOR MANAGING COLLATERAL FOR RMBS CDOS BELIEVEDIT WOULD HAVE AFFECTED AN INVESTOR'S NEGOTIATION OF THEIRPURCHASE PRICE OF THE CDO IF THEY HAD KNOWN THAT CERTAINASSETS WERE BEING TRANSFERRED INTO THE SECOND RMBS CDOWAREHOUSE AT ACQUISITION COST RATHER THAN CURRENT MARKETPRICE. WACHOVIA CAPITAL MARKETS ACTED NEGLIGENTLY IN AT LEASTTWO RESPECTS. FIRST, WACHOVIA CAPITAL MARKETS ATTEMPTED,ALBEIT UNSUCCESSFULLY, TO DISCLOSE THE ISSUE BY PROVIDINGPROSPECTIVE INVESTORS SPREADSHEETS WITH CERTAIN PRICING DATA.SECOND, THE STANDARD AFFILIATE TRANSACTION DISCLOSURES IN THEOFFERING CIRCULAR WERE NOT MODIFIED TO ADDRESS THESECIRCUMSTANCES. IN BOTH INSTANCES, WACHOVIA CAPITAL MARKETSEXERCISED INADEQUATE CARE IN MAKING THE PRICING DISCLOSURES.

WACHOVIA CAPITAL MARKETS WILLFULLY VIOLATED SECTIONS 17(A)(2)AND (3) OF THE SECURITIES ACT, WHICH PROHIBIT FRAUDULENTCONDUCT IN THE OFFER AND SALE OF SECURITIES.







SEC ADMIN RELEASES 33-9200 AND 34-64182, APRIL 5, 2011: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTION 15(B) OF THE SECURITIES EXCHANGEACT OF 1934 ("EXCHANGE ACT") AGAINST WELLS FARGO SECURITIES LLC(F/K/A WACHOVIA CAPITAL MARKETS LLC) ("RESPONDENT" OR "WELLSFARGO SECURITIES").















Cease and Desist





Other Product Type(s): COLLATERALIZED DEBT OBLIGATION

SEC ADMIN RELEASES 33-9200 AND 34-64182, APRIL 5, 2011: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTION 15(B) OF THE SECURITIES EXCHANGEACT OF 1934 ("EXCHANGE ACT") AGAINST WELLS FARGO SECURITIES LLC(F/K/A WACHOVIA CAPITAL MARKETS LLC) ("RESPONDENT" OR "WELLSFARGO SECURITIES").









Resolution:


Sanction Details: IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS,RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICHTHE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").



THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTERESTTO IMPOSE THE SANCTIONS AGREED TO IN THE OFFER OF WELLS FARGOSECURITIES.

PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B)OF THE EXCHANGE ACT, THE COMMISSION ORDERED THAT:

A. RESPONDENT WELLS FARGO SECURITIES CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.

B. RESPONDENT WELLS FARGO SECURITIES SHALL, WITHIN 10 DAYS OFTHE ENTRY OF THE ORDER, PAY DISGORGEMENT OF $6.75 MILLION AND ACIVIL MONEY PENALTY IN THE AMOUNT OF $4.45 MILLION.


Yes


Order






IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS,RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICHTHE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").



THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTERESTTO IMPOSE THE SANCTIONS AGREED TO IN THE OFFER OF WELLS FARGOSECURITIES.

PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B)OF THE EXCHANGE ACT, THE COMMISSION ORDERED THAT:

A. RESPONDENT WELLS FARGO SECURITIES CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.

B. RESPONDENT WELLS FARGO SECURITIES SHALL, WITHIN 10 DAYS OFTHE ENTRY OF THE ORDER, PAY DISGORGEMENT OF $6.75 MILLION AND ACIVIL MONEY PENALTY IN THE AMOUNT OF $4.45 MILLION.


Allegations: THE ALLEGATIONS WERE THAT WACHOVIA CAPITAL MARKETS, (NKAWELLS FARGO SECURITIES, LLC) VIOLATED THE ANTIFRAUD PROVISIONSOF THE SECURITIES ACT IN TWO RESPECTS. FIRST WCM CHARGEDUNDISCLOSED EXCESSIVE MARKUPS IN THE SALE OF CERTAIN OF THEPREFERRED SHARES, OR EQUITY OF GRAND AVENUE II TO THE ZUNIINDIAN TRIBE AND AN INDIVIDUAL INVESTOR. SECOND, WCMREPRESENTED TO INVESTORS IN LONGSHORE III THAT IT ACQUIREDASSETS FROM AFFILIATES "ON AN ARMS LENGTH BASIS" AND "AT FAIRMARKET PRICES" WHEN IN FACT CERTAIN ASSETS WERE TRANSFERREDFROM AN AFFILIATE AT ABOVE-MARKET PRICES.







Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION


Cease and Desist


DISGORGEMENT OF $6.75 MILLIONCIVIL MONEY PENALTY OF $4.45 MILLION


Docket/Case Number: FILE NO. 3-14320


Other Product Type(s): RMBS CDOS

THE ALLEGATIONS WERE THAT WACHOVIA CAPITAL MARKETS, (NKAWELLS FARGO SECURITIES, LLC) VIOLATED THE ANTIFRAUD PROVISIONSOF THE SECURITIES ACT IN TWO RESPECTS. FIRST WCM CHARGEDUNDISCLOSED EXCESSIVE MARKUPS IN THE SALE OF CERTAIN OF THEPREFERRED SHARES, OR EQUITY OF GRAND AVENUE II TO THE ZUNIINDIAN TRIBE AND AN INDIVIDUAL INVESTOR. SECOND, WCMREPRESENTED TO INVESTORS IN LONGSHORE III THAT IT ACQUIREDASSETS FROM AFFILIATES "ON AN ARMS LENGTH BASIS" AND "AT FAIRMARKET PRICES" WHEN IN FACT CERTAIN ASSETS WERE TRANSFERREDFROM AN AFFILIATE AT ABOVE-MARKET PRICES.


Resolution:


Sanction Details: WELLS FARGO SECURITIES SHALL PAY DISGORGEMENT OF $6.75 MILLIONAND A CIVIL MONEY PENALTY OF $4.45 MILLION.

Firm Statement THE ALLEGATIONS WERE THAT WACHOVIA CAPITAL MARKETS, (NKAWELLS FARGO SECURITIES, LLC) VIOLATED THE ANTIFRAUD PROVISIONSOF THE SECURITIES ACT IN TWO RESPECTS. FIRST WCM CHARGEDUNDISCLOSED EXCESSIVE MARKUPS IN THE SALE OF CERTAIN OF THEPREFERRED SHARES, OR EQUITY OF GRAND AVENUE II TO THE ZUNIINDIAN TRIBE AND AN INDIVIDUAL INVESTOR. SECOND, WCMREPRESENTED TO INVESTORS IN LONGSHORE III THAT IT ACQUIREDASSETS FROM AFFILIATES "ON AN ARMS LENGTH BASIS" AND "AT FAIRMARKET PRICES" WHEN IN FACT CERTAIN ASSETS WERE TRANSFERREDFROM AN AFFILIATE AT ABOVE-MARKET PRICES.

WITHOUT ADMITTING OR DENYING ANY WRONGDOING, WELLS FARGOSECURITIES, LLC AGREED TO SETTLE THE SEC'S CHARGES BY PAYING$11.2 MILLION IN DISGORGEMENT AND PENALTIES.


Settled


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Initiated By: CONNECTICUT





Docket/Case Number: CO-10-7568-S




Allegations: ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTEREDA CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/AWELLS FARGO ADVISORS, LLC) AND WACHOVIA CAPITAL MARKETS, LLC(N/K/A WELLS FARGO SECURITIES, LLC). THE CONSENT ORDERFOLLOWED AN INVESTIGATION BY A MULTISTATE TASK FORCE INTO THEMARKETING AND SALE OF AUCTION RATE SECURITIES (ARS) BY THEFIRMS FROM JANUARY 1, 2006 THROUGH FEBRUARY 14, 2008. THECONSENT ORDER ALLEGED THAT, IN CONJUNCTION WITH THEMARKETING OF ARS, THE FIRMS FAILED TO SUPERVISE THEIREMPLOYEES, AND THAT THE FIRM ENGAGED IN DISHONEST ORUNETHICAL PRACTICES IN THE SECURITIES BUSINESS BYMISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TOCUSTOMERS.



Resolution:

Other Sanctions Ordered: THE CONSENT ORDER FINED WACHOVIA SECURITIES, LLC N/K/A WELLSFARGO ADVISORS, LLC AND WACHOVIA CAPITAL MARKETS, LLC N/K/AWELLS FARGO SECURITIES, LLC $863,341.30, AND DIRECTED THEM TOCEASE AND DESIST FROM REGULATORY VIOLATIONS.


Yes

Sanctions Ordered: Monetary/Fine $863,341.30Cease and Desist/Injunction

Consent






Sanction Details: SEE RESPONSE TO ITEM 13.B.


Initiated By: STATE OF CONNECTICUT-DEPARTMENT OF BANKING, SECURITIES ANDBUSINESS INVESTMENTS DIVISION





Docket/Case Number: DOCKET NO. CO-10-7568-S



Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLC (N.K.A.WELLS FARGO SECURITIES, LLC), MISREPRESENTED THE SALE OFAUCTION RATE SECURITIES TO CUSTOMERS.



Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: WELLS FARGO SECURITIES PAID THE $863,341.30 FINE TO THE STATE OFCONNECTICUT ON JULY 20, 2010 AND ALSO AGREED TO REPURCHASECERTAIN AUCTION RATE SECURITIES.


Consent


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Allegations: FINRA RULES 2010, 6380A(A), MSRB RULES G-14, G-27 - WELLS FARGOSECURITIES, LLC FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TOTRANSMIT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (TRF)LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIESAND FAILED TO DESIGNATE THROUGH THE TRF SOME OF THE LAST SALEREPORTS AS LATE. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF FINRA RULE 6380A(A) AND A PATTERN ORPRACTICE OF LATE REPORTING WITHOUT EXCEPTIONALCIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY MSRB RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL;THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRMFAILED TO REPORT THE CORRECT TRADE DATE TO THE RTRS FOR A FEWREPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES REPORTING.







Initiated By: FINRA






Other Product Type(s): DESIGNATED SECURITIES

FINRA RULES 2010, 6380A(A), MSRB RULES G-14, G-27 - WELLS FARGOSECURITIES, LLC FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TOTRANSMIT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (TRF)LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIESAND FAILED TO DESIGNATE THROUGH THE TRF SOME OF THE LAST SALEREPORTS AS LATE. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF FINRA RULE 6380A(A) AND A PATTERN ORPRACTICE OF LATE REPORTING WITHOUT EXCEPTIONALCIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY MSRB RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL;THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRMFAILED TO REPORT THE CORRECT TRADE DATE TO THE RTRS FOR A FEWREPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES REPORTING.


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 $20,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGMUNICIPAL SECURITIES REPORTING WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.


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, FINED $20,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGMUNICIPAL SECURITIES REPORTING WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.




CENSURE AND UNDERTAKING


Docket/Case Number: AWC NO. 20090184340-01


Other Product Type(s): EQUITY LISTED (COMMON & PREFERRED STOCK)

Allegations: FINRA RULES 2010, 6380A(A), MSRB RULES G-14, G-27 - WELLS FARGOSECURITIES, LLC FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TOTRANSMIT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (TRF)LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIESAND FAILED TO DESIGNATE THROUGH THE TRF SOME OF THE LAST SALEREPORTS AS LATE. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF FINRA RULE 6380A(A) AND A PATTERN ORPRACTICE OF LATE REPORTING WITHOUT EXCEPTIONALCIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY MSRB RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL;THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRMFAILED TO REPORT THE CORRECT TRADE DATE TO THE RTRS FOR A FEWREPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES REPORTING.








Resolution:

Other Sanctions Ordered: AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES CONCERNING MUNICIPAL SECURITIES TRADE REPORTING.

Sanction Details: THE FINE WAS COMPRISED OF $7500 RELATING TO THE TIMELINESS OFEQUITIES TRADE REPORTING, $7500 RELATING TO THE TIMELINESS OFMUNICIPAL TRADE REPORTING, AND $5000 RELATING TO THE FIRM'SWSPS CONCERNING MUNCIPAL TRADE REPORTING.

Firm Statement THE MATTER IS FINAL, THE FINE HAS BEEN PAID, AND ADDITIONALMUNICIPAL SECURITIES TRADE REPORTING PROCEDURES HAVE BEENADOPTED.




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Initiated By: FINRA


Other


N/A





Allegations: NASD RULE 6230: THE FIRM FAILED TO REPORT TO TRACE THE CORRECTCONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS, AND DOUBLEREPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES.THESE TRANSACTIONS CONSTITUTED 5.4 PERCENT OF THE INTER-DEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT THE FIRMREPORTED TO TRACE DURING THE REVIEW PERIOD.



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 $7,500.



Initiated By: FINRA


Other


N/A





Allegations: NASD RULE 6230: WELLS FARGO SECURITIES, LLC FAILED TO REPORT TOTRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS,AND DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLESECURITIES. THESE TRANSACTIONS CONSTITUTED 5.4 PERCENT OF THEINTER-DEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT THEFIRM REPORTED TO TRACE DURING THE REVIEW PERIOD.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGOSECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS. WELLS FARGO SECURITIES, LLC WASCENSURED AND FINED $7500.




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Initiated By: UTAH DIVISION OF SECURITIES


Cease and Desist


ADMINISTRATIVE FINE AND BUY BACK OF AUCTION RATE SECURITIESTHAT IT SOLD TO ELIGIBLE UTAH INVESTORS.


Docket/Case Number: SD-09-0044




Allegations: THE UTAH DIVISION OF SECURITIES, AS PART OF A MULTI-STATE TASKFORCE CONSISTING OF MEMBER STATES OF THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATINGTHE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TOINVESTORS, ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLC("WACHOVIA"): (1) ENGAGED IN DISHONEST AND UNETHICAL PRACTICESIN THE MARKETING AND SALE OF ARS BY MISREPRESENTING TOINVESTORS THAT ARS WERE CASH EQUIVALENTS, COMPLETELY SAFE,AND/OR LIQUID AT ANY TIME; (2) ENGAGED IN DISHONEST AND UNETHICALPRACTICES BY NOT ADEQUATELY EXPLAINING ISSUES INVOLVINGTEMPORARY MAXIMUM WAIVERS ON CERTAIN ARS; AND (3) FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WHO SOLD ARS.



Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ALL INVESTORS IN THERELEVANT CLASS AS OUTLINED IN THE DIVISION'S STIPULATION ANDCONSENT ORDER.


Yes


Stipulation and Consent






OFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ALL INVESTORS IN THERELEVANT CLASS AS OUTLINED IN THE DIVISION'S STIPULATION ANDCONSENT ORDER.

Sanction Details: PURSUANT TO A STIPULATION AND CONSENT ORDER WITH THE UTAHDIVISION OF SECURITIES, WACHOVIA CAPITAL MARKETS, LLC("WACHOVIA") WILL: (1) CEASE AND DESIST FROM VIOLATING THE UTAHUNIFORM SECURITIES ACT ("ACT") AND WILL HEREAFTER COMPLY WITHTHE ACT WITH REGARD TO THE MARKETING AND SALE OF ARS TO UTAHINVESTORS; (2) PAY THE SUM OF $247,272.91 AS AN ADMINISTRATIVE FINETO THE DIVISION; AND (3) OFFER TO PURCHASE, AT PAR PLUS ACCRUEDAND UNPAID DIVIDENDS/INTEREST, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS FROM ALL INVESTORS WHO PURCHASED ARS FROMWACHOVIA ON OR BEFORE 13 FEBRUARY 2008 INTO ACCOUNTSMAINTAINED AT WACHOVIA.

Regulator Statement A PDF COPY OF THE DIVISION'S STIPULATION AND CONSENT ORDER CANBE VIEWED ONLINE ATHTTP://SECURITIES.UTAH.GOV/DOCKETS/09004301.PDF


Initiated By: UTAH DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES








Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLC(N.K.A.WELLS FARGO SECURITIES, LLC) MISREPRESENTED THE SALE OFAUCTION RATE SECURITIES TO CUSTOMERS.



Resolution:










Sanction Details: THE FINE WAS RECEIVED BY THE STATE OF UTAH ON SEPTEMBER 29,2009.


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Initiated By: PENNSYLVANIA CONTACT: COUNSEL CAROLYN MENDELSON (412)-565-5083




RESPONDENT IS REQUIRED TO OFFER AND TO COMPLETE A BUYBACK OFAUCTION RATE SECURITIES THAT IT SOLD TO ELIGIBLE PA INVESTORS.


Docket/Case Number: 2008-04-16




Allegations: IF THE FACTS ARE AS FOUND IN THE FINDINGS OF FACT IN THE MISSOURIORDER, THEN THE ACTS AND CONDUCT SET FORTH IN THE MISSOURIORDER, IN PARTICULAR THE AUCTION RATE SECURITIES SALES IN PA,WOULD CONSTITUTE DISHONEST OR UNETHICAL PRACTICES IN THESECURITIES BUSINESS BY RESPONDENT, AND WOULD CONSTITUTEFAILURE TO REASONABLY SUPERVISE AGENTS OR EMPLOYEES.



Resolution:



Yes

Sanctions Ordered: Monetary/Fine $2,527,771.09

Settled






Sanction Details: RESPONDENT SHALL PAY WITHIN TEN DAYS AFTER THE ENTRY OF THISORDER $2,527,771.09 TO THE COMMONWEALTH OF PA, WHICH AMOUNTREPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUEDWACHOVIA CAPITAL MARKETS, LLC, AND OTHER NAMED RESPONDENT.


Initiated By: PENNSYLVANIA SECURITIES COMMISSION


Cease and Desist


CIVIL PENALTY AND RECISSION


Docket/Case Number: DOCKET NO. 2008-04-16



Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS AND FAILED TO SUPERVISE AGENTS SELLING SECURITIES.



Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECT TOAUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON AUGUST 19, 2009.

Sanctions Ordered: Monetary/Fine $2,527,771.09Cease and Desist/Injunction

Settled


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Allegations: NASD RULES 2110 AND 6230(A): RESPONDENT WACHOVIA CAPITALMARKETS, LLC FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFNASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110.







Initiated By: FINRA





Principal Product Type: Debt - Corporate


Allegations: NASD RULES 2110 AND 6230(A): RESPONDENT WACHOVIA CAPITALMARKETS, LLC FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFNASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110.


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 $7,500.


No




Allegations: NASD RULES 2110 AND 6230(A): RESPONDENT WACHOVIA CAPITALMARKETS,LLC FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFNASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110.







Initiated By: FINRA


Censure


$7,500 FINE





NASD RULES 2110 AND 6230(A): RESPONDENT WACHOVIA CAPITALMARKETS,LLC FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFNASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110.


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 $7,500.00.




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Initiated By: STATE OF MICHIGANOFFICE OF FINANCIAL AND INSURANCE REGULATION




Docket/Case Number: N/A














Resolution:




Consent


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Initiated By: SECURITIES COMMISSIONER OF SOUTH CAROLINA





Docket/Case Number: FILE NO. 08018



Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETSMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.



Resolution:


Consent







Sanction Details: THE FINE WAS PAID APRIL 23, 2009.



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Initiated By: STATE OF MAINEOFFICE OF SECURITIES


Other


AUCTION RATE SECURITIES


Docket/Case Number: CONSENT ORDER 09-054






Resolution:




Consent


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Initiated By: STATE OF MISSOURIOFFICE OF SECRETARY OF STATE





Docket/Case Number: AP-08-28






Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS IN THE RELEVANT CLASS.

Sanction Details: IN ADDITION TO THE FINE PAID ON 12/16/2008 IN THE AMOUNT OF$2,841,550.88, WACHOVIA PAID $265,000 AS COST FOR THEINVESTIGATION. $15,000 WAS PAID TO NASAA.


Consent


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Initiated By: ARIZONA CORPORATION COMMISSIONSECURITIES DIVISION

















Resolution:




Consent


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Initiated By: MISSISSIPPI SECRETARY OF STATEREGULATION AND ENFORCEMENT








Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS,LLCMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.









Resolution:


Sanction Details: THE FINE WAS PAID ON MARCH 6, 2009.


Consent


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Initiated By: PUERTO RICOOFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS











Resolution:



Consent









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Initiated By: STATE OF CALIFORNIADEPARTMENT OF CORPORATIONS











Resolution:




Consent


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Initiated By: TEXAS STATE SECURITIES BOARD










Resolution:




Consent


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Initiated By: STATE OF VERMONT


















Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.



Consent


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Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT











Resolution:


Consent






Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.




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Initiated By: DELAWARE DEPARTMENT OF JUSTICE


Cease and Desist



Docket/Case Number: CONSENT ORDER 09-2-2






Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: FINE WAS PAID ON 04/09/2009.


Consent


i







Initiated By: COLORADO DEPARTMENT OF REGULATORY AGENCIES





Docket/Case Number: ORDER NO. 09-6-11






Resolution:




Consent


i


Initiated By: STATE OF RHODE ISLAND
















Resolution:

Other Sanctions Ordered: OFFER TO PURCASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON MAY 11, 2009.


Consent


i


Initiated By: DEPARTMENT OF FINANCE OF THE STATE OF IDAHO











Resolution:


Consent







Sanction Details: THE FINE WAS PAID ON JUNE 29, 2009.



i


Initiated By: INDIANA SECRETARY OF STATESECURITIES DIVISION





Docket/Case Number: CAUSE NO. 09-0082 CO






Resolution:


Sanction Details: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.

Firm Statement THE FINE WAS PAID ON MAY 12, 2009.


Consent







i


Initiated By: COMMONWEALTH OF KENTUCKY





Docket/Case Number: ACTION NO. 2009-AH-032






Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.



Consent


i


Allegations: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY







Initiated By: ALABAMA SECURITIES COMMISSION


Other


CONSENT ORDER


Docket/Case Number: CO-2009-0011




THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY


Resolution:

Other Sanctions Ordered: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION.RECEIVED 06/10/2009

Sanction Details: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION.RECEIVED 06/10/2009

Regulator Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY


No


Consent







Initiated By: STATE OF ALABAMAALABAMA SECURITIES COMMISSION





Docket/Case Number: NO. CO-2009-






Resolution:


Sanction Details: THE $683,141.24 FINE PAID ON JUNE 4, 2009, INCLUDED THE FOLLOWING:$350,000 PAID TO THE ALABAMA DISTRICT ATTORNEYS ASSOCIATION$250,000 PAID TO THE STATE OF ALABAMA SECURITIES COMMISSION$73,141.24 PAID TO THE INVESTOR PROTECTION FUND$10,000 PAID TO NASAA

Firm Statement THE $683,141.24 FINE PAID ON JUNE 4, 2009, INCLUDED THE FOLLOWING:$350,000 PAID TO THE ALABAMA DISTRICT ATTORNEYS ASSOCIATION$250,000 PAID TO THE STATE OF ALABAMA SECURITIES COMMISSION$73,141.24 PAID TO THE INVESTOR PROTECTION FUND$10,000 PAID TO NASAA


Consent


i








Initiated By: STATE OF OREGONDEPARTMENT OF BUSINESS AND CONSUMER SERVICES




CEASE AND DESIST


Docket/Case Number: CASE NO. 09-0022






Resolution:


Sanction Details: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.

Firm Statement THE FINE WAS PAID ON JULY 3, 2009.


Consent


i


Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE








Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE









Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTIONS IN THE RELEVANT CLASS.



Consent


i


Initiated By: TENNESSEE SECURITIES DIVISION





Docket/Case Number: ORDER NO. 09-003 (SI-2008-010)











Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION (ELIGIBLE "ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.



Consent


i


Initiated By: KANSAS OFFICE OF THE SECURITIES COMMISSIONER





Docket/Case Number: DOCKET NO. 09 E012, KSC NO. 2009-5598






Resolution:


Sanction Details: OFFER TO PURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION (ELIGIBLE "ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.


Consent






Sanction Details: OFFER TO PURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION (ELIGIBLE "ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Firm Statement THE FINE WAS PAID ON JUNE 16, 2009.


i


Initiated By: MINNESOTA DEPARTMENT OF COMMERCE





Docket/Case Number: CONSENT ORDER (FILE 11200)






Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.



Consent


i








Initiated By: STATE OF WYOMING SECRETARY OF STATE SECURITIES DIVISION





Docket/Case Number: ADMINISTRATIVE CONSENT ORDER 09-05





Resolution:


Sanction Details: FINE WAS PAID ON 6/29/2009


Consent


i


Initiated By: OKLAHOMA DEPARTMENT OF SECURITIES





Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS AND FAILED TO SUPERVISE AGENTS SELLING SECURITIES








Cease and Desist


CIVIL PENALTY AND RESCISSION




Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECTTO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS

Sanction Details: CIVIL PENALTY HAS BEEN PAID


No


Consent




Cease and Desist







Allegations: THE STATE ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS AND FAILED TO SUPERVISE AGENTS SELLING SECURITIES.










Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECTTO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS.



Consent


i


Initiated By: FINRA







Allegations: NASD RULE 6955(A) - WACHOVIA CAPITAL MARKETS, LLC TRANSMITTED TOTHE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS AND THE FIRM FAILED TO REPAIR MOST OF THE REJECTEDROES.



Resolution:


No










No



Initiated By: FINRA


Censure


$7500.00 FINE





Allegations: NASD RULE 6955(A) - WACHOVIA CAPITAL MARKETS, LLC TRANSMITTED TOTHE ORDER AUDIT TRAIL SYSTEM(OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS AND THE FIRM FAILED TO REPAIR MOST OF THE REJECTEDROES.



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 $7,500.










i


Initiated By: WASHINGTON


Cease and Desist







Allegations: ON MARCH 24, 2009, THE SECURITIES DIVISION ENTERED INTO ACONSENT ORDER WITH WACHOVIA SECURITIES, LLC AND WACHOVIACAPITAL MARKETS, LLC (COLLECTIVELY "RESPONDENTS"), IN ORDER TOSETTLE THE ALLEGATIONS THAT RESPONDENTS HAD ENGAGED INDISHONEST AND UNETHICAL CONDUCT IN THE MARKETING AND SALE OFAUCTION RATE SECURITIES ("ARS"), AND FAILED TO REASONABLYSUPERVISE THEIR SALESPERSONS IN THE SALE OF ARS. RESPONDENTSNEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TOCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON. RESPONDENTS AGREED TO OFFER TO PURCHASE AT PARARS THAT ARE SUBJECT TO UNSUCCESSFUL AUCTIONS AND THAT ARENOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS, FROM INVESTORSWHO PURCHASED ARS FROM RESPONDENTS ON OR BEFORE FEBRUARY13, 2008, INTO ACCOUNTS MAINTAINED WITH RESPONDENTS.RESPONDENTS AGREED TO PAY $491,556.71 AS A CIVIL MONETARYPENALTY. RESPONDENTS EACH WAIVED THEIR RIGHT TO A HEARING ANDTO JUDICIAL REVIEW OF THIS MATTER.



Resolution:


Yes

Consent







Sanction Details: THIS ORDER CONCLUDES THE INVESTIGATION BY THE SECURITIESDIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIALINSTITUTIONS AND ANY OTHER ACTION THAT THE SECURITIES DIVISIONOF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONSCOULD COMMENCE UNDER APPLICABLE WASHINGTON STATE LAW ONBEHALF OF THE STATE OF WASHINGTON AS IT RELATES TO WACHOVIA,AND ITS MARKETING AND SALE OF AUCTION RATE SECURITIES TOINVESTORS.2. THIS ORDER IS ENTERED INTO SOLELY FOR THE PURPOSE OFRESOLVING THE REFERENCED MULTI-STATE INVESTIGATION, AND IS NOTINTENDED TO BE USED FOR ANY OTHER PURPOSE. 3. WACHOVIA SHALLCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OFWASHINGTON.4. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALLPAY THE SUM OF $491,556.71 TO THE STATE OF WASHINGTON AS A CIVILMONETARY PENALTY PURSUANT TO RCW 21.20.110, TO BE DEPOSITED INTHE SECURITIES PROSECUTION FUND, PURSUANT TO RCW 21.20.395,WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'SPROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF 50MILLION DOLLARS ($50,000,000.00). 5. IN THE EVENT ANOTHER STATESECURITIES REGULATOR DETERMINES NOT TO ACCEPT WACHOVIA'SSTATE SETTLEMENT OFFER, THE TOTAL AMOUNT OF THE STATE OFWASHINGTON'S PAYMENT SHALL NOT BE AFFECTED, AND SHALL REMAINAT $491,556.71. 6. WACHOVIA SECURITIES AND WACHOVIA CAPITALMARKETS, RESPECTIVELY, AS AGENTS FOR ONE OR MORE AFFILIATEDCOMPANIES AND NOT AS PRINCIPAL, SHALL OFFER TO PURCHASE AT PARARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL ANDARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS ("ELIGIBLEARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. FOR PURPOSES OFTHIS ORDER THE RELEVANT CLASS SHALL BE DEFINED AS ALL INVESTORSWHO PURCHASED ARS FROM EITHER WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY, ON OR BEFORE FEBRUARY13, 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY.

Regulator Statement CONTACT: BRIDGETT FISHER 360-902-8732


Yes







Regulator Statement CONTACT: BRIDGETT FISHER 360-902-8732


Initiated By: SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OFFINANCIAL INSTITUTIONS.


Cease and Desist









Resolution:


Sanction Details: OFFER TO REPURCHASE AT PAR, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS IN THE RELEVANT CLASS.


Consent


i


Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATESECURITIES DIVISION








Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATESECURITIES DIVISION





Docket/Case Number: 09SEC029




Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: PAYMENT OF FINE WAS DUE BY 03/06/2009.


Consent


i


Initiated By: MONTANA SECURITIES DEPARTMENT





Docket/Case Number: CASE NO. SEC-2009-5












Resolution:


Sanction Details: THE FINE WAS PAID ON FEBRUARY 19, 2009.


Consent


i


Initiated By: STATE OF NEVADA OFFICE OF THE SECRETARY OF STATE SECURITIESDIVISION





Docket/Case Number: FILE NO. I09-038






Resolution:



Consent









i


Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATIONDIVISION OF SECURITIES





Docket/Case Number: ADMINISTRATIVE CONSENT ORDER






Resolution:




Consent


i









Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTORPROTECTION BUREAU





Docket/Case Number: ASSURANCE NO. 08-179





Resolution:


Sanction Details: PAYMENT IS DUE TO STATE OF NEW YORK BY MARCH 31, 2009.


Consent


i


Initiated By: COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION


Docket/Case Number: E-2008-0053



Allegations: THE STATE HAS ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION REATE SECURITIES TOCUSTOMERS.












Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS")FROM ALL INVESTORS IN THE RELEVANTCLASS.



Consent


i


Initiated By: COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION





Docket/Case Number: E-2008-0053



Allegations: THE STATE HAS ALLEGED THAT WACHOVIA CAPITAL MARKETS, LLCMISREPRESENTED THE SALE OF AUCTION REATE SECURITIES TOCUSTOMERS.



Resolution:


Consent






Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS")FROM ALL INVESTORS IN THE RELEVANTCLASS.




i


Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES





Docket/Case Number: ENSC-1465






Resolution:


Sanction Details: FINE IS DUE BY 03/06/2009.


Consent







i


Initiated By: FINRA






Other Product Type(s): DESIGNATED SECURITIES, REPORTABLE SECURITIES

Allegations: NASD RULES 2110, 3010, 4632(A), 4632(D), 6130(D) - WACHOVIA CAPITALMARKETS, LLC FAILED WITHIN 90 SECONDS AFTER EXECUTION, TOTRANSMIT TO THE NASD/NASDAQ TRADE REPORTING FACILITY (NNTRF)LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIESAND FAILED TO DESIGNATE SOME OF THEM AS LATE. THE FIRM EXECUTEDSHORT SALE TRANSACTIONS AND FAILED TO REPORT THEM TO THENNTRF WITH THE CORRECT SYMBOL INDICATING WHETHER THETRANSACTIONS WERE BUY, SELL, SELL SHORT, SELL SHORT EXEMPT ORCROSS FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRMFAILED TO SUBMIT TO THE NNTRF FOR THE OFFSETTING, "RISKLESS"PORTION OF "RISKLESS" PRINCIPAL TRANSACTION(S) IN DESIGNATEDSECURITIES, EITHER A CLEARING-ONLY REPORT WITH A CAPACITYINDICATOR OF "RISKLESS PRINCIPAL" OR A NON-TAPE, NON-CLEARINGREPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL." THEFIRM INCORRECTLY SUBMITTED NON-TAPE REPORTS TO THE NNTRF THATINACCURATELY CLASSIFIED LAST SALE REPORTS AS THE SECOND LEG OF "RISKLESS" PRINCIPAL TRANSACTION(S) WHEN THEY WERE "PRINCIPAL"SALES THAT SHOULD HAVE BEEN MEDIA REPORTED TO THE NNTRF. THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND/OR NASD RULES ADDRESSINGQUALITY OF MARKET TOPICS. THE FIRM'S SUPERVISORY PROCEDURESFAILED TO PROVIDE FOR ONE OR MORE OF THE MINIMUMREQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURESIN BEST EXECUTION; SALES INDICATOR ORDER MARKING AND TRADEINPUT; SOFT DOLLAR AGREEMENTS; AND THE ORDER AUDIT TRAILSYSTEM (OATS).










Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $18,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING BESTEXECUTION; SALES INDICATOR ORDER MARKING AND TRADE INPUT; SOFTDOLLAR AGREEMENTS; AND OATS WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.


No




Allegations: NASD RULES 2110, 3010, 4632(A), 4632(D), 6130(D) - WACHOVIA CAPITALMARKETS, LLC ("WCM,LLC") FAILED WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT TO THE NASD/NASDAQ TRADE REPORTINGFACILITY (NNTRF) LAST SALE REPORTS OF TRANSACTIONS INDESIGNATED SECURITIES AND FAILED TO DESIGNATE SOME OF THEM ASLATE. WCM,LLC EXECUTED SHORT SALE TRANSACTIONS AND FAILED TOREPORT THEM TO THE NNTRF WITH THE CORRECT SYMBOL INDICATINGWHETHER THE TRANSACTIONS WERE BUY, SELL, SELL SHORT, SELLSHORT EXEMPT OR CROSS FOR TRANSACTIONS IN REPORTABLESECURITIES. WCM,LLC FAILED TO SUBMIT TO THE NNTRF FOR THEOFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPALTRANSACTION(S) IN DESIGNATED SECURITIES, EITHER A CLEARING-ONLYREPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR ANON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL." WCM,LLC INCORRECTLY SUBMITTED NON-TAPEREPORTS TO THE NNTRF THAT INACCURATELY CLASSIFIED LAST SALEREPORTS AS THE SECOND LEG OF "RISKLESS" PRINCIPALTRANSACTION(S) WHEN THEY WERE "PRINCIPAL" SALES THAT SHOULDHAVE BEEN MEDIA REPORTED TO THE NNTRF. WCM,LLC'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND/OR NASD RULES ADDRESSING QUALITY OF MARKETTOPICS. WCM,LLC'S SUPERVISORY PROCEDURES FAILED TO PROVIDEFOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FOR ADEQUATEWRITTEN SUPERVISORY PROCEDURES IN BEST EXECUTION; SALESINDICATOR ORDER MARKING AND TRADE INPUT; SOFT DOLLARAGREEMENTS; AND THE ORDER AUDIT TRAIL SYSTEM (OATS).







Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")


Censure


MONETARY FINE OF $18,500.00




Other Product Type(s): DESIGNATED SECURITIES, REPORTABLE SECURITIES.

NASD RULES 2110, 3010, 4632(A), 4632(D), 6130(D) - WACHOVIA CAPITALMARKETS, LLC ("WCM,LLC") FAILED WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT TO THE NASD/NASDAQ TRADE REPORTINGFACILITY (NNTRF) LAST SALE REPORTS OF TRANSACTIONS INDESIGNATED SECURITIES AND FAILED TO DESIGNATE SOME OF THEM ASLATE. WCM,LLC EXECUTED SHORT SALE TRANSACTIONS AND FAILED TOREPORT THEM TO THE NNTRF WITH THE CORRECT SYMBOL INDICATINGWHETHER THE TRANSACTIONS WERE BUY, SELL, SELL SHORT, SELLSHORT EXEMPT OR CROSS FOR TRANSACTIONS IN REPORTABLESECURITIES. WCM,LLC FAILED TO SUBMIT TO THE NNTRF FOR THEOFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPALTRANSACTION(S) IN DESIGNATED SECURITIES, EITHER A CLEARING-ONLYREPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR ANON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL." WCM,LLC INCORRECTLY SUBMITTED NON-TAPEREPORTS TO THE NNTRF THAT INACCURATELY CLASSIFIED LAST SALEREPORTS AS THE SECOND LEG OF "RISKLESS" PRINCIPALTRANSACTION(S) WHEN THEY WERE "PRINCIPAL" SALES THAT SHOULDHAVE BEEN MEDIA REPORTED TO THE NNTRF. WCM,LLC'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND/OR NASD RULES ADDRESSING QUALITY OF MARKETTOPICS. WCM,LLC'S SUPERVISORY PROCEDURES FAILED TO PROVIDEFOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FOR ADEQUATEWRITTEN SUPERVISORY PROCEDURES IN BEST EXECUTION; SALESINDICATOR ORDER MARKING AND TRADE INPUT; SOFT DOLLARAGREEMENTS; AND THE ORDER AUDIT TRAIL SYSTEM (OATS).


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, WCM,LLC IS CENSURED, FINED $18,500 AND REQUIRED TOREVISE OUR WRITTEN SUPERVISORY PROCEDURES REGARDING BESTEXECUTION; SALES INDICATOR ORDER MARKING AND TRADE INPUT; SOFTDOLLAR AGREEMENTS; AND OATS WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.




i


Allegations: NASD RULE 2110 - WACHOVIA CAPITAL MARKETS, LLC FAILED, WITHIN 90SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQMARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES IT WAS REQUIRED TO REPORT TO THE NMC.








Initiated By: FINRA






Other Product Type(s): ELIGIBLE SECURITIES

Allegations: NASD RULE 2110 - WACHOVIA CAPITAL MARKETS, LLC FAILED, WITHIN 90SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQMARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES IT WAS REQUIRED TO REPORT TO THE NMC.


Resolution:




No




Initiated By: FINRA


Allegations: NASD RULE 2110 - WACHOVIA CAPITAL MARKETS, LLC FAILED, WITHIN 90SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQMARKET CENTER (NMC), LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES IT WAS REQUIRED TO REPORT TO THE NMC.








Censure


MONETARY FINE



Other Product Type(s): ELIGIBLE SECURITIES


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $6000.00.




i


Allegations: NASD RULES 2110, 2711(H) - SPECIFICALLY, [2711(H)(2)(A)(II)(A);2711(H)(1)(B); 2711(H)(2)(A)(II)(B); 2711(H)(2)(A)(II)(C); 2711(H)(2)(A)(III)(A);2711(H)(2)(A)(III)(B); 2711(H)(8), 2711(H)(10)] AND 2711(I): WACHOVIA CAPITALMARKETS, LLC ("WACHOVIA") PUBLISHED 40 EQUITY RESEARCHREPORTS THAT OMITTED A TOTAL OF 56 DISCLOSURES REQUIRED BYNASD RESEARCH ANALYST CONFLICT OF INTEREST RULES. THE FIRMOMITTED DISCLOSURES REQUIRED BY 2711(H)(1) (OWNERSHIP OFSHARES OF THE SUBJECT COMPANY), 2711(H)(2) (COMPENSATION FROMINVESTMENT BANKING SERVICES), AND 2711(H)(8) (MAKING A MARKET INTHE SECURITIES OF THE SUBJECT COMPANY). THE FIRM OMITTEDDISCLOSURES CONCERNING ITS REMUNERATIVE RELATIONSHIP WITHTHE SUBJECT COMPANIES, THUS DEPRIVING THE INVESTING PUBLIC OFCRITICAL INFORMATION REGARDING THE FIRM'S ACTUAL POTENTIALCONFLICTS OF INTEREST. IN THESE CASES, THE FIRM FAILED TO ENSURETHAT APPLICABLE DISCLOSURE INFORMATION WAS INCLUDED ININITIATION AND OTHER REPORTS PRIOR TO PUBLICATION. FROM MARCH2004 TO JULY 2007, WACHOVIA INCLUDED IN MORE THAN 15,000 EQUITYRESEARCH REPORTS (ALL SUCH REPORTS PUBLISHED DURING THATTIME PERIOD), A DISCLAIMER STATING THAT THE FIRM AND ITS AFFILIATES "MAY" OWN AN INTEREST IN THE SECURITIES OF THE SUBJECT COMPANYWITHOUT STATING AFFIRMATIVELY WHETHER OR NOT IT HELD SUCH ANINTEREST. THIS DISCLAIMER WAS MADE IN ADDITION TO AND CONFLICTEDWITH THE REQUIRED DISCLOSURE REGARDING THE FIRM'S OWNERSHIPINTEREST AS REQUIRED BY RULE 2711(H)(1)(B). THE FIRM'S USE OF THISDISCLAIMER CONTRADICTED EXPRESS GUIDANCE IN NOTICE TOMEMBERS 04-18, PUBLISHED IN MARCH 2004, CONCERNING THE USE OFDISCLAIMERS THAT CONTRADICT OR ARE INCONSISTENT WITHDISCLOSURES REQUIRED BY SRO RULES. WACHOVIA ALSO FAILED TOADEQUATELY IMPLEMENT SUPERVISORY PROCEDURES REASONABLYDESIGNED TO ENSURE COMPLIANCE WITH RULE 2711(H). (CONTINUED INCOMMENTS SECTION)







Initiated By: FINRA







NASD RULES 2110, 2711(H) - SPECIFICALLY, [2711(H)(2)(A)(II)(A);2711(H)(1)(B); 2711(H)(2)(A)(II)(B); 2711(H)(2)(A)(II)(C); 2711(H)(2)(A)(III)(A);2711(H)(2)(A)(III)(B); 2711(H)(8), 2711(H)(10)] AND 2711(I): WACHOVIA CAPITALMARKETS, LLC ("WACHOVIA") PUBLISHED 40 EQUITY RESEARCHREPORTS THAT OMITTED A TOTAL OF 56 DISCLOSURES REQUIRED BYNASD RESEARCH ANALYST CONFLICT OF INTEREST RULES. THE FIRMOMITTED DISCLOSURES REQUIRED BY 2711(H)(1) (OWNERSHIP OFSHARES OF THE SUBJECT COMPANY), 2711(H)(2) (COMPENSATION FROMINVESTMENT BANKING SERVICES), AND 2711(H)(8) (MAKING A MARKET INTHE SECURITIES OF THE SUBJECT COMPANY). THE FIRM OMITTEDDISCLOSURES CONCERNING ITS REMUNERATIVE RELATIONSHIP WITHTHE SUBJECT COMPANIES, THUS DEPRIVING THE INVESTING PUBLIC OFCRITICAL INFORMATION REGARDING THE FIRM'S ACTUAL POTENTIALCONFLICTS OF INTEREST. IN THESE CASES, THE FIRM FAILED TO ENSURETHAT APPLICABLE DISCLOSURE INFORMATION WAS INCLUDED ININITIATION AND OTHER REPORTS PRIOR TO PUBLICATION. FROM MARCH2004 TO JULY 2007, WACHOVIA INCLUDED IN MORE THAN 15,000 EQUITYRESEARCH REPORTS (ALL SUCH REPORTS PUBLISHED DURING THATTIME PERIOD), A DISCLAIMER STATING THAT THE FIRM AND ITS AFFILIATES "MAY" OWN AN INTEREST IN THE SECURITIES OF THE SUBJECT COMPANYWITHOUT STATING AFFIRMATIVELY WHETHER OR NOT IT HELD SUCH ANINTEREST. THIS DISCLAIMER WAS MADE IN ADDITION TO AND CONFLICTEDWITH THE REQUIRED DISCLOSURE REGARDING THE FIRM'S OWNERSHIPINTEREST AS REQUIRED BY RULE 2711(H)(1)(B). THE FIRM'S USE OF THISDISCLAIMER CONTRADICTED EXPRESS GUIDANCE IN NOTICE TOMEMBERS 04-18, PUBLISHED IN MARCH 2004, CONCERNING THE USE OFDISCLAIMERS THAT CONTRADICT OR ARE INCONSISTENT WITHDISCLOSURES REQUIRED BY SRO RULES. WACHOVIA ALSO FAILED TOADEQUATELY IMPLEMENT SUPERVISORY PROCEDURES REASONABLYDESIGNED TO ENSURE COMPLIANCE WITH RULE 2711(H). (CONTINUED INCOMMENTS SECTION)


Resolution:



Regulator Statement (FINDINGS CONTINUED) WACHOVIA FAILED TO IMPLEMENT ITS WRITTENSUPERVISORY PROCEDURES CONCERNING RESEARCH DISCLOSURES BYFAILING TO (1) COMPILE ACCURATE AND COMPLETE DISCLOSUREINFORMATION FOR THE SUBJECT COMPANIES; AND (2) CHECK WHETHERALL APPROPRIATE DISCLOSURE INFORMATION WAS ENTERED INTO THEONLINE PUBLICATION SYSTEM AND INCLUDED IN THE RESEARCHREPORTS PRIOR TO PUBLICATION.


No









(FINDINGS CONTINUED) WACHOVIA FAILED TO IMPLEMENT ITS WRITTENSUPERVISORY PROCEDURES CONCERNING RESEARCH DISCLOSURES BYFAILING TO (1) COMPILE ACCURATE AND COMPLETE DISCLOSUREINFORMATION FOR THE SUBJECT COMPANIES; AND (2) CHECK WHETHERALL APPROPRIATE DISCLOSURE INFORMATION WAS ENTERED INTO THEONLINE PUBLICATION SYSTEM AND INCLUDED IN THE RESEARCHREPORTS PRIOR TO PUBLICATION.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure


$300,000.00 FINE





Allegations: WACHOVIA CAPITAL MARKETS, LLC ("WCM"), ENTERED INTO ANACCEPTANCE, WAIVER AND CONSENT WITH FINRA, WHEREBY WCMACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THEFINDINGS, TO THE ENTRY OF THE FOLLOWING FINDINGS BY FINRA: 1)WCM VIOLATED NASD RULES 2110, 2711(H) AND 2711(I) BY PUBLISHING 40EQUITY RESEARCH REPORTS DURING THE PERIOD JUNE 2004 TO APRIL2006 THAT OMITTED A TOTAL OF 56 DISCLOSURES REQUIRED BY NASDRULE 2711. 2) FROM MARCH 2004 TO JULY 2007, WCM INCLUDED IN MORETHAN 15,000 EQUITY RESEARCH REPORTS, A DISCLAIMER STATING THATTHE FIRM AND ITS AFFILIATES "MAY" OWN AN INTEREST IN THESECURITIES OF THE SUBJECT COMPANY. THIS DISCLAIMER WAS MADE INADDITION TO AND CONFLICTED WITH THE REQUIRED DISCLOSUREREGARDING THE FIRM'S OWNERSHIP INTEREST AS REQUIRED BY RULE2711(H)(1)(B). 3) WCM ALSO FAILED TO ADEQUATELY IMPLEMENTSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH RULE 2711(H).



Resolution:











Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA CAPITALMARKETS, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED AND FINED$300,000.00.


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Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT




Docket/Case Number: HBD# 07-116



Allegations: **6/29/07** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION'S DIVISION OF ENFORCEMENT AND PENDINGCONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT,WACHOVIA CAPITAL MARKETS LLC CONSENTS TO FINDINGS THAT ITVIOLATED: 1. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCTDESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGED TRADEDFUNDS; AND 2. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISHAND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITHRESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIESRELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS.STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF:1. CENSURE; 2. A FINE IN THE AMOUNT OF $375,000; AND3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH A WRITTENCERTIFICATION THAT ITS CURRENT POLICIES AND PROCEDURES,INCLUDING WRITTEN SUPERVISORY AND OPERATIONAL POLICIES ANDPROCEDURES, REGARDING THE DELIVERY OF PROSPECTUSES ANDPRODUCT DESCRIPTIONS ARE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NYSE RULESAPPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCTDESCRIPTIONS. THE FIRM WILL PROVIDE ENFORCEMENT WITH THISWRITTEN CERTIFICATION WITHIN 90 DAYS FROM THE DATE THAT AHEARING PANEL DECISION IN THIS MATTER BECOMES FINAL.









Resolution:

Other Sanctions Ordered: CONSENT TO CENSURE, $375,000 FINE AND UNDERTAKING.

Sanction Details: **9/7/07** DECISION 07-116 ISSUED BY NYSE HEARING BOARDDECISION: WACHOVIA CAPITAL MARKETS LLC CONSENTED TO FINDINGSTHAT IT VIOLATED: 1. NYSE RULE 1100(B) BY FAILING TO DELIVERPRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGETRADED FUNDS; AND 2. NYSE RULE 342 BY FAILING TO PROVIDE FOR,ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISIONAND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITHRESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIESRELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS. SANCTION:CENSURE, A $375,000 FINE AND AN UNDERTAKING.

Regulator Statement **10/4/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESSON OCTOBER 2, 2007 AND THE FINE BECAME PAYABLE ON THAT SAMEDATE. CONTACT: PEGGY GERMINO 212-656-8450.


Decision


Allegations: STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION'SDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, WACHOVIA CAPITAL MARKETSLLC CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 1100(B) BYFAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THATPURCHASED EXCHANGED TRADED FUNDS IN THE SECONDARY MARKET;AND 2. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH ANDMAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROLINCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITSOPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THEDELIVERY OF PRODUCT DESCRIPTIONS. STIPULATED SANCTION: THEIMPOSITION BY THE NYSE OF: 1. CENSURE; 2. A FINE IN THE AMOUNT OF$375,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH AWRITTEN CERTIFICATION THAT ITS CURRENT POLICIES ANDPROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONALPOLICIES AND PROCEDURES, REGARDING THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS ARE REASONABLYDESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIESLAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS. THE FIRM WILL PROVIDEENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYSFROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTERBECOMES FINAL.









Censure


$375,000 FINE





STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION'SDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, WACHOVIA CAPITAL MARKETSLLC CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 1100(B) BYFAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THATPURCHASED EXCHANGED TRADED FUNDS IN THE SECONDARY MARKET;AND 2. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH ANDMAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROLINCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITSOPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THEDELIVERY OF PRODUCT DESCRIPTIONS. STIPULATED SANCTION: THEIMPOSITION BY THE NYSE OF: 1. CENSURE; 2. A FINE IN THE AMOUNT OF$375,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH AWRITTEN CERTIFICATION THAT ITS CURRENT POLICIES ANDPROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONALPOLICIES AND PROCEDURES, REGARDING THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS ARE REASONABLYDESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIESLAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS. THE FIRM WILL PROVIDEENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYSFROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTERBECOMES FINAL.


Resolution:

Other Sanctions Ordered: CONSENT TO CENSURE, $375,000 FINE AND UNDERTAKING.

Sanction Details: **9/7/07** DECISION 07-116 ISSUED BY NYSE HEARING BOARD DECISION:WACHOVIA CAPITAL MARKETS LLC CONSENTED TO FINDINGS THAT ITVIOLATED: 1. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCTDESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADEDFUNDS; AND 2. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISHAND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITHRESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIESRELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS. SANCTION:CENSURE, A $375,000 FINE AND AN UNDERTAKING.


Decision


i


Allegations: ON JULY 16, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF NEW HAMPSHIRE,THROUGH A CONSENT ORDER. THE ORDERWAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: STATE OF NEW HAMPSHIRE, DEPT. OF STATE BUREAU OF SECURITIESREGULATION




CEASE AND DESIST




Other Product Type(s): EQUITY RESEARCH/INVESTMENT BANKING

Allegations: ON JULY 16, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF NEW HAMPSHIRE,THROUGH A CONSENT ORDER. THE ORDERWAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION


Order


i







Initiated By: STATE OF MARYLAND OFFICE OF THE ATTORNEY GENERAL




CEASE AND DESIST





Allegations: ON JULY 12, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF MARYLAND, OFFICE OF THE ATTORNEY GENERAL THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $326,480.00 -SUPERVISION 26,934.00 - BOOKS & RECORDS $ 48,972.00 - INVESTOREDUCATION (IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $326,480.00 -SUPERVISION 26,934.00 - BOOKS & RECORDS $ 48,972.00 - INVESTOREDUCATION (IPT)


Order







i


Initiated By: STATE OF SOUTH CAROLINA, OFFICE OF THE ATTORNEY GENERALSECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: ADMIN ORDER NO. 07022



Allegations: ON JULY 11, 2007 WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF SOUTH CAROLINA,THROUGH A CONSENT ORDER. THE ORDERWAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $247,304.00 -SUPERVISION 20,402.00 - BOOKS & RECORDS $ 37,096.00 - INVESTOREDUCATION (IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $247,304.00 -SUPERVISION 20,402.00 - BOOKS & RECORDS $ 37,096.00 - INVESTOREDUCATION (IPT)


Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $247,304.00 -SUPERVISION 20,402.00 - BOOKS & RECORDS $ 37,096.00 - INVESTOREDUCATION (IPT)


i


Initiated By: STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE SERVICES




CEASE AND DESIST





Allegations: ON JULY 5,2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCESERVICES,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $612,615.00 -SUPERVISION $50,541.00 - BOOKS & RECORDS $ $91,892.00 - INVESTOREDUCATION (IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $612,615.00 -SUPERVISION $50,541.00 - BOOKS & RECORDS $ $91,892.00 - INVESTOREDUCATION (IPT)








Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $612,615.00 -SUPERVISION $50,541.00 - BOOKS & RECORDS $ $91,892.00 - INVESTOREDUCATION (IPT)


i


Initiated By: DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES ANDBANKING




CEASE AND DESIST


Docket/Case Number: ORDER NO. SB-06-003



Allegations: ON JULY 5, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THEDISTRICT OF COLUMBIA, DEPARTMENT OF INSURANCE, SECURITIES ANDBANKING, THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION (MADE PAYABLE TO IPT)


Order







Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION (MADE PAYABLE TO IPT)


i


Initiated By: ALASKA DEPARTMENT OF COMMERCE, COMMUNITY AND ECONOMICDEVELOPMENT


Cease and Desist



Docket/Case Number:



Allegations: ON MAY 22, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THEALASKA DEPARTMENT OF COMMERCE, THROUGH A CONSENT ORDER.THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:


Order










i




Other


WACHOVIA AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNTOF $262,154.






Allegations: A MULTI-STATE TASK FORCE CONDUCTED A COORDINATEDINVESTIGATION INTO ACTIVITIES OF WACHOVIA CAPITAL MARKETS, LLCAND ITS PREDECESSORS, IN CONNECTION WITH CERTAIN POTENTIALCONFLICTS OF INTEREST THAT RESEARCH ANALYSTS WERE SUBJECT TODURING THE PERIOD OF JANUARY 1, 1999, THROUGH DECEMBER 31, 2002.



Resolution:


No

Consent







Sanction Details: WACHOVIA IS ORDERED TO PAY A $262,154.00 CIVIL PENALTY TO THEOKLAHOMA DEPARTMENT OF SECURITIES INVESTOR EDUCATIONREVOLVING FUND.


No



Initiated By: STATE OF OKLAHOMA DEPARTMENT OF SECURITIES


Cease and Desist



Docket/Case Number: ODS FILE NO. 06-035



Allegations: ON JUNE 6, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF OKLAHOMA DEPARTMENT OF SECURITIES, THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution: Order












i


Initiated By: STATE OF IDAHO DEPARTMENT OF FINANCE


Cease and Desist






Allegations: ON MAY 10, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF IDAHO DEPARTMENT OF FINANCE, THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.








Resolution:





Order


i


Initiated By: MINNESOTA


Cease and Desist






Allegations: ON MAY 4, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF MINNESOTA,THROUGH A CONSENT ORDER. THE ORDER WASPART OF A NATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORSTO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.









Resolution:





Order


i


Initiated By: NASD







Allegations: NASD RULES 2110, 3010 - WACHOVIA CAPITAL MARKETS, LLC FAILED TOADEQUATELY SUPERVISE FOR COMPLIANCE WITH NASD CONDUCT RULE3050(C) IN THAT THE FIRM FAILED TO ENSURE THAT ALL NEW EMPLOYEESPROMPTLY COMPLETED AND RETURNED FORMS DISCLOSING WHETHERTHEY HAD INTERESTS IN ANY OUTSIDE BROKERAGE ACCOUNTS.


Resolution: Acceptance, Waiver & Consent(AWC) 157©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC







Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $15,000.


No




Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS








Allegations: WACHOVIA CAPITAL MARKETS, LLC (WCM) FAILED TO ADEQUATELYSUPERVISE FOR COMPLIANCE WITH NASD CONDUCT RULE 3050(C) FROMAPPROXIMATELY OCTOBER, 2003 TO FEBRUARY, 2004, AND AGAIN INEARLY 2005. SPECIFICALLY, WCM DID NOT ENSURE THAT ALL NEWEMPLOYEES PROMPTLY COMPLETED AND RETURNED FORMSDISCLOSING WHETHER THEY HAD INTERESTS IN ANY OUTSIDEBROKERAGE ACCOUNTS. AS A RESULT, THE FIRM VIOLATED NASDCONDUCT RULES 2110 AND 3010.



Resolution:









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WCM CONSENTED TOTHE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, WCM WAS FINED $15,000.

Firm Statement WACHOVIA CAPITAL MARKETS, LLC (WCM) FAILED TO ADEQUATELYSUPERVISE FOR COMPLIANCE WITH NASD CONDUCT RULE 3050(C) FROMAPPROXIMATELY OCTOBER, 2003 TO FEBRUARY, 2004, AND AGAIN INEARLY 2005. SPECIFICALLY, WCM DID NOT ENSURE THAT ALL NEWEMPLOYEES PROMPTLY COMPLETED AND RETURNED FORMSDISCLOSING WHETHER THEY HAD INTERESTS IN ANY OUTSIDEBROKERAGE ACCOUNTS. AS A RESULT, THE FIRM VIOLATED NASDCONDUCT RULES 2110 AND 3010. WITHOUT ADMITTING OR DENYING THEFINDINGS, WCM CONSENTED TO THE DESCRIBED SANCTION AND TO THEENTRY OF FINDINGS; THEREFORE, WCM WAS FINED $15,000.



i


Initiated By: PENNSYLVANIA CONTACT: MICHAEL J. BYRNE (717)-783-5130


Other


WACHOVIA CAPITAL MARKETS, LLC IS ORDERED TO PAY A $733,021.00ADMINISTRATIVE ASSESSMENT AND $200,000.00 TO THE INVESTOREDUCATION FUND OF THE INVESTOR PROTECTION TRUST.






Allegations: A COORDINATED INVESTIGATION INTO ACTIVITIES OF WACHOVIA CAPITALMARKETS, LLC AND ITS PREDECESSORS, IN CONNECTION WITH CERTAINPOTENTIAL CONFLICTS OF INTEREST THAT RESEARCH ANALYSTS WERESUBJECT TO DURING THE PERIOD OF JANUARY 1, 1999, THROUGHDECEMBER 31, 2002, HAS BEEN CONDUCTED BY A MULTI-STATE TASKFORCE.


Resolution: Settled159©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC






Resolution:

Other Sanctions Ordered: RESPONDENT HAS DEMONSTRATED THAT ITS ORGANIZATIONALSTRUCTURE AND SOME OF ITS POLICIES WERE ALREADY CONSISTENTWITH MANY OF THE NEW STRUCTURAL REFORMS OUTLINED IN THEDECEMBER 2002 RESEARCH ANALYST GLOBAL SETTLEMENT AGREEMENT-IN-PRINCIPLE, AND RESPONDENT VOLUNTARILY BEGAN IMPLEMENTINGADDITIONAL POLICIES AND PROCEDURES IN JANUARY 2003 CONSISTENTWITH THOSE STRUCTURAL REFORMS AND COMPLETED THATIMPLEMENTATION BY NOVEMBER 2003. RESPONDENT CONTRACTED TOUPGRADE THE EMAIL RETENTION TECHNOLOGY, INCLUDING CONTENTFILTERING AND INTERNAL ARCHIVING PLATFORMS, OF ITS SUBSIDIARIESAND BUSINESS UNITS, INCLUDING RESPONDENT, AND ITSPREDECESSORS, WHICH UPGRADE IS IN THE PROCESS OF BEINGIMPLEMENTED.

Sanction Details: RESPONDENT IS ORDERED TO PAY A $733,021.00 ADMINISTRATIVEASSESSMENT AND $200,000.00 TO THE INVESTOR EDUCATION FUND OFTHE INVESTOR PROTECTION TRUST. RESPONDENT ELECTS TOPERMANENTLY WAIVE ANY RIGHT TO A HEARING AND APPEAL UNDER THEPA SECURITIES ACT OF 1972.

Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TORESPONDENT.


Settled


Initiated By: COMMONWEALTH OF PENNSYLVANIA SECURITIES COMMISSION



Allegations: ON APRIL 24, 2007,, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THECOMMONWEALTH OF PENNSYLVANIA SECURITIES COMMISSION,THROUGHA CONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.








Cease and Desist






Resolution:





Order


i


Initiated By: STATE OF LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS

Allegations: ON MARCH 23, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF LOUISIANA, OFFICE OF FINANCIAL INSTITUTIONS,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF A NATIONALSETTLEMENT WITH STATE SECURITIES REGULATORS TO RESOLVE ANINVESTIGATION OF POTENTIAL CONFLICTS OF INTEREST BETWEENWCM'S EQUITY RESEARCH AND INVESTMENT BANKING OPERATIONSDURING 1999-2002. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WCM CONSENTED TO AN ORDER THAT IT FAILED TO REASONABLYSUPERVISE ITS EMPLOYEES WITH RESPECT TO THE POTENTIALCONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED IN ACCORDANCEWITH INDUSTRY RULES.







Initiated By: STATE OF LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS




CEASE AND DESIST


Docket/Case Number:




Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $275,471.00 -SUPERVISION, 22,726.00 - BOOKS & RECORDS $ 41,321.00 - INVESTOREDUCATION (ALL PAYMENTS WENT TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $275,471.00 -SUPERVISION, 22,726.00 - BOOKS & RECORDS $ 41,321.00 - INVESTOREDUCATION (ALL PAYMENTS WENT TO IPT)

Sanctions Ordered: Monetary/Fine $339,518.00Disgorgement/Restitution

Order


i


Allegations: ON MARCH 21, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF ARKANSAS SECURITIES DEPARTMENT THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.







Initiated By: STATE OF ARKANSAS SECURITIES DEPARTMENT




CEASE AND DESIST


Docket/Case Number:



ON MARCH 21, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF ARKANSAS SECURITIES DEPARTMENT THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION, 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION, 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION


Order


i


Allegations: ON MARCH 2, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THEILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.







Initiated By: ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT




CEASE AND DESIST


Docket/Case Number: CASE NO. 0400407



ON MARCH 2, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THEILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $765,537.00 -SUPERVISION 63,157.00 - BOOKS & RECORDS, 114,830.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $765,537.00 -SUPERVISION 63,157.00 - BOOKS & RECORDS, 114,830.00 - INVESTOREDUCATION


Order


i


Allegations: THE RELATIONSHIP BETWEEN THE INVESTMENT BANKING DIVISION ANDEQUITY RESEARCH DEPARTMENTS OF RESPONDENT CREATEDPOTENTIAL CONFLICTS OF INTEREST FOR RESEARCH ANALYSTS, IN THATANALYSTS PARTICIPATED IN INVESTMENT BANKING ACTIVITIES; SOME OFRESPONDENT'S PITCHBOOKS PREPARED BY THE INVESTMENT BANKINGDIVISION REFERENCED PAST RESEARCH IN THE CONTEXT OF SEEKINGFUTURE BUSINESS; INVESTMENT BANKING CONCERNS WERECONSIDERED IN RESPONDENT'S DECISIONS TO INITIATE OR CONTINUERESEARCH COVERAGE; INVESTMENT BANKING INPUT WAS A FACTOR INDECISIONS REGARDING PARTICIPATION AT CERTAIN RESEARCHCONFERENCES; INVESTMENT BANKING WAS A FACTOR IN DETERMININGSOMME RESEARCH ANALYSTS' COMPENSATION; PARTICIPATION ININVESTMENT BANKING WAS A FACTOR IN EVALUATING THEPERFORMANCE OF SOME RESEARCH ANALYSTS; AND ADEQUATESYSTEMS/PROCEDURES WERE NOT IN PLACE TO ENSURE THAT ALLELECTRONIC MAIL WAS MAINTAINED OR READILY ACCESSIBLE







Initiated By: FLORIDA




CEASE AND DESIST FROM VIOLATIONS OF CHAPTER 517, FLORIDASTATUTES


Docket/Case Number: 0285-S-8/06




THE RELATIONSHIP BETWEEN THE INVESTMENT BANKING DIVISION ANDEQUITY RESEARCH DEPARTMENTS OF RESPONDENT CREATEDPOTENTIAL CONFLICTS OF INTEREST FOR RESEARCH ANALYSTS, IN THATANALYSTS PARTICIPATED IN INVESTMENT BANKING ACTIVITIES; SOME OFRESPONDENT'S PITCHBOOKS PREPARED BY THE INVESTMENT BANKINGDIVISION REFERENCED PAST RESEARCH IN THE CONTEXT OF SEEKINGFUTURE BUSINESS; INVESTMENT BANKING CONCERNS WERECONSIDERED IN RESPONDENT'S DECISIONS TO INITIATE OR CONTINUERESEARCH COVERAGE; INVESTMENT BANKING INPUT WAS A FACTOR INDECISIONS REGARDING PARTICIPATION AT CERTAIN RESEARCHCONFERENCES; INVESTMENT BANKING WAS A FACTOR IN DETERMININGSOMME RESEARCH ANALYSTS' COMPENSATION; PARTICIPATION ININVESTMENT BANKING WAS A FACTOR IN EVALUATING THEPERFORMANCE OF SOME RESEARCH ANALYSTS; AND ADEQUATESYSTEMS/PROCEDURES WERE NOT IN PLACE TO ENSURE THAT ALLELECTRONIC MAIL WAS MAINTAINED OR READILY ACCESSIBLE


Resolution:


Sanction Details: $1,066,446 TO BE PAID WITHIN TEN (10) DAYS OF THE FINAL ORDER;$147,775 TO BE PAID WITHIN NINETY (90) DAYS OF THE FINAL ORDER.

Regulator Statement RESPONDENT FAILED TO PROPERLY SUPERVISE ITS AGENTS AND PAILEDTO PRESERVE FOR THREE (3) YEARS, AND/OR PRESERVE IN ANACCESSIBLE PLACE FOR TWO (2) YEARS, ALL INTERNAL AND EXTERNALELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THERESPONDENT.


Yes


Consent






Regulator Statement RESPONDENT FAILED TO PROPERLY SUPERVISE ITS AGENTS AND PAILEDTO PRESERVE FOR THREE (3) YEARS, AND/OR PRESERVE IN ANACCESSIBLE PLACE FOR TWO (2) YEARS, ALL INTERNAL AND EXTERNALELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THERESPONDENT.


Initiated By: STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION


Cease and Desist



Docket/Case Number: ADMIN PROCEEDING NO.: 1285-S-8/06



Allegations: ON APRIL 3, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:




Order





www.finra.org/brokercheck User GuidanceTHE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $209,922.00 -SUPERVISION 17,318.00 - BOOKS & RECORDS $ 31,488.00 - INVESTOREDUCATION



i


Initiated By: CONNECTICUT








Other Product Type(s): RESEARCH ANALYST CONFLICTS OF INTEREST

Allegations: THE 4/4/07 CONSENT ORDER ENTERED BY CONNECTICUT FOLLOWED ACOORDINATED INVESTIGATION INTO THE FIRM'S RESEARCH ANDINVESTMENT BANKING ACTIVITIES BETWEEN JANUARY 1, 1999 ANDDECEMBER 31, 2002 CONDUCTED BY A MULTI-STATE TASK FORCE.ACCORDING TO THE CONSENT ORDER, THE FIRM FAILED TO IMPLEMENTCONTROLS TO MANAGE CONFLICTS OF INTEREST INVOLVING ITSRESEARCH ANALYSTS AND INVESTMENT BANKING PERSONNEL AND, INSO DOING, VIOLATED SECTION 36B-31-6F OF THE REGULATIONS UNDERTHE ACT. THE CONSENT ORDER ALSO CONCLUDED THAT THE FIRMVIOLATED SECTION 36B-14(A)(2) OF THE ACT AND SECTION 36B-31-14A(A)OF THE REGULATIONS THEREUNDER BY FAILING TO PRESERVE THERECORDS REQUIRED BY LAW.



Resolution:


No

Consent






Other Sanctions Ordered: THE CONSENT ORDER DIRECTED THE FIRM TO CEASE AND DESIST FROMVIOLATING SECTION 36B-31-6F OF THE REGULATIONS. IN ADDITION, THECONSENT ORDER FINED THE FIRM $227,240, AND REQUIRED THAT THEFIRM REMIT AN ADDITIONAL $31,488 TO THE DEPARTMENT TO PROMOTETHE AGENCY'S INVESTOR EDUCATION EFFORTS.

Sanction Details: SEE RESPONSE TO ITEM 13.B. ABOVE.


No



Initiated By: STATE OF CONNECTICUT BANKING COMMISSIONER


Cease and Desist






Allegations: ON APRIL 4, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF CONNECTICUT BANKING COMMISSIONER, THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.


Resolution: Order168©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC






Resolution:





Order


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Initiated By: ARIZONA CORPORATION COMMISSION




CEASE AND DESIST


Docket/Case Number: DOCKET NO. S-20468A-06-0521



Allegations: ON FEBRUARY 1,, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE ARIZONA CORPORATION COMMISSION,THROUGH A CONSENT ORDER.THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.








CEASE AND DESIST


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $316,257.00 -SUPERVISION 26,091.00 - BOOKS & RECORDS $ 47,439.00 - INVESTOREDUCATION (SENT TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $316,257.00 -SUPERVISION 26,091.00 - BOOKS & RECORDS $ 47,439.00 - INVESTOREDUCATION (SENT TO IPT)


Order


i


Initiated By: TN DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION




Allegations: TN PARTICIPATED IN A MULTI-STATE TASK FORCE INVESTIGATION OFWACHOVIA CAPITAL MARKETS, LLC (WCM) COVERING THE PERIOD FROMJANUARY 1, 1999 TO DECEMBER 31, 2002. WCM VIOLATED T.C.A. 48-2-112(A)(2)(J) BY FAILING TO PROPERLY SUPERVISE ITS EMPLOYEES SO ASTO ENSURE EQUITY RESEARCH ANALYTS DID NOT HAVE CONFLICTS OFINTERST WITH RESPECT TO THEIR RESEARCH DUTIES. THERELATIONSHIP BETWEEN WCM'S EQUITY RESEARCH AND ITSINVESTMENT BANKING WAS SUCH THAT EQUITY RESEARCH ANALYSTSWERE EXPECTED TO ASSIST INVESTMENT BANKING IN GENERATING NEWBUSINESS BUT WERE ALSO REQUIRED TO PROVIDE INDEPENDENT ANDOBJECTIVE RESEARCH TO INVESTORS. WCM ALSO VIOLATED T.C.A. 48-2-111(A) BY FAILING TO PROPERLY PRESERVE AND PRODUCE ITSELECTRONIC RECORDS IN A TIMELY MANNER.








Cease and Desist


CIVIL PENALTY



Other Product Type(s): EQUITY RESEARCH


Resolution:


Sanction Details: WCM IS ORDERED TO CEASE AND DESIST FROM ENGAGING INRESEARCH-RELATED CONDUCT THAT VIOLATES T.C.A. 48-2-112(A)(2)(J)AND IS ORDERED TO MAKE A PAYMENT OF $432,228.00 TO THE TN DEPT.OF COMMERCE AND INSURANCE. $350,692.00 OF THE PAYMENTREPRESENTS TN'S SHARE OF THE $20,000,000.00 SETTLEMENT REACHEDBETWEEN WCM AND THE MULTI-STATE TASK FORCE FOR WCM'SCONDUCT RELATED TO EQUITY RESEARCH. $28,932.00 OF THE PAYMENTREPRESENTS TN'S SHARE OF THE $1,650,000.00 SETTLEMENT REACHEDBETWEEN WCM AND THE MULTI-STATE TASK FORCE FOR WCM'SCONDUCT RELATED TO THE PRESERVATION AND PRODUCTION OF BOOKSAND RECORDS. $52,604.00 OF THE PAYMENT REPRESENTS TN'S SHAREOF THE $3,000,000.00 SETTLEMENT REACHED BETWEEN WCM AND THEMULTI-STATE TASK FORCE FOR INVESTOR EDUCATION.


No


Settled


Allegations: ON JANUARY 25, 2007,, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF TENNESSEE SECURITIES DIVISION,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: STATE OF TENNESSEE SECURITIES DIVISION




CEASE AND DESIST





ON JANUARY 25, 2007,, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF TENNESSEE SECURITIES DIVISION,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.


Resolution:





Order


i


Allegations: ON JANUARY 16, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF RHODE ISLAND, DEPARTMENT OF BUSINESSREGULATION,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.







Initiated By: STATE OF RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION




CEASE AND DESIST





ON JANUARY 16, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF RHODE ISLAND, DEPARTMENT OF BUSINESSREGULATION,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.


Resolution:





Order


i







Initiated By: STATE OF HAWAII, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS




CEASE AND DESIST


Docket/Case Number: SEU-2005-042



Allegations: ON JANUARY 23, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF HAWAII, DEPARTMENT OF COMMERCE AND CONSUMERAFFAIRS, THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.



Resolution:





Order







i


Initiated By: STATE OF OHIO DIVISION OF SECURITIES




CEASE AND DESIST





Allegations: ON JANUARY 8, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF OHIO DIVISION OF SECURITIES,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $699,818.00 -SUPERVISION 57,735.00- BOOKS & RECORDS $ 104,973.00 - INVESTOREDUCATION (SENT TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $699,818.00 -SUPERVISION 57,735.00- BOOKS & RECORDS $ 104,973.00 - INVESTOREDUCATION (SENT TO IPT)


Order





www.finra.org/brokercheck User GuidanceTHE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $699,818.00 -SUPERVISION 57,735.00- BOOKS & RECORDS $ 104,973.00 - INVESTOREDUCATION (SENT TO IPT)


i


Initiated By: STATE OF MISSISSIPPI SECRETARY OF STATE, BUSINESS REGULATION &ENFORCEMENT DIVISION




CEASE AND DESIST


Docket/Case Number: MATTER NO. S-04-0147



Allegations: ON JANUARY 8, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF MISSISSIPPI SECRETARY OF STATE,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:





Order








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Initiated By: STATE OF WYOMING SECRETARY OF STATE




CEASE AND DESIST


Docket/Case Number: CONSENT ORDER #07-01



Allegations: ON DECEMBER 28, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE STATE OF WYOMING SECURITIES DIVISION,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:




Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION 16,500.00 - BOOKS & RECORDS $ 30,000.00 - INVESTOREDUCATION (SENT TO IPT)



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Initiated By: WISCONSIN





Docket/Case Number: S-06146




Allegations: AN ADMINISTRATIVE CONSENT ORDER WAS ISSUED AS PART OF THENATIONAL RESEARCH ANALYST CONFLICT OF INTEREST SETTLEMENTS.THE FIRM PAID A CIVIL MONETARY PENALTY OF $407,491.00, TO THE STATEOF WISCONSIN.



Resolution:


Sanction Details: THE FIRM PAID THE CIVIL MONETARY PENALTY TO THE STATE OFWISCONSIN.


No


Settled






Sanction Details: THE FIRM PAID THE CIVIL MONETARY PENALTY TO THE STATE OFWISCONSIN.

Regulator Statement AN ADMINISTRATIVE CONSENT ORDER WAS ISSUED AS PART OF THENATIONAL RESEARCH ANALYST CONFLICT OF INTEREST SETTLEMENTS.THE FIRM PAID A CIVIL MONETARY PENALTY OF $407,491.00, TO THE STATEOF WISCONSIN.


Initiated By: STATE OF WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS




CEASE AND DESIST


Docket/Case Number: FILE NO. S-06146 (LX)



Allegations: ON FEBRUARY 13, 2007, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE STATE OF WISCONSIN, DEPARTMENT OF FINANCIALINSTITUTIONS, THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.



Resolution:




Order









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Initiated By: STATE OF WEST VIRGINIA SECURITIES DIVISION




CEASE AND DESIST





Allegations: ON DECEMBER 19, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE STATE OF WEST VIRGINIA SECURITIES DIVISION,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Order










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Initiated By: NORTH DAKOTA




CONSENT ORDER CONSISTING OF CEASE & DESIST LANGUAGE, FINDINGSOF FACT AND CONCLUSIONS OF LAW.


Docket/Case Number:



Other Product Type(s): VIOLATIONS CONSISTING OF RESEARCH AND INVESTMENT BANKINGPRACTICES AND BOOKS AND RECORDS.

Allegations: WACHOVIA FAILED TO PROVIDE SUPERVISION TO EMPLOYEES RELATEDTO CONFLICTS OF INTEREST IN EQUITY RESEARCH AND INVESTMENTBANKING. WACHOVIA FAILED TO PRESERVE REQUIRED BOOKS ANDRECORDS.



Resolution:


Yes

Consent







Sanction Details: SIGNED CONSENT ORDER.


Yes



Initiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENT




CEASE AND DESIST





Allegations: ON DECEMBER 4, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF NORTH DAKOTA SECURITIES DEPARTMENT, THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Order









Monetary/Fine $246,500.00Cease and Desist/Injunction


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Initiated By: NEVADA OFFICE OF THE SECRETARY OF STATE, SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: FILE NO. I05-265



Allegations: ON OCTOBER 23, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE NEVADA OFFICE OF THE SECRETARY OF STATE,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution: Order












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Initiated By: COLORADO DIVISION OF SECURITIES




CEASE AND DESIST





Allegations: ON NOVEMBER 1, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE COLORADO DIVISION OF SECURITIES, THROUGH A CONSENT ORDER.THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.








Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $265,133.00 -SUPERVISION $21,873.00 - BOOKS & RECORDS $ 39,770.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $265,133.00 -SUPERVISION $21,873.00 - BOOKS & RECORDS $ 39,770.00 - INVESTOREDUCATION


Order


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Other



Docket/Case Number: CO-2006-0041




Allegations: ON 11/15/2006, WACHOVIA CAPITAL MARKETS LLC ENTERED INTO ACONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION TORESOLVE ISSUED RELATING TO CONFLICTS OF INTEREST ANDSUPERVISORY PROCEDURES. THE FIRM PAID $225,000.00 INADMINISTRATIVE ASSESSMENT, $41,738.00 IN INVESTIGATIVE COSTS,$30,000.00 TO THE NATIONAL FOUNDATION FOR COMPUTER CRIMEPREVENTION, $10,000.00 TO THE ALABAMA COUNCIL FOR ECONOMICEDUCATION AND $31,118.00 TO THE INVESTOR EDUCATION FUND OF THEINVESTOR PROTECTION TRUST.









Resolution:

Other Sanctions Ordered: ON 11/15/2006, WACHOVIA CAPITAL MARKETS LLC ENTERED INTO ACONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION TORESOLVE ISSUED RELATING TO CONFLICTS OF INTEREST ANDSUPERVISORY PROCEDURES. THE FIRM PAID $225,000.00 INADMINISTRATIVE ASSESSMENT, $41,738.00 IN INVESTIGATIVE COSTS,$30,000.00 TO THE NATIONAL FOUNDATION FOR COMPUTER CRIMEPREVENTION, $10,000.00 TO THE ALABAMA COUNCIL FOR ECONOMICEDUCATION AND $31,118.00 TO THE INVESTOR EDUCATION FUND OF THEINVESTOR PROTECTION TRUST.

Sanction Details: ON 11/15/2006, WACHOVIA CAPITAL MARKETS LLC ENTERED INTO ACONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION TORESOLVE ISSUED RELATING TO CONFLICTS OF INTEREST ANDSUPERVISORY PROCEDURES. THE FIRM PAID $225,000.00 INADMINISTRATIVE ASSESSMENT, $41,738.00 IN INVESTIGATIVE COSTS,$30,000.00 TO THE NATIONAL FOUNDATION FOR COMPUTER CRIMEPREVENTION, $10,000.00 TO THE ALABAMA COUNCIL FOR ECONOMICEDUCATION AND $31,118.00 TO THE INVESTOR EDUCATION FUND OF THEINVESTOR PROTECTION TRUST.

Regulator Statement ON 11/15/2006, WACHOVIA CAPITAL MARKETS LLC ENTERED INTO ACONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION TORESOLVE ISSUED RELATING TO CONFLICTS OF INTEREST ANDSUPERVISORY PROCEDURES. THE FIRM PAID $225,000.00 INADMINISTRATIVE ASSESSMENT, $41,738.00 IN INVESTIGATIVE COSTS,$30,000.00 TO THE NATIONAL FOUNDATION FOR COMPUTER CRIMEPREVENTION, $10,000.00 TO THE ALABAMA COUNCIL FOR ECONOMICEDUCATION AND $31,118.00 TO THE INVESTOR EDUCATION FUND OF THEINVESTOR PROTECTION TRUST.


No


Consent











CEASE AND DESIST


Docket/Case Number: ORDER NO. CO-2006-0041



Allegations: ON NOVEMBER 15, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE ALABAMA SECURITIES COMMISSION,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $225,000.00 -SUPERVISION/BOOKS & RECORDS $ 41738.00 - COST OF INVESTIGATION$30,000.00- NATIONAL FOUNDATION FOR COMPUTER CRIME PREVENTION$10,000.00 - INVESTOR EDUCATION31,118.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $225,000.00 -SUPERVISION/BOOKS & RECORDS $ 41738.00 - COST OF INVESTIGATION$30,000.00- NATIONAL FOUNDATION FOR COMPUTER CRIME PREVENTION$10,000.00 - INVESTOR EDUCATION31,118.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


Order





www.finra.org/brokercheck User GuidanceTHE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $225,000.00 -SUPERVISION/BOOKS & RECORDS $ 41738.00 - COST OF INVESTIGATION$30,000.00- NATIONAL FOUNDATION FOR COMPUTER CRIME PREVENTION$10,000.00 - INVESTOR EDUCATION31,118.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


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Initiated By: STATE OF MISSOURI, OFFICE OF SECRETARY OF STATE




CEASE AND DESIST ORDER


Docket/Case Number: CASE NO. AP-06-26



Allegations: ON OCTOBER 6, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF MISSOURI, OFFICE OF SECRETARY OF STATE,THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $344,894.00 -SUPERVISION$ 28,454.00 - BOOKS & RECORDS$ 51,734.00 - INVESTOR EDUCATION


Order





www.finra.org/brokercheck User GuidanceTHE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $344,894.00 -SUPERVISION$ 28,454.00 - BOOKS & RECORDS$ 51,734.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $344,894.00 -SUPERVISION$ 28,454.00 - BOOKS & RECORDS$ 51,734.00 - INVESTOR EDUCATION


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Initiated By: COMMONWEALTH OF KENTUCKY, OFFICE OF FINANCIAL INSTITUTIONS









Allegations: ON OCTOBER 17, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE COMMONWEALTH OF KENTUCKY, OFFICE OF FINANCIALINSTITUTIONS,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $164,138.00 -SUPERVISION$85,000.00 - CONTRIBUTION TO KENTUCKY COUNCIL ON ECONOMICEDUCATION$ 20,554.00 - BOOKS & RECORDS$ 37,371.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


Order






Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $164,138.00 -SUPERVISION$85,000.00 - CONTRIBUTION TO KENTUCKY COUNCIL ON ECONOMICEDUCATION$ 20,554.00 - BOOKS & RECORDS$ 37,371.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $164,138.00 -SUPERVISION$85,000.00 - CONTRIBUTION TO KENTUCKY COUNCIL ON ECONOMICEDUCATION$ 20,554.00 - BOOKS & RECORDS$ 37,371.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


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Initiated By: STATE OF NEW MEXICO, SECURITIES DIVISION






Docket/Case Number: ORDER NO. 06-06-017-046 (CO)



Allegations: ON OCTOBER 13, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF NEW MEXICO, SECURITIES DIVISION,THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.










Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$ 16,500.00 - BOOKS & RECORDS$ 30,000.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$ 16,500.00 - BOOKS & RECORDS$ 30,000.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


Order


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Initiated By: STATE OF VERMONT, SECURITIES DIVISION, DEPARTMENT OF BANKINGINSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION


Docket/Case Number: DOCKET NO. 06-050-S


Allegations: ON OCTOBER 6, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF VERMONT, SECURITIES DIVISION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.














Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$ 16,500.00 - BOOKS & RECORDS$ 30,000.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$ 16,500.00 - BOOKS & RECORDS$ 30,000.00 - INVESTOR EDUCATION


Order


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Initiated By: COMMONWEALTH OF PUERTO RICO, COMMISSIONER OF FINANCIALINSTITUTIONS

Allegations: ON SEPTEMBER 28, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE COMMONWEALTH OF PUERTO RICO, COMMISSIONER OFFINANCIAL INSTITUTIONS, THROUGH A CONSENT ORDER. THE ORDERWAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: COMMONWEALTH OF PUERTO RICO, COMMISSIONER OF FINANCIALINSTITUTIONS






Docket/Case Number: ORDER NO.: C06-V-006




Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $234,766.00 -SUPERVISION$19,368.00 - BOOKS & RECORDS$35,215.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $234,766.00 -SUPERVISION$19,368.00 - BOOKS & RECORDS$35,215.00 - INVESTOR EDUCATION


Order


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Allegations: ON AUGUST 28, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE SOUTH DAKOTA DIVISION OF SECURITIES, THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: SOUTH DAKOTA, DIVISION OF SECURITIES









ON AUGUST 28, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE SOUTH DAKOTA DIVISION OF SECURITIES, THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$16,500.00 - BOOKS & RECORDS$30,000.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION$16,500.00 - BOOKS & RECORDS$30,000.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


Order


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Allegations: ON SEPTEMBER 5, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE SECURITIES COMMISSIONER OF THE STATE OF DELAWARE,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF A NATIONALSETTLEMENT WITH STATE SECURITIES REGULATORS TO RESOLVE ANINVESTIGATION OF POTENTIAL CONFLICTS OF INTEREST BETWEENWCM'S EQUITY RESEARCH AND INVESTMENT BANKING OPERATIONSDURING 1999-2002. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WCM CONSENTED TO AN ORDER THAT IT FAILED TO REASONABLYSUPERVISE ITS EMPLOYEES WITH RESPECT TO THE POTENTIALCONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED IN ACCORDANCEWITH INDUSTRY RULES.







Initiated By: SECURITIES COMMISSIONER OF THE STATE OF DELAWARE









Allegations: ON SEPTEMBER 5, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE SECURITIES COMMISSIONER OF THE STATE OF DELAWARE,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF A NATIONALSETTLEMENT WITH STATE SECURITIES REGULATORS TO RESOLVE ANINVESTIGATION OF POTENTIAL CONFLICTS OF INTEREST BETWEENWCM'S EQUITY RESEARCH AND INVESTMENT BANKING OPERATIONSDURING 1999-2002. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WCM CONSENTED TO AN ORDER THAT IT FAILED TO REASONABLYSUPERVISE ITS EMPLOYEES WITH RESPECT TO THE POTENTIALCONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED IN ACCORDANCEWITH INDUSTRY RULES.


Resolution:





Order


i








Initiated By: STATE OF NEW JERSEY, BUREAU OF SECURITIES









Allegations: ON AUGUST 22, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF NEW JERSEY, BUREAU OF SECURITIES THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:





Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $518,668.00 -SUPERVISION$42,790.00 - BOOKS & RECORDS$77,800.00 - INVESTOR EDUCATION


i


Initiated By: STATE OF NEW JERSEY, BUREAU OF SECURITIES









Allegations: ON AUGUST 22, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF NEW JERSEY, BUREAU OF SECURITIES THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:




Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $518,668.00 -SUPERVISION$42,790.00 - BOOKS & RECORDS$77,800.00 - INVESTOR EDUCATION



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Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES




CEASE AND DESIST


Docket/Case Number: CASE NO. EN-19574



Allegations: ON SEPTEMBER 7 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF GEORGIA COMMISSIONER OF SECURITIES, THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Order







Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $500,000.00 -SUPERVISION$46,251.00 -REIMBURSEMENT OF LEGAL AND ADMINISTRATIVE COSTS$75,693.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $500,000.00 -SUPERVISION$46,251.00 -REIMBURSEMENT OF LEGAL AND ADMINISTRATIVE COSTS$75,693.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


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Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES




CEASE AND DESIST


Docket/Case Number: ORDER NO. S-06-0018



Allegations: ON SEPTEMBER 7, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE OREGON DEPARTMENT OF CONSUMER AND BUSINESSSERVICES, THROUGH A CONSENT ORDER. THE ORDER WAS PART OF ANATIONAL SETTLEMENT WITH STATE SECURITIES REGULATORS TORESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTS OF INTERESTBETWEEN WCM'S EQUITY RESEARCH AND INVESTMENT BANKINGOPERATIONS DURING 1999-2002. WITHOUT ADMITTING OR DENYING THEALLEGATIONS, WCM CONSENTED TO AN ORDER THAT IT FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THEPOTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED INACCORDANCE WITH INDUSTRY RULES.


Resolution: Order199©2020 FINRA. All rights reserved. Report about WELLS FARGO SECURITIES, LLC






Resolution:





Order


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Initiated By: WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS,SECURITIES DIVISION


Docket/Case Number: S-04-142-0S-CO01



Allegations: ON SEPTEMBER 15, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE WASHINGTON STATE DEPARTMENT OF FINANCIALINSTITUTIONS, SECURITIES DIVISION, THROUGH A CONSENT ORDER. THEORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.










CEASE AND DESIST



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $363,319.00 -SUPERVISION$29,974.00 - BOOKS & RECORDS$54,498.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $363,319.00 -SUPERVISION$29,974.00 - BOOKS & RECORDS$54,498.00 - INVESTOR EDUCATION (MADE PAYABLE TO IPT)


Order


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Initiated By: KANSAS OFFICE OF SECURITIES COMMISSIONER

Allegations: ON AUGUST 16, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF KANSAS OFFICE OF SECURITIES COMMISSIONER,THROUGH A CONSENT ORDER. THE ORDER WAS PART OF A NATIONALSETTLEMENT WITH STATE SECURITIES REGULATORS TO RESOLVE ANINVESTIGATION OF POTENTIAL CONFLICTS OF INTEREST BETWEENWCM'S EQUITY RESEARCH AND INVESTMENT BANKING OPERATIONSDURING 1999-2002. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WCM CONSENTED TO AN ORDER THAT IT FAILED TO REASONABLYSUPERVISE ITS EMPLOYEES WITH RESPECT TO THE POTENTIALCONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED IN ACCORDANCEWITH INDUSTRY RULES.












Docket/Case Number: K.S.C. NO. 2004-4891




Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION $16,500.00 - BOOKS & RECORDS $30,000.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $200,000.00 -SUPERVISION $16,500.00 - BOOKS & RECORDS $30,000.00 - INVESTOREDUCATION


Order


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Allegations: ON AUGUST 14, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE COMMONWEALTH OF MASSACHUSETTS, OFFICE OF THE SECRETARYOF THE COMMONWEALTH SECURITIES DIVISION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: COMMONWEALTH OF MASSACHUSETTS, OFFICE OF THE SECRETARY OFTHE COMMONWEALTH, SECURITIES DIVISION




CEASE AND DESIST ORDERS





ON AUGUST 14, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE COMMONWEALTH OF MASSACHUSETTS, OFFICE OF THE SECRETARYOF THE COMMONWEALTH SECURITIES DIVISION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.


Resolution:

Other Sanctions Ordered: CEASE AND DESIST

Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $391,364.00 -SUPERVISION $32,287.00 - BOOKS & RECORDS $58,705.00 - INVESTOREDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $391,364.00 -SUPERVISION $32,287.00 - BOOKS & RECORDS $58,705.00 - INVESTOREDUCATION


Order


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Allegations: ON AUGUST 4, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE UTAH SECURITIES DIVISION THROUGH A CONSENT ORDER. THEORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: UTAH SECURITIES DIVISION




CEASE AND DESIST





ON AUGUST 4, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE UTAH SECURITIES DIVISION THROUGH A CONSENT ORDER. THEORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$200,00.00 - SUPERVISION$16,500 - BOOKS & RECORDS$30,000 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$200,00.00 - SUPERVISION$16,500 - BOOKS & RECORDS$30,000 - INVESTOR EDUCATION


Order


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Allegations: ON AUGUST 3, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF INDIANA SECURITIES DIVISION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: STATE OF INDIANA SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: CAUSE NO. 06-0070 CO



ON AUGUST 3, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF INDIANA SECURITIES DIVISION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.


Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$374,806.00 - SUPERVISION$30,921.00 - BOOKS & RECORDS$56,221.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$374,806.00 - SUPERVISION$30,921.00 - BOOKS & RECORDS$56,221.00 - INVESTOR EDUCATION


Order


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Initiated By: NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE




CEASE AND DESIST


Docket/Case Number: FILE NO. 02-030-RF



Allegations: ON JULY 31, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THENORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE THROUGHA CONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:





Order





www.finra.org/brokercheck User GuidanceTHE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$496,167.00 - SUPERVISION$40,934.00 - BOOKS & RECORDS$74,425.00 - INVESTOR EDUCATION


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Initiated By: STATE OF CALIFORNIA, DEPARTMENT OF CORPORATIONS




CEASE AND DESIST





Allegations: ON AUGUST 1, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF CALIFORNIA, DEPARTMENT OF CORPORATIONS, THROUGHA CONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$2,087,881.00 - SUPERVISION$172,252.00 - BOOKS & RECORDS$313,182.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$2,087,881.00 - SUPERVISION$172,252.00 - BOOKS & RECORDS$313,182.00 - INVESTOR EDUCATION


Order






Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$2,087,881.00 - SUPERVISION$172,252.00 - BOOKS & RECORDS$313,182.00 - INVESTOR EDUCATION


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Initiated By: NEW YORK STATE DEPARTMENT OF LAW




CEASE AND DESIST





Allegations: ON AUGUST 1, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE NEW YORK STATE DEPARTMENT OF LAW, THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$1,266,230.00 - SUPERVISION AND BOOKS & RECORDS$175,459.00 - INVESTOR EDUCATION MADE PAYABLE TO IPT


Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$1,266,230.00 - SUPERVISION AND BOOKS & RECORDS$175,459.00 - INVESTOR EDUCATION MADE PAYABLE TO IPT

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$1,266,230.00 - SUPERVISION AND BOOKS & RECORDS$175,459.00 - INVESTOR EDUCATION MADE PAYABLE TO IPT


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Initiated By: STATE OF MONTANA, STATE AUDITOR'S OFFICE, SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: 08-07-06-235



Allegations: ON JULY 31, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THESTATE OF MONTANA, STATE AUDITOR'S OFFICE, SECURITIES DIVISIONTHROUGH A CONSENT ORDER. THE ORDER WAS PART OF A NATIONALSETTLEMENT WITH STATE SECURITIES REGULATORS TO RESOLVE ANINVESTIGATION OF POTENTIAL CONFLICTS OF INTEREST BETWEENWCM'S EQUITY RESEARCH AND INVESTMENT BANKING OPERATIONSDURING 1999-2002. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WCM CONSENTED TO AN ORDER THAT IT FAILED TO REASONABLYSUPERVISE ITS EMPLOYEES WITH RESPECT TO THE POTENTIALCONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINED IN ACCORDANCEWITH INDUSTRY RULES.



Resolution:



Order







Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$200,000.00 - SUPERVISION$16,500.00 - BOOKS & RECORDS (E-MAIL)$30,000.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$200,000.00 - SUPERVISION$16,500.00 - BOOKS & RECORDS (E-MAIL)$30,000.00 - INVESTOR EDUCATION


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Initiated By: VIRGINIA STATE CORPORATION COMMISSION





Docket/Case Number: SEC-2003-00042



Allegations: ON JULY 31, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITH THEVIRGINIA STATE CORPORATION COMMISSION THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TOORDERS THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution: Order








Sanction Details: SEC ORDER #SEC 2003-00042 REQUIRED WCM TO PAY THE AMOUNTSINDICATED BELOW:

$200,000 - SUPERVISION$35,997 - BOOKS & RECORDS (E-MAIL)$65,449 - INVESTOR EDUCATION$236,326 - COST OF INVESTIGATION

Firm Statement SEC ORDER #SEC 2003-00042 REQUIRED WCM TO PAY THE AMOUNTSINDICATED BELOW:

$200,000 - SUPERVISION$35,997 - BOOKS & RECORDS (E-MAIL)$65,449 - INVESTOR EDUCATION$236,326 - COST OF INVESTIGATION



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Initiated By: TEXAS


Cease and Desist


ADMINISTRATIVE FINE


Docket/Case Number: IC06-CDO-40




Allegations: FROM ON OR ABOUT JANUARY 1, 1999 TO DECEMBER 31, 2002, WACHOVIACAPITAL MARKETS, LLC ENGAGED IN ACTS OR PRACTICES THATINCLUDED: FAILING TO REASONABLY SUPERVISE RESEARCH ANALYSTS'ACTIVITIES AND TO ESTABLISH PROCEDURES TO GUARD AGAINSTIMPROPER CONDUCT, AND FAILED TO PRESERVE FOR A PERIOD OFTHREE YEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWOYEARS, ALL INTERNAL AND EXTERNAL ELECTRONIC COMMUNICATIONSRELATING TO THE BUSINESS OF WACHOVIA CAPITAL MARKETS, LLC.








ADMINISTRATIVE FINE


Resolution:

Other Sanctions Ordered: ADMINISTRATIVE FINE

Sanction Details: NO OTHER SANCTIONS TO FOLLOW.


No


Order


Initiated By: TEXAS STATE SECURITIES BOARD






Docket/Case Number: ORDER IC06-CDO-40



Allegations: ON SEPTEMBER 14, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLEDWITH THE TEXAS STATE SECURITIES BOARD, THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.








Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $1,285,326.00 -SUPERVISION$106,040.00 - BOOKS & RECORDS$192,799.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $1,285,326.00 -SUPERVISION$106,040.00 - BOOKS & RECORDS$192,799.00 - INVESTOR EDUCATION


Order


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Initiated By: IOWA


Cease and Desist


CIVIL PENALTYUNDERTAKINGS





Other Product Type(s): N/A

Allegations: CONFLICTS OF INTEREST BETWEEN INVESTMENT BANKING AND EQUITYRESEARCH DEPARTMENT, FAILURE TO SUPERVISE ITS RESEARCHANALYSTS, FAILED TO MAINTAIN AND PRODUCE IN A TIMELY MANNERCERTAIN BOOKS AND REORDS.


Appealed To and Date AppealFiled:

N/A







CIVIL PENALTYUNDERTAKINGS


Resolution:

Other Sanctions Ordered: N/A

Sanction Details: ORDERED TO CEASE AND DESIST SUPERVISION OF EQUITY RESEARCHSTAFF.

Regulator Statement WACHOVIA AGREED TO THE ORDER WITHOUT ADMITTING OR DENYINGTHE FINDINGS OF FACT OR THE CONCLUSIONS OF LAW CONTAINED INTHE ORDER.


Yes


Consent


Initiated By: IOWA, SECURITIES & REGULATED INDUSTRIES BUREAU


Docket/Case Number: CASE # 1000075



Allegations: ON AUGUST 15, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE IOWA SECURITIES & REGULATED INDUSTRIES BUREAU, THROUGH ACONSENT ORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENTWITH STATE SECURITIES REGULATORS TO RESOLVE AN INVESTIGATIONOF POTENTIAL CONFLICTS OF INTEREST BETWEEN WCM'S EQUITYRESEARCH AND INVESTMENT BANKING OPERATIONS DURING 1999-2002.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTEDTO AN ORDER THAT IT FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES WITH RESPECT TO THE POTENTIAL CONFLICTS, AND THATSOME E-MAIL WAS NOT RETAINED IN ACCORDANCE WITH INDUSTRYRULES.













Resolution:


Sanction Details: THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $198,975.00 -SUPERVISION$1025.00 - REIMBURSEMENT OF LEGAL AND ADMINISTRATIVE COSTS$16,500.00 - BOOKS & RECORDS$30,000.00 - INVESTOR EDUCATION

Firm Statement THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER. $198,975.00 -SUPERVISION$1025.00 - REIMBURSEMENT OF LEGAL AND ADMINISTRATIVE COSTS$16,500.00 - BOOKS & RECORDS$30,000.00 - INVESTOR EDUCATION


Order


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Allegations: ON JULY 3, 2006, THE NEBRASKA DEPARTMENT OF BANKING ANDFINANCE, DIVISION OF SECURITIES, ISSUED A CONSENT ORDERCONCERNING WACHOVIA CAPITAL MARKETS, LLC. THE CONSENT ORDERIS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.







Initiated By: NEBRASKA DEPARTMENT OF BANKING & FINANCE, BUREAU OFSECURITIES




CEASE AND DESIST





ON JULY 3, 2006, THE NEBRASKA DEPARTMENT OF BANKING ANDFINANCE, DIVISION OF SECURITIES, ISSUED A CONSENT ORDERCONCERNING WACHOVIA CAPITAL MARKETS, LLC. THE CONSENT ORDERIS PART OF A NATIONAL SETTLEMENT WITH STATE SECURITIESREGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIAL CONFLICTSOF INTEREST BETWEEN WCM'S EQUITY RESEARCH AND INVESTMENTBANKING OPERATIONS DURING 1999-2002. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, WCM CONSENTED TO AN ORDER THAT ITFAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TOTHE POTENTIAL CONFLICTS, AND THAT SOME E-MAIL WAS NOT RETAINEDIN ACCORDANCE WITH INDUSTRY RULES.


Resolution:

Other Sanctions Ordered: WCM WAS REQUIRED TO PAY A $200,000 FINE RELATING TO SUPERVISION;A $16,500 FINE RELATING TO BOOKS AND RECORDS (E-MAIL); A $30,000PAYMENT FOR INVESTOR EDUCATION; AND A $350,000 PAYMENT FORCOSTS OF INVESTIGATION PAYABLE TO THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION.

Sanction Details: WCM WAS REQUIRED TO PAY A $200,000 FINE RELATING TO SUPERVISION;A $16,500 FINE RELATING TO BOOKS AND RECORDS (E-MAIL); A $30,000PAYMENT FOR INVESTOR EDUCATION; AND A $350,000 PAYMENT FORCOSTS OF INVESTIGATION PAYABLE TO THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION.

Firm Statement ADMINISTRATIVE CONSENT ORDERS ENTERED ON DATES NOTED ABOVEWITH SANCTIONS AS DESCRIBED ABOVE.


Order


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Allegations: IN CONNECTION WITH WACHOVIA CAPITAL MARKETS' ("WCM") RESEARCHANALYST WORK, THE MAINE OFFICE OF SECURITIES CHARGEDVIOLATIONS OF THE REVISED MAINE SECURITIES ACT AND THE MAINEUNIFORM SECURIITES ACT. WHEN WCM FAILED TO REASONABLYSUPERVISE ITS AGENTS OR EMPLOYEES, IT VIOLATED SECTIONS10313(1)(J), 16702(1). WHEN WCM FAILED TO PRESERVE FOR A PERIOD OFTHREE YEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWOYEARS, ALL INTERNAL AND EXTERNAL ELECTRONIC COMMUNICATIONSRELATING TO THE BUISNESS OF WACHOVIA, IT VIOLATED SECTIONS10310(6), 16702(1).







Initiated By: MAINE OFFICE OF SECURITIES


Cease and Desist


PENALTY





Other Product Type(s): RESEARCH

IN CONNECTION WITH WACHOVIA CAPITAL MARKETS' ("WCM") RESEARCHANALYST WORK, THE MAINE OFFICE OF SECURITIES CHARGEDVIOLATIONS OF THE REVISED MAINE SECURITIES ACT AND THE MAINEUNIFORM SECURIITES ACT. WHEN WCM FAILED TO REASONABLYSUPERVISE ITS AGENTS OR EMPLOYEES, IT VIOLATED SECTIONS10313(1)(J), 16702(1). WHEN WCM FAILED TO PRESERVE FOR A PERIOD OFTHREE YEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWOYEARS, ALL INTERNAL AND EXTERNAL ELECTRONIC COMMUNICATIONSRELATING TO THE BUISNESS OF WACHOVIA, IT VIOLATED SECTIONS10310(6), 16702(1).


Resolution:


Sanction Details: WCM AGREED TO PAY TO THE MAINE OFFICE OF SECURITIES: (1) $200,000AS A CIVIL MONETARY PENALTY FOR FAILING TO SUPERVISE ITSEMPLOYEES IN CONNECTION WITH POTENTIAL CONFLICTS OF INTERESTBETWEEN EQUITY RESEARCH AND INVESTMENT BANKING; (2) $16,500 AS ACIVIL MONETARY PENALTY FOR FAILING TO PRESERVE CERTAIN BOOKSAND RECORDS; AND (3) $30,000 TO BE USED FOR INVESTOR EDUCATION.

Regulator Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE APPLICANTAGREED TO A CONSENT ORDER WITH THE MAINE OFFICE OF SECURITIESAND TO PAY $246,000. THE MAINE OFFICE OF SECURITIES CHARGEDVIOLATIONS OF THE REVISED MAINE SECURITIES ACT AND THE MAINEUNIFORM SECURITIES ACT IN CONNECTION WITH RESEARCH ANALYSTWORK, SUPERVISION, AND PRODUCTION OF EMAILS.


No


Order







Initiated By: STATE OF MAINE, OFFICE OF SECURITIES




CEASE AND DESIST


Docket/Case Number: ORDER NO. 04-022



Allegations: ON AUGUST 11, 2006, WACHOVIA CAPITAL MARKETS, LLC SETTLED WITHTHE STATE OF MAINE, OFFICE OF SECURITIES THROUGH A CONSENTORDER. THE ORDER WAS PART OF A NATIONAL SETTLEMENT WITH STATESECURITIES REGULATORS TO RESOLVE AN INVESTIGATION OF POTENTIALCONFLICTS OF INTEREST BETWEEN WCM'S EQUITY RESEARCH ANDINVESTMENT BANKING OPERATIONS DURING 1999-2002. WITHOUTADMITTING OR DENYING THE ALLEGATIONS, WCM CONSENTED TO ANORDER THAT IT FAILED TO REASONABLY SUPERVISE ITS EMPLOYEESWITH RESPECT TO THE POTENTIAL CONFLICTS, AND THAT SOME E-MAILWAS NOT RETAINED IN ACCORDANCE WITH INDUSTRY RULES.



Resolution:





Order






THE ORDER REQUIRED WCM TO PAY THE AMOUNTS INDICATED BELOWAND TO CEASE AND DESIST FROM SUPERVISION VIOLATIONS RELATINGTO THE RESEARCH PRACTICES DESCRIBED IN THE ORDER.$200,000.00 - SUPERVISION$16,500.00 - BOOKS & RECORDS$30,000.00 - INVESTOR EDUCATION


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Allegations: **7/6/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION DIVISION OF ENFORCEMENT AND PENDING AGAINSTWACHOVIA CAPITAL MARKETS, LLC; WACHOVIA SECURITIES, LLC; ANDFIRST CLEARING, LLC ("WACHOVIA RESPONDENTS")CONSENTED TOFINDINGS: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TOFINDINGS: THAT THE WACHOVIA RESPONDENTS VIOLATED SECTION 17(A)OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4THEREUNDER AND NYSE RULE 440 IN THAT THE WACHOVIARESPONDENTS FAILED TO PRESERVE ELECTRONIC RECORDS RELATINGTO THE BUSINESS OF THE WACHOVIA RESPONDENTS FOR AT LEASTTHREE YEARS, THE FIRST TWO YEARS IN AN EASILY ACCESSIBLELOCATION. THAT THE WACHOVIA RESPONDENTS VIOLATED NYSE RULES342 AND 342.17 IN THAT THE WACHOVIA RESPONDENTS FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF THEIREMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OFELECTRONIC COMMUNICATIONS. CONSENTED TO SANCTION: THEIMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE, AREGULATORY UNDERTAKING, AND A FINE OF $2,250,000 (TWO MILLIONAND TWO HUNDRED AND FIFTY THOUSAND DOLLARS, TO BE PAYABLE ASFOLLOWS: BY ONE PAYMENT TO NYSE REGULATION, INC. IN THE AMOUNTOF $600,000 (SIX HUNDRED THOUSAND DOLLARS), DUE AND PAYABLEWHEN THE DECISION IN THIS MATTER BECOMES FINAL; AND BY ANOTHERPAYMENT IN THE AMOUNT OF $1,650,000 (ONE MILLION AND SIX HUNDREDAND FIFTY THOUSAND DOLLARS), COLLECTION OF WHICH THE NYSE WILLWAIVE IN RECOGNITION OF AND CONDITIONAL UPON THE PAYMENT BYWACHOVIA CAPITAL MARKETS OF $1,650,000 (ONE MILLION AND SIXHUNDRED AND FIFTY THOUSAND DOLLARS) PURSUANT TO THE TERMS OFTHE SETTLEMENT OF A REGULATORY ACTION, CONCLUDED UNDER THEAUSPICES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORSASSOCIATION, RELATING TO WACHOVIA CAPITAL MARKETS' VIOLATION OFTHE DUTY TO RETAIN E-MAIL COMMUNICATIONS.













Resolution:


Sanction Details: **8/1/06** DECISION 06-150 ISSUED BY NYSE HEARING BOARDVIOLATIONS FOUND: VIOLATED SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER AND NYSE RULE440 BY FAILING TO PRESERVE ELECTRONIC RECORDS RELATING TO ITSBUSINESS FOR AT LEAST THREE YEARS, THE FIRST TWO YEARS IN ANEASILY ACCESSIBLE LOCATION; VIOLATED EXCHANGE RULES 342 AND342.17 BY FAILING TO REASONABLY SUPERVISE AND CONTROL ACTIVITIESOF ITS EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OFELECTRONIC COMMUNICATIONS.SANCTION: THE HEARING PANEL IMPOSED THE SANCTION, CONSENTEDTO BY THE RESPONDENT, OF A CENSURE, A FINE OF $2,250,000, SUBJECTTO CERTAIN CONDITIONS SET FORTH IN THE DECISION, AND AREGULATORY UNDERTAKING.

Regulator Statement **9/1/06** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450.


Decision


Allegations: WACHOVIA CAPITAL MARKETS, LLC, ALONG WITH WACHOVIA SECURITIES,LLC AND FIRST CLEARING, LLC, IS ALLEGED TO HAVE VIOLATED SECTION17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4 THEREUNDER,ALONG WITH NYSE RULES 440, 342, AND 342.17, BY FAILING TO PRESERVEELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE FIRM FOR ATLEAST THREE YEARS AND BY FAILING TO REASONABLY SUPERVISE THERETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS.







Initiated By: NEW YORK STOCK EXCHANGE


Censure


MONETARY FINE AND UNDERTAKING


Docket/Case Number: NYSE HEARING BOARD DECISION 06-150



WACHOVIA CAPITAL MARKETS, LLC, ALONG WITH WACHOVIA SECURITIES,LLC AND FIRST CLEARING, LLC, IS ALLEGED TO HAVE VIOLATED SECTION17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4 THEREUNDER,ALONG WITH NYSE RULES 440, 342, AND 342.17, BY FAILING TO PRESERVEELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE FIRM FOR ATLEAST THREE YEARS AND BY FAILING TO REASONABLY SUPERVISE THERETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE STIPULATIONOF FACTS AND CONSENT TO PENALTY, THE FIRM, ALONG WITH WACHOVIASECURITIES, LLC AND FIRST CLEARING, LLC, CONSENTED TO THECENSURE, THE FINE AND AN UNDERTAKING TO ENSURE COMPLIANCEWITH THE RULES AND REGULATIONS ON THE RETENTION AND REVIEW OFELECTRONIC COMMUNICATIONS THROUGH ENGAGEMENT OF ANINDEPENDENT CONSULTANT. WITH REGARD TO THE FINE, $1,650,000 OFTHE $2,250,000 IS WAIVED, CONDITIONAL UPON WACHOVIA CAPITALMARKETS, LLC ("WCM") PAYING THAT AMOUNT PURSUANT TO WCM'SSETTLEMENT OF A REGULATORY ACTION BY STATE SECURITIESREGULATORS RELATING, IN PART, TO E-MAIL RETENTION. THE BALANCEOF THE FINE WILL BE PAID BY THE THREE FIRMS ON OR BEFORE 10/16/06.




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Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATEDMAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINTALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OFTHE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS,RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTIONRATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30,2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGEDIN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS:COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS,BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE,BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS,SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OFSECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TOPROVIDE HIGHER RETURNS, AND PRICE TALK.









Cease and Desist


CENSURE, CIVIL PENALTIES




Other Product Type(s): MUNICIPAL BONDS, CORPORATE BONDS

SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATEDMAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINTALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OFTHE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS,RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTIONRATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30,2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGEDIN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS:COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS,BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE,BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS,SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OFSECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TOPROVIDE HIGHER RETURNS, AND PRICE TALK.


Resolution:

Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER,RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLDAUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCHSECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THERESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES.FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THEENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE ADESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICESAND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER-DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN ANAUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITSWEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER-DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERALPUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THEGENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THISORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THECOMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEFEXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITINGTO THE STAFF OF THE COMMISSION THAT RESPONDENT HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOPREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THEAUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURESDISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTALDISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH THISORDER.


No

Sanctions Ordered: CensureMonetary/Fine $125,000.00Cease and Desist/Injunction

Order






NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER,RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLDAUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCHSECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THERESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES.FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THEENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE ADESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICESAND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER-DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN ANAUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITSWEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER-DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERALPUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THEGENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THISORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THECOMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEFEXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITINGTO THE STAFF OF THE COMMISSION THAT RESPONDENT HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOPREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THEAUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURESDISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTALDISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH THISORDER.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTCONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANTTO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THEEXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALLCEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIESACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY OF $125,000 TO THE UNITED STATES TREASURY.




Allegations: WACHOVIA CAPITAL MARKETS, LLC WAS ONE OF FIFTEEN FIRMS THATSETTLED AN SEC INVESTIGATION OF THE FIRMS' PRACTICES INCONDUCTING AUCTIONS OF AUCTION RATE SECURITIES DURING THEPERIOD JANUARY 2003 THROUGH JUNE 2004. THE ORDER ALLEGES WCMENGAGED IN ONE OR MORE PRACTICES DESCRIBED IN THE ORDER THATCONSTITUTED VIOLATIONS OF SECTION 17(A)(2)OF THE SECURITIES ACTOF 1933. WCM NEITHER ADMITTED NOR DENIED THE FINDINGS IN THEORDER.THE SEC'S ORDER RECITED THAT WCM WAS AMONG THE FIRMS THATPAID THE LOWEST PENALTY AMOUNT ($125,000) BASED ON ITSRELATIVELY SMALL SHARE OF THE AUCTION RATE SECURITIES MARKETAND THAT IT ENGAGED IN FEWER TYPES OF PRACTICES THAN FIRMSTHAT PAID HIGHER PENALTIES.










CEASE AND DESIST, AS WELL AS CENSURE. ALL FIRMS IN THESETTLEMENT MUST ALSO DISTRIBUTE A DESCRIPTION OF THEIRMATERIAL AUCTION PRACTICES AND PROCEDURES TO THEIRCUSTOMERS THAT HOLD AUCTION RATE SECURITIES AND THE ISSUER OFSUCH SECURITIES THROUGH METHODS DESCRIBED IN THE ORDER. THEFIRMS MUST ALSO MAKE A CERTIFICATION TO THE SEC STAFF RELATINGTO THE SUFFICIENCY OF THEIR PROCEDURES AND THE DISTRIBUTION OFTHE PROCEDURES TO CUSTOMERS AND ISSUERS AS DESCRIBED IN THEORDER.




Other Product Type(s): DEBT-MUNICIPALEQUITY LISTED (COMMON & PREFERRED STOCK)


Resolution:

Other Sanctions Ordered: ALL FIRMS IN THE SETTLEMENT MUST ALSO DISTRIBUTE A DESCRIPTIONOF THEIR MATERIAL AUCTION PRACTICES AND PROCEDURES TO THEIRCUSTOMERS THAT HOLD AUCTION RATE SECURITIES AND THE ISSUER OFSUCH SECURITIES THROUGH METHODS DESCRIBED IN THE ORDER. THEFIRMS MUST ALSO MAKE A CERTIFICATION TO THE SEC STAFF RELATINGTO THE SUFFICIENCY OF THEIR PROCEDURES AND THE DISTRIBUTION OFTHE PROCEDURES TO CUSTOMERS AND ISSUERS AS DESCRIBED IN THEORDER.

Sanction Details: THE $125,000.00 FINE WAS SENT TO THE SEC ON JUNE 9, 2006.

Sanctions Ordered: CensureMonetary/Fine $125,000.00Cease and Desist/Injunction

Order


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Allegations: **9/28/05**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:1.VIOLATED EXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BYFAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICEIN THE CONDUCT OF THEIR BUSINESS AFFAIRS IN THAT IT SUBMITTEDINACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS INRESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TOESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURESFOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FORCOMPLYING WITH ELECTRONIC BLUE SHEET REPORTINGREQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITHEXCHANGE RULES RELATING TO THE PREPARATION AND SUBMISSION OFELECTRONIC BLUE SHEETS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE, A $500,000 FINE AND A REQUIREMENT THAT RESPONDENT WILLCONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTSIN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.











Docket/Case Number: HPD# 05-160



**9/28/05**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:1.VIOLATED EXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BYFAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICEIN THE CONDUCT OF THEIR BUSINESS AFFAIRS IN THAT IT SUBMITTEDINACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS INRESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TOESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURESFOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FORCOMPLYING WITH ELECTRONIC BLUE SHEET REPORTINGREQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITHEXCHANGE RULES RELATING TO THE PREPARATION AND SUBMISSION OFELECTRONIC BLUE SHEETS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE, A $500,000 FINE AND A REQUIREMENT THAT RESPONDENT WILLCONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTSIN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.


Resolution:


Sanction Details: **1/5/06** DECISION 05-160 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS; VIOLATED NYSE RULE 401 BY SUBMITTING INACCURATETRADING INFORMATION ON ELECTRONIC BLUE SHEETS; VIOLATED NYSERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATESYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OFAREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION ANDSUBMISSION OF ELECTRONIC BLUE SHEETS. -CONSENT TO CENSURE,FINE OF $500,000, AND A REQUIREMENT TO CONDUCT VALIDATION OF ALLREQUIRED BLUE SHEET DATA ELEMENTS, AND UNDERTAKING TO INFORMNYSE IN WRITING THAT VALIDATION HAS BEEN COMPLETED.


Decision





www.finra.org/brokercheck User Guidance**1/5/06** DECISION 05-160 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS; VIOLATED NYSE RULE 401 BY SUBMITTING INACCURATETRADING INFORMATION ON ELECTRONIC BLUE SHEETS; VIOLATED NYSERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATESYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OFAREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION ANDSUBMISSION OF ELECTRONIC BLUE SHEETS. -CONSENT TO CENSURE,FINE OF $500,000, AND A REQUIREMENT TO CONDUCT VALIDATION OF ALLREQUIRED BLUE SHEET DATA ELEMENTS, AND UNDERTAKING TO INFORMNYSE IN WRITING THAT VALIDATION HAS BEEN COMPLETED.

Regulator Statement **2/17/06** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212 656-8450.


Allegations: **9/28/05** SUBMITTED A STIPULATION OF FACTS AND CONSENT TOPENALTY TO NYSE DIVISION OF ENFORCEMENT TO RESOLVE AREGULATORY SWEEP INVOLVING MORE THAN 20 FIRMS FOR ALLEGEDLYSUBMITTING INACCURATE SHORT SALE INFORMATION TO NYSE VIAELECTRONIC BLUE SHEET SUBMISSIONS. SETTLEMENT OF THIS MATTERIS PENDING ACCEPTANCE BY NYSE HEARING PANEL. FOR THE SOLEPURPOSE OF SETTLING THIS ACTION, PRIOR TO HEARING, WITHOUTADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ALLEGATIONS, FACTS, CONCLUSIONS ORFINDINGS, WCM CONSENTS TO FOLLOWING FINDINGS: 1.VIOLATEDEXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATE TRADINGINFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETSIN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERETO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OFOUR BUSINESS AFFAIRS IN THAT WACHOVIA CAPITAL MARKETS, LLCSUBMITTED INACCURATE TRADING INFORMATION ON ELECTRONIC BLUESHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS ANDPROCEDURES FOR THE SUPERVISION AND CONTROL OF AREASRESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH EXCHANGE RULES RELATING TO THE PREPARATIONAND SUBMISSION OF ELECTRONIC BLUE SHEETS. STIPULATED SANCTION:THE IMPOSITION BY THE EXCHANGE OF A CENSURE, A $500,000 FINE ANDA REQUIREMENT THAT WACHOVIA CAPITAL MARKETS, LLC WILL CONDUCTA VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS INACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.











CENSURE AND A REQUIREMENT THAT WACHOVIA CAPITAL MARKETS, LLC,WILL CONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATAELEMENTS IN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG2005-01.


Docket/Case Number: HPD# 05-160



**9/28/05** SUBMITTED A STIPULATION OF FACTS AND CONSENT TOPENALTY TO NYSE DIVISION OF ENFORCEMENT TO RESOLVE AREGULATORY SWEEP INVOLVING MORE THAN 20 FIRMS FOR ALLEGEDLYSUBMITTING INACCURATE SHORT SALE INFORMATION TO NYSE VIAELECTRONIC BLUE SHEET SUBMISSIONS. SETTLEMENT OF THIS MATTERIS PENDING ACCEPTANCE BY NYSE HEARING PANEL. FOR THE SOLEPURPOSE OF SETTLING THIS ACTION, PRIOR TO HEARING, WITHOUTADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ALLEGATIONS, FACTS, CONCLUSIONS ORFINDINGS, WCM CONSENTS TO FOLLOWING FINDINGS: 1.VIOLATEDEXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATE TRADINGINFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETSIN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERETO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OFOUR BUSINESS AFFAIRS IN THAT WACHOVIA CAPITAL MARKETS, LLCSUBMITTED INACCURATE TRADING INFORMATION ON ELECTRONIC BLUESHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS ANDPROCEDURES FOR THE SUPERVISION AND CONTROL OF AREASRESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH EXCHANGE RULES RELATING TO THE PREPARATIONAND SUBMISSION OF ELECTRONIC BLUE SHEETS. STIPULATED SANCTION:THE IMPOSITION BY THE EXCHANGE OF A CENSURE, A $500,000 FINE ANDA REQUIREMENT THAT WACHOVIA CAPITAL MARKETS, LLC WILL CONDUCTA VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS INACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.


Resolution:

Other Sanctions Ordered: A REQUIREMENT THAT WACHOVIA CAPITAL MARKETS, LLC, WILL CONDUCTA VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS INACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.

Sanction Details: CENSURE AND $500,000.00 FINE AGAINST WACHOVIA CAPITAL MARKETS,LLC. THE FINE WAS PAID ON 3/2/2006.




i


Allegations: VIOLATION OF SEC RULE 11AC1-6(B). FOR THE FOURTH QUARTER OF 2003,AND THE FIRST QUARTER 2004, THE FIRM MADE AVAILABLE REPORTS ONITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIESDURING THE RESPECTIVE QUARTERS. THESE REPORTS INCLUDEDINCORRECT OR INCOMPLETE INFORMATION TO THE IDENTITY OF THE TENVENUES TO WHICH THE LARGEST NUMBER OF TOTAL NON-DIRECTEDORDERS WERE ROUTED FOR EXECUTION AND OF ANY VENUE TO WHICHFIVE PERCENT OR MORE OF NON-DIRECTED ORDERS WERE ROUTED FOREXECUTION, THE PERCENTAGE OF TOTAL NON-DIRECTED ORDERSROUTED TO THE VENUE, AND THE PERCENTAGES OF TOTAL NON-DIRECTED MARKET ORDERS, TOTAL NON-DIRECTED LIMIT ORDERS, ANDTOTAL NON-DIRECTED OTHER ORDERS THAT WERE ROUTED TO THEVENUE; AND A DISCUSSION OF THE MATERIAL ASPECTS OF THE FIRM'SRELATIONSHIP WITH EACH OF THE TEN VENUES TO WHICH THELARGERST NUMBER OF TOTAL NON-DIRECTED ORDERS WERE ROUTEDFOR EXECUTION, INCLUDING A DESCRIPTION OF ANY ARRANGEMENT FORPAYMENT FOR ORDER FLOW AND ANY PROFIT-SHARING RELATIONSHIP.







Initiated By: NASD




Docket/Case Number: CMS040205



VIOLATION OF SEC RULE 11AC1-6(B). FOR THE FOURTH QUARTER OF 2003,AND THE FIRST QUARTER 2004, THE FIRM MADE AVAILABLE REPORTS ONITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIESDURING THE RESPECTIVE QUARTERS. THESE REPORTS INCLUDEDINCORRECT OR INCOMPLETE INFORMATION TO THE IDENTITY OF THE TENVENUES TO WHICH THE LARGEST NUMBER OF TOTAL NON-DIRECTEDORDERS WERE ROUTED FOR EXECUTION AND OF ANY VENUE TO WHICHFIVE PERCENT OR MORE OF NON-DIRECTED ORDERS WERE ROUTED FOREXECUTION, THE PERCENTAGE OF TOTAL NON-DIRECTED ORDERSROUTED TO THE VENUE, AND THE PERCENTAGES OF TOTAL NON-DIRECTED MARKET ORDERS, TOTAL NON-DIRECTED LIMIT ORDERS, ANDTOTAL NON-DIRECTED OTHER ORDERS THAT WERE ROUTED TO THEVENUE; AND A DISCUSSION OF THE MATERIAL ASPECTS OF THE FIRM'SRELATIONSHIP WITH EACH OF THE TEN VENUES TO WHICH THELARGERST NUMBER OF TOTAL NON-DIRECTED ORDERS WERE ROUTEDFOR EXECUTION, INCLUDING A DESCRIPTION OF ANY ARRANGEMENT FORPAYMENT FOR ORDER FLOW AND ANY PROFIT-SHARING RELATIONSHIP.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS FINED $5,000.


No




Allegations: SANCTIONED FOR TECHNICAL VIOLATION OF SEC RULE 11AC 1-6.VIOLATION STEMMED FROM THE INTEGRATION OF NEW TRADING SYSTEMAND RESULTED IN AN ERRONEOUS STATISTIC IN A SINGLE DATA FIELDRELATED TO ORDER ROUTING VENUE.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS





Docket/Case Number: CMS040205

Principal Product Type: Equity - OTC


SANCTIONED FOR TECHNICAL VIOLATION OF SEC RULE 11AC 1-6.VIOLATION STEMMED FROM THE INTEGRATION OF NEW TRADING SYSTEMAND RESULTED IN AN ERRONEOUS STATISTIC IN A SINGLE DATA FIELDRELATED TO ORDER ROUTING VENUE.


Resolution:


Sanction Details: $5000 FINE PAID BY APPLICANT ON DECEMBER 23, 2004.

Firm Statement FINE PAID








Civil - Final

This type of disclosure event involves (1) an injunction issued by a foreign or domestic court within the last 10 years inconnection with investment-related activity, (2) a finding by a court of a violation of any investment-related statute orregulation, or (3) an action dismissed by a court pursuant to a settlement agreement.

Disclosure 1 of 1


SEC LITIGATION RELEASE 23480 / MARCH 7, 2016: THE SECURITIES ANDEXCHANGE COMMISSION CHARGED A RHODE ISLAND AGENCY AND ITSBOND UNDERWRITER WELLS FARGO SECURITIES WITH DEFRAUDINGINVESTORS IN A MUNICIPAL BOND OFFERING TO FINANCE STARTUP AVIDEO GAME COMPANY. THE RHODE ISLAND ECONOMIC DEVELOPMENTCORPORATION (RIEDC, NOW CALLED THE RHODE ISLAND COMMERCECORPORATION) ISSUED $75 MILLION IN BONDS FOR THE VIDEO GAMECOMPANY'S PROJECT AS PART OF A STATE GOVERNMENT PROGRAMINTENDED TO SPUR ECONOMIC DEVELOPMENT AND INCREASEEMPLOYMENT OPPORTUNITIES BY LOANING BOND PROCEEDS TOPRIVATE COMPANIES. THE SEC'S COMPLAINT CHARGES WELLS FARGOWITH VIOLATIONS OF SECTIONS 17(A)(2) AND (A)(3) OF THE SECURITIESACT OF 1933. WELLS FARGO ALSO IS CHARGED WITH VIOLATIONS OFSECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 ANDRULES G-17 AND G-32 OF THE MUNICIPAL SECURITIES RULEMAKINGBOARD (MSRB).ACCORDING TO THE SEC'S COMPLAINT, FILED IN FEDERAL DISTRICTCOURT IN PROVIDENCE, THE RIEDC LOANED $50 MILLION IN BONDPROCEEDS TO THE COMPANY. REMAINING PROCEEDS WERE USED TOPAY RELATED BOND OFFERING EXPENSES AND ESTABLISH A RESERVEFUND AND A CAPITALIZED INTEREST FUND. THE LOAN AND, IN TURN,BOND INVESTORS WOULD BE REPAID FROM REVENUES GENERATED BYVIDEO GAMES THAT THE COMPANY PLANNED TO DEVELOP. THE BONDOFFERING DOCUMENT PRODUCED BY THE RIEDC AND WELLS FARGOFAILED TO DISCLOSE TO INVESTORS THAT THE COMPANY HAD CONVEYEDIT NEEDED AT LEAST $75 MILLION IN FUNDING TO PRODUCE APARTICULAR VIDEO GAME. THEREFORE, INVESTORS WEREN'T FULLYINFORMED WHEN DECIDING TO PURCHASE THE BONDS THAT THECOMPANY FACED A FUNDING SHORTFALL EVEN WITH THE LOANPROCEEDS AND COULD NOT DEVELOP THE VIDEO GAME WITHOUTADDITIONAL SOURCES OF FINANCING. WHEN THE COMPANY WAS LATERUNABLE TO OBTAIN ADDITIONAL FINANCING, THE VIDEO GAME DIDN'TMATERIALIZE AND THE COMPANY DEFAULTED ON THE LOAN.THE SEC'S COMPLAINT FURTHER ALLEGES THAT WELLS FARGO AND ITSLEAD BANKER ON THE DEAL MISLED INVESTORS IN AN ADDITIONAL WAYIN BOND OFFERING MATERIALS. WELLS FARGO DISCLOSED ITS BONDOFFERING COMPENSATION AS A SHARE OF THE PLACEMENT AGENT FEEPLUS A $50,000 PAYMENT FROM THE COMPANY. NO OTHER FEES ORCOMPENSATION TO WELLS FARGO WERE DISCLOSED, AND THE BONDPLACEMENT AGREEMENT STATED THAT NO OTHER MONEY WASANTICIPATED. INVESTORS WEREN'T INFORMED THAT WELLS FARGO HAD ASIDE DEAL WITH THE COMPANY THAT ENABLED THE FIRM TO RECEIVENEARLY DOUBLE THE AMOUNT OF COMPENSATION DISCLOSED INOFFERING DOCUMENTS. THIS ADDITIONAL COMPENSATION, TOTALING$400,000 AND PAID FROM BOND PROCEEDS, CREATED A CONFLICT OFINTEREST THAT WELLS FARGO SHOULD HAVE DISCLOSED TO BONDINVESTORS. THE LEAD BANKER ON THE DEAL WAS RESPONSIBLE FORWELLS FARGO'S FAILURE TO DISCLOSE ITS ADDITIONAL FEES. THE SEC'SLITIGATION CONTINUES AGAINST WELLS FARGO.

Allegations:







Initiated By: THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Relief Sought: Injunction

Other Relief Sought:

Date Court Action Filed: 03/07/2016


Other Product Types:

Court Details: THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODEISLAND; RHODE ISLAND; CIVIL ACTION NO. 1:16-CV-107

SEC LITIGATION RELEASE 23480 / MARCH 7, 2016: THE SECURITIES ANDEXCHANGE COMMISSION CHARGED A RHODE ISLAND AGENCY AND ITSBOND UNDERWRITER WELLS FARGO SECURITIES WITH DEFRAUDINGINVESTORS IN A MUNICIPAL BOND OFFERING TO FINANCE STARTUP AVIDEO GAME COMPANY. THE RHODE ISLAND ECONOMIC DEVELOPMENTCORPORATION (RIEDC, NOW CALLED THE RHODE ISLAND COMMERCECORPORATION) ISSUED $75 MILLION IN BONDS FOR THE VIDEO GAMECOMPANY'S PROJECT AS PART OF A STATE GOVERNMENT PROGRAMINTENDED TO SPUR ECONOMIC DEVELOPMENT AND INCREASEEMPLOYMENT OPPORTUNITIES BY LOANING BOND PROCEEDS TOPRIVATE COMPANIES. THE SEC'S COMPLAINT CHARGES WELLS FARGOWITH VIOLATIONS OF SECTIONS 17(A)(2) AND (A)(3) OF THE SECURITIESACT OF 1933. WELLS FARGO ALSO IS CHARGED WITH VIOLATIONS OFSECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 ANDRULES G-17 AND G-32 OF THE MUNICIPAL SECURITIES RULEMAKINGBOARD (MSRB).ACCORDING TO THE SEC'S COMPLAINT, FILED IN FEDERAL DISTRICTCOURT IN PROVIDENCE, THE RIEDC LOANED $50 MILLION IN BONDPROCEEDS TO THE COMPANY. REMAINING PROCEEDS WERE USED TOPAY RELATED BOND OFFERING EXPENSES AND ESTABLISH A RESERVEFUND AND A CAPITALIZED INTEREST FUND. THE LOAN AND, IN TURN,BOND INVESTORS WOULD BE REPAID FROM REVENUES GENERATED BYVIDEO GAMES THAT THE COMPANY PLANNED TO DEVELOP. THE BONDOFFERING DOCUMENT PRODUCED BY THE RIEDC AND WELLS FARGOFAILED TO DISCLOSE TO INVESTORS THAT THE COMPANY HAD CONVEYEDIT NEEDED AT LEAST $75 MILLION IN FUNDING TO PRODUCE APARTICULAR VIDEO GAME. THEREFORE, INVESTORS WEREN'T FULLYINFORMED WHEN DECIDING TO PURCHASE THE BONDS THAT THECOMPANY FACED A FUNDING SHORTFALL EVEN WITH THE LOANPROCEEDS AND COULD NOT DEVELOP THE VIDEO GAME WITHOUTADDITIONAL SOURCES OF FINANCING. WHEN THE COMPANY WAS LATERUNABLE TO OBTAIN ADDITIONAL FINANCING, THE VIDEO GAME DIDN'TMATERIALIZE AND THE COMPANY DEFAULTED ON THE LOAN.THE SEC'S COMPLAINT FURTHER ALLEGES THAT WELLS FARGO AND ITSLEAD BANKER ON THE DEAL MISLED INVESTORS IN AN ADDITIONAL WAYIN BOND OFFERING MATERIALS. WELLS FARGO DISCLOSED ITS BONDOFFERING COMPENSATION AS A SHARE OF THE PLACEMENT AGENT FEEPLUS A $50,000 PAYMENT FROM THE COMPANY. NO OTHER FEES ORCOMPENSATION TO WELLS FARGO WERE DISCLOSED, AND THE BONDPLACEMENT AGREEMENT STATED THAT NO OTHER MONEY WASANTICIPATED. INVESTORS WEREN'T INFORMED THAT WELLS FARGO HAD ASIDE DEAL WITH THE COMPANY THAT ENABLED THE FIRM TO RECEIVENEARLY DOUBLE THE AMOUNT OF COMPENSATION DISCLOSED INOFFERING DOCUMENTS. THIS ADDITIONAL COMPENSATION, TOTALING$400,000 AND PAID FROM BOND PROCEEDS, CREATED A CONFLICT OFINTEREST THAT WELLS FARGO SHOULD HAVE DISCLOSED TO BONDINVESTORS. THE LEAD BANKER ON THE DEAL WAS RESPONSIBLE FORWELLS FARGO'S FAILURE TO DISCLOSE ITS ADDITIONAL FEES. THE SEC'SLITIGATION CONTINUES AGAINST WELLS FARGO.

Resolution: Judgment Rendered


Other Sanctions:

Sanction Details: ON MARCH 20, 2019 A FINAL JUDGMENT WAS ENTERED AGAINST WELLSFARGO WHEREIN IT WAS PERMANENTLY RESTRAINED AND ENJOINEDFROM VIOLATING SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933,SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 ANDRULE G-17 PROMULGATED BY THE MUNICIPAL SECURITIES RULEMAKINGBOARD.WELLS FARGO IS LIABLE FOR A CIVIL PENALTY IN THE AMOUNT OF$812,500.

Monetary/Fine $812,500.00Cease and Desist/Injunction

Sanctions Ordered or ReliefGranted:








IN A MATTER BROUGHT IN FEDERAL DISTRICT COURT FOR THE DISTRICTOF RHODE ISLAND ON MARCH 7, 2016, THE SECURITIES AND EXCHANGECOMMISSION ("SEC") CHARGED A RHODE ISLAND AGENCY AND ITS BONDUNDERWRITER WELLS FARGO SECURITIES, LLC ("WFS"), A WFS BANKER,AND CERTAIN OTHER INDIVIDUALS WITH DEFRAUDING INVESTORS IN AMUNICIPAL BOND OFFERING TO FINANCE A STARTUP VIDEO GAMECOMPANY ("COMPANY"). THE RHODE ISLAND ECONOMIC DEVELOPMENTCORPORATION ("RIEDC", NOW CALLED THE RHODE ISLAND COMMERCECORPORATION) ISSUED $75 MILLION IN BONDS FOR THE COMPANY'SPROJECT AS PART OF A STATE GOVERNMENT PROGRAM INTENDED TOSPUR ECONOMIC DEVELOPMENT AND INCREASE EMPLOYMENTOPPORTUNITIES BY LOANING BOND PROCEEDS TO PRIVATE COMPANIES.THE COMPLAINT, AS AMENDED ON OCTOBER 28, 2016, CHARGES WFSWITH VIOLATIONS OF SECTIONS 17(A)(2) AND (A)(3) OF THE SECURITIESACT OF 1933 ("SECURITIES ACT"). WFS ALSO IS CHARGED WITHVIOLATIONS OF SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACTOF 1934 ("EXCHANGE ACT") AND RULES G-17 AND G-32 OF THE MUNICIPALSECURITIES RULEMAKING BOARD ("MSRB"). ACCORDING TO THEAMENDED COMPLAINT, THE RIEDC LOANED $50 MILLION IN BONDPROCEEDS TO THE COMPANY. REMAINING PROCEEDS WERE USED TOPAY RELATED BOND OFFERING EXPENSES AND ESTABLISH A RESERVEFUND AND A CAPITALIZED INTEREST FUND. THE COMPANY WOULD USEREVENUES GENERATED BY VIDEO GAMES THAT THE COMPANY PLANNEDTO DEVELOP TO MAKE LOAN PAYMENTS AND THE RIEDC WOULD USETHESE PAYMENTS TO MAKE PAYMENTS TO INVESTORS. THE BONDOFFERING DOCUMENT PRODUCED BY THE RIEDC AND WFS ALLEGEDLYFAILED TO DISCLOSE TO INVESTORS THAT THE COMPANY HAD CONVEYEDIT NEEDED AT LEAST $75 MILLION IN FUNDING TO PRODUCE APARTICULAR VIDEO GAME. THEREFORE, THE AMENDED COMPLAINTALLEGES, INVESTORS WERE NOT FULLY INFORMED WHEN DECIDING TOPURCHASE THE BONDS THAT THE COMPANY FACED A FUNDINGSHORTFALL EVEN WITH THE LOAN PROCEEDS AND COULD NOT DEVELOPTHE VIDEO GAME WITHOUT ADDITIONAL SOURCES OF FINANCING. THEAMENDED COMPLAINT ALLEGES THAT THE COMPANY WAS ULTIMATELYUNABLE TO OBTAIN ADDITIONAL FINANCING TO COMPLETE THE VIDEOGAME AND THE COMPANY DEFAULTED ON THE LOAN. THE AMENDEDCOMPLAINT FURTHER ALLEGES THAT WFS MISLED INVESTORS IN ANADDITIONAL WAY IN BOND OFFERING MATERIALS. WFS DISCLOSED ITSBOND OFFERING COMPENSATION AS A SHARE OF THE PLACEMENTAGENT FEE PLUS A $50,000 PAYMENT FROM THE COMPANY. NO OTHERFEES OR COMPENSATION TO WFS WERE DISCLOSED, AND THE BONDPLACEMENT AGREEMENT STATED THAT NO OTHER MONEY WASANTICIPATED. THE AMENDED COMPLAINT ALLEGES INVESTORS WERENOT INFORMED THAT WFS HAD A SIDE DEAL WITH THE COMPANY THATENABLED THE FIRM TO RECEIVE NEARLY DOUBLE THE AMOUNT OFCOMPENSATION DISCLOSED IN OFFERING DOCUMENTS. THE AMENDEDCOMPLAINT ALLEGES THIS ADDITIONAL COMPENSATION, TOTALING$400,000 AND PAID FROM BOND PROCEEDS, CREATED A CONFLICT OFINTEREST THAT WFS SHOULD HAVE DISCLOSED TO BOND INVESTORS.THE COMPLAINT ALLEGES THAT THE WFS BANKER AIDED AND ABETTEDTHE WFS VIOLATIONS.

Allegations:






Initiated By: THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Relief Sought: Injunction

Other Relief Sought:

Date Court Action Filed: 03/07/2016


Other Product Types:

Court Details: THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODEISLAND; PROVIDENCE, RHODE ISLAND: CIVIL ACTION NO. 1:16-CV-107

IN A MATTER BROUGHT IN FEDERAL DISTRICT COURT FOR THE DISTRICTOF RHODE ISLAND ON MARCH 7, 2016, THE SECURITIES AND EXCHANGECOMMISSION ("SEC") CHARGED A RHODE ISLAND AGENCY AND ITS BONDUNDERWRITER WELLS FARGO SECURITIES, LLC ("WFS"), A WFS BANKER,AND CERTAIN OTHER INDIVIDUALS WITH DEFRAUDING INVESTORS IN AMUNICIPAL BOND OFFERING TO FINANCE A STARTUP VIDEO GAMECOMPANY ("COMPANY"). THE RHODE ISLAND ECONOMIC DEVELOPMENTCORPORATION ("RIEDC", NOW CALLED THE RHODE ISLAND COMMERCECORPORATION) ISSUED $75 MILLION IN BONDS FOR THE COMPANY'SPROJECT AS PART OF A STATE GOVERNMENT PROGRAM INTENDED TOSPUR ECONOMIC DEVELOPMENT AND INCREASE EMPLOYMENTOPPORTUNITIES BY LOANING BOND PROCEEDS TO PRIVATE COMPANIES.THE COMPLAINT, AS AMENDED ON OCTOBER 28, 2016, CHARGES WFSWITH VIOLATIONS OF SECTIONS 17(A)(2) AND (A)(3) OF THE SECURITIESACT OF 1933 ("SECURITIES ACT"). WFS ALSO IS CHARGED WITHVIOLATIONS OF SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACTOF 1934 ("EXCHANGE ACT") AND RULES G-17 AND G-32 OF THE MUNICIPALSECURITIES RULEMAKING BOARD ("MSRB"). ACCORDING TO THEAMENDED COMPLAINT, THE RIEDC LOANED $50 MILLION IN BONDPROCEEDS TO THE COMPANY. REMAINING PROCEEDS WERE USED TOPAY RELATED BOND OFFERING EXPENSES AND ESTABLISH A RESERVEFUND AND A CAPITALIZED INTEREST FUND. THE COMPANY WOULD USEREVENUES GENERATED BY VIDEO GAMES THAT THE COMPANY PLANNEDTO DEVELOP TO MAKE LOAN PAYMENTS AND THE RIEDC WOULD USETHESE PAYMENTS TO MAKE PAYMENTS TO INVESTORS. THE BONDOFFERING DOCUMENT PRODUCED BY THE RIEDC AND WFS ALLEGEDLYFAILED TO DISCLOSE TO INVESTORS THAT THE COMPANY HAD CONVEYEDIT NEEDED AT LEAST $75 MILLION IN FUNDING TO PRODUCE APARTICULAR VIDEO GAME. THEREFORE, THE AMENDED COMPLAINTALLEGES, INVESTORS WERE NOT FULLY INFORMED WHEN DECIDING TOPURCHASE THE BONDS THAT THE COMPANY FACED A FUNDINGSHORTFALL EVEN WITH THE LOAN PROCEEDS AND COULD NOT DEVELOPTHE VIDEO GAME WITHOUT ADDITIONAL SOURCES OF FINANCING. THEAMENDED COMPLAINT ALLEGES THAT THE COMPANY WAS ULTIMATELYUNABLE TO OBTAIN ADDITIONAL FINANCING TO COMPLETE THE VIDEOGAME AND THE COMPANY DEFAULTED ON THE LOAN. THE AMENDEDCOMPLAINT FURTHER ALLEGES THAT WFS MISLED INVESTORS IN ANADDITIONAL WAY IN BOND OFFERING MATERIALS. WFS DISCLOSED ITSBOND OFFERING COMPENSATION AS A SHARE OF THE PLACEMENTAGENT FEE PLUS A $50,000 PAYMENT FROM THE COMPANY. NO OTHERFEES OR COMPENSATION TO WFS WERE DISCLOSED, AND THE BONDPLACEMENT AGREEMENT STATED THAT NO OTHER MONEY WASANTICIPATED. THE AMENDED COMPLAINT ALLEGES INVESTORS WERENOT INFORMED THAT WFS HAD A SIDE DEAL WITH THE COMPANY THATENABLED THE FIRM TO RECEIVE NEARLY DOUBLE THE AMOUNT OFCOMPENSATION DISCLOSED IN OFFERING DOCUMENTS. THE AMENDEDCOMPLAINT ALLEGES THIS ADDITIONAL COMPENSATION, TOTALING$400,000 AND PAID FROM BOND PROCEEDS, CREATED A CONFLICT OFINTEREST THAT WFS SHOULD HAVE DISCLOSED TO BOND INVESTORS.THE COMPLAINT ALLEGES THAT THE WFS BANKER AIDED AND ABETTEDTHE WFS VIOLATIONS.

Date Notice/Process Served: 03/08/2016

Resolution: Judgment Rendered


Other Sanctions: INJUNCTION

Sanction Details: WITHOUT WFS ADMITTING OR DENYING THE SEC'S ALLEGATIONS, WFSCHOSE TO SETTLE THE MATTER. ON MARCH 20, 2019 A FINAL JUDGMENTWAS ENTERED AGAINST WFS WHEREIN ITWAS ENJOINED FROM VIOLATING SECTION 17(A)(2) OF THE SECURITIESACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT AND MSRB RULE G-17,AND WAS ORDERED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $812,500.THE SEC DISMISSED THE CLAIMS ALLEGING VIOLATIONS OF SECTION17(A)(3) OF THE SECURITIES ACT AND MRSB RULE G-32.

Monetary/Fine $812,500.00Sanctions Ordered or ReliefGranted:






End of Report

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