RAYMOND JAMES & ASSOCIATES

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") AND RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC. ("RJFSA") VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND RULE 206(4)-7 THEREUNDER, BY FAILING TO CONDUCT PROMISED SUITABILITY REVIEWS FOR CERTAIN ADVISORY ACCOUNTS, FAILING TO ADOPT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS CONCERNING THE SUITABILITY OF FEE-BASED ADVISORY ACCOUNTS, AND OVERVALUING CERTAIN ASSETS THAT RESULTED IN CHARGING EXCESS ADVISORY FEES. THE SEC ALSO ALLEGED THAT RJA AND RAYMOND JAMES FINANCIAL SERVICES, INC. ("RJFS") VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") BY FAILING TO HAVE A REASONABLE BASIS FOR RECOMMENDING CERTAIN UNIT INVESTMENT TRUST TRANSACTIONS TO BROKERAGE CUSTOMERS, AND FAILING TO DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH EARNING GREATER COMPENSATION WHEN RECOMMENDING CERTAIN SECURITIES WITHOUT PROVIDING APPLICABLE SALES-LOAD DISCOUNTS TO BROKERAGE CUSTOMERS.

Sanction: Cease and Desist

How it ended: Order

Detail: "IN THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $3,000,000, WHICH WAS PAID ON 09/25/2019, AND REQUIRED TO PAY DISGORGEMENT OF $11,098,349.01. DISGORGEMENT PAID TO OPEN ACCOUNTS ON 9/9 AND CLOSED ACCOUNTS ON 9/16

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, RJA, RJFS, AND RJFSA CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER") (RELEASE NO. 86985, SEPT. 17, 2019). PURSUANT TO THE ORDER RJA AND RJFS MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT; RJA AND RJFSA MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ALSO PURSUANT TO THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED AND MUST PAY DISGORGEMENT, PREJUDMENT INTEREST AND A CIVIL MONEY PENALTY TOTALING $15,171,113.81. IN DETERMINING TO ACCEPT RAYMOND JAMES' OFFER OF A SETTLEMENT, THE SEC TOOK INTO CONSIDERATION CERTAIN REMEDIAL EFFORTS PROMPTLY TAKEN BY, AND THE COOPERATION OF, RAYMOND JAMES.

Resolved: Sep 17, 2019

Allegations: DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS.

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

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS FINED $5000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.

Summary: DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS. THERE WAS A MONETARY FINE OF $5,000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.

Resolved: May 20, 2015

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANY CONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES.

Sanction: Other

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM IS CENSURED, ORDERED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,489,553.70 TO CUSTOMERS, AND WITH RESPECT TO ANY CUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES IN AN ACCOUNT AT THE FIRM, THE FIRM UNDERTAKES TO OFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS A SHARES AT NO EXPENSE TO THE CUSTOMER.

Resolved: Jul 6, 2015

Allegations: STATE OF HAWAII ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF HRS 485-15(7). FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF HRS 485-15(10). RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERS AUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELY CHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS. ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSED THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMES WAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE, SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELY DESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSING THE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARS AUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THAT LEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMOND JAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOME INSTANCES, NOT BEEN ABLE TO LIQUIDATE.

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

How it ended: Stipulation and Consent

Detail: ON 9/16/2014, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF $3,972.17 TO THE TREASURER OF STATE OF HAWAII.

Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMES FINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF HAWAII ON 9/16/2014, IN WHICH IT CONSENTED: (I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS. (II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS. (III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERS WHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHO TRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIOR TO JANUARY 1, 2006. (IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLE INTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOK OUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECURED BY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THE TIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITH THE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTAL INTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THE DURATION OF THE LOAN. (V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHO PURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANY SUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLE INTEREST.

Resolved: Sep 16, 2014

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT OVER REPORTED TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES TO THE OVER THE COUNTER REPORTING FACILITY (OTCRF) THAT WERE EXECUTED IN CANADA AND ALSO REPORTED TO THE REGULATOR OF SECURITIES MARKETS FOR THAT COUNTRY. THE FINDINGS STATED THAT THE UNDERLYING SECURITIES WERE DUALLY LISTED IN THE UNITED STATES AND IN CANADA. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRADE REPORTING OF TRANSACTIONS INVOLVING SECURITIES THAT ARE DUALLY LISTED IN THE UNITED STATES AND ANOTHER COUNTRY.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED, FINED $12,500, AND UNDERTAKES TO REVISE ITS WSPS. THE FINE WAS PAID ON 7/28/16, AND WSPS WERE REVISED ON 4/6/2015.

Resolved: Jul 15, 2016

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTED AND HELD CUSTOMER ORDERS TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER ORDERS, AND FAILED TO EXECUTE OR IMMEDIATELY EXECUTE THE CUSTOMER ORDERS IN OVER-THE COUNTER (OTC) SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGS STATED THAT IN SEVERAL INSTANCES THE FIRM FAILED TO MAKE EVERY EFFORT TO CROSS A MARKETABLE CUSTOMER ORDER WITH ANOTHER ORDER RECEIVED BY THE FIRM ON THE OPPOSITE SIDE OF THE MARKET. FURTHER, ON MULTIPLE OCCASIONS INVOLVING EITHER A TRADING AHEAD AND/OR CROSSING FAILURE, THE FIRM FAILED TO EXECUTE A MARKETABLE CUSTOMER ORDER FULLY AND PROMPTLY.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS FINED $5000.00, AND ORDERED TO PAY $601.83, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. THE FINE WAS PAID ON 10/4/16.

Resolved: Sep 20, 2016

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO PUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTEN SUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDING FINRA RULE 6460.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED, FINED $30,000 AND UNDERTAKES TO REVISE ITS WSPS WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, AND WITHIN 30 BUSINESS DAYS OF THE AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATED LETTER, OR AN E- MAIL PROVIDING THE FOLLOWING INFORMATION: A REFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS, TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC; AND, THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. PAYMENT WAS SENT ON 9/28/16.

Resolved: Sep 12, 2016

Allegations: VIOLATION OF 9 VERMONT SECURITIES ACT (VSA) 5412(D)(9)

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

How it ended: Order

Detail: RJA SHALL CEASE AND DESIST FROM VIOLATING SECTION 5412(D)(9) OF THE VERMONT UNIFORM SECURITIES ACT (VUSA) AND WILL COMPLY WITH ALL APPLICABLE PROVISIONS OF THE VUSA. WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER, RJA SHALL PAY TO THE DEPARTMENT OF FINANCIAL REGULATION (DFR) THE SUM OF $1,450,0000, OF WHICH $1,250,000 REPRESENTS AN ADMINISTRATIVE PENALTY AND $200,000 SHALL REIMBURSE THE OFR FOR ITS COSTS. THE COMMISSIONER DIRECTS THAT WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER RJA PAY $4,500,000 TO THE RECEIVER APPOINTED IN THE MATTER ENTITLED SEC V. QUIROS, NO.1:16-CV-21301-DPG (S.D. FLA.) FOR THE SOLE PURPOSE OF REIMBURSING CLAIMS BY THE EB-5 INVESTORS. THE SUM OF $2,750,000 REPRESENTS THE TOTAL REVENUES EARNED BY RJA AND THE REGISTERED REPRESENTATIVE IN CONNECTION WITH THE QUIROS-CONTROLLED ACCOUNTS, AND THE BALANCE REPRESENTS RESTITUTION. THE FINES WERE PAID ON JULY 7, 2016.

Resolved: Jun 29, 2016

Allegations: THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S ("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES RELATING TO TRADING COMMISSIONS CHARGED TO CLIENTS PARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS") SEPARATELY MANAGED ACCOUNT PROGRAM. UNDER THE RJCS PROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TO DEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELY MANAGED ACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE, RJA CLIENTS ALSO WERE ASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA. ALTHOUGH RJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENT MANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH RJA AND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILL BE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOT OBTAIN INFORMATION REGARDING THE AMOUNT OF COMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WAS MATERIAL. INSTEAD, RJA RECEIVED INFORMATION REGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITY COMMISSION COST INCLUDED IN THE PRICE OF THE SECURITY. RJCS PROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING AWAY BECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATION ABOUT COMMISSIONS FROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO ALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULAR INVESTMENT MANAGERS WERE SUITABLE FOR ITS PROSPECTIVE AND EXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDING COMMISSIONS ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THE INVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVE ADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAP FEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM; AND (III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERS TO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER.

How it ended: Order

Detail: THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WAS PAID ON 10/12/16.

Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.

Resolved: Sep 8, 2016

Allegations: N/A

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

How it ended: Order

Detail: 03/09/2017 - $10,000 ADMINISTRATIVE FINE PAID IN FULL.

Summary: ON MARCH 9, 2017, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER AGAINST RAYMOND JAMES & ASSOCIATES, INC., ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC., ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE FINDINGS BY THE OFFICE. THE FINDINGS BY THE OFFICE OF FINANCIAL REGULATION INCLUDE A FAILURE TO EXAMINE A NON-REGISTERED RESIDENCE LOCATION ("NRL"), CREATE AND MAINTAIN WSPS FOR SUCH NRL, AND MAINTAIN WRITTEN REPORTS OF ITS INSPECTION AND REVIEW OF ITS NRLS.

Resolved: Mar 9, 2017

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT LACKED A REASONABLE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS, INCLUDING ONGOING REVIEWS OF DAILY TRADE BLOTTERS OF ITS CONVERTIBLE BONDS DESK FOR SPECIFIC TRADING PATTERNS. THE FINDINGS STATED THAT THE FIRM'S CONVERTIBLE BONDS DESK, IN 99 INSTANCES, SOLD BONDS TO ANOTHER BROKER-DEALER IN A PRINCIPAL CAPACITY AND CONCURRENTLY (WITHIN A FEW MINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN AN AGENCY CAPACITY FOR A FIRM ADVISORY CLIENT OR CLIENTS, OR PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR AN ADVISORY CLIENT OR ADVISORY CLIENTS OF THE FIRM'S AFFILIATE. SINCE THE FIRM'S CONVERTIBLE BONDS WERE OFFERED ON A CONDITIONAL BASIS, ITS CONVERTIBLE BONDS DESK NEEDED TO MANUALLY ACCEPT ANY ATTEMPT BY A THIRD PARTY TO LIFT ITS OFFER OFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THE CONVERTIBLE BONDS DESK KNEW THAT THERE WAS AN ATTEMPT TO LIFT THE FIRM'S INVENTORY FOR THE EXACT SAME QUANTITY OF THE SAME CONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TO BUY SUCH BONDS FOR AN ADVISORY CLIENT. WHILE THE FIRM'S WSPS PERTAINING TO MANAGED ACCOUNTS GENERALLY PROHIBITED PRINCIPAL TRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION) AND ESTABLISHED TRADING SYSTEM FUNCTIONALITY LIMITATIONS TO PRECLUDE PRINCIPAL FILLS DIRECTLY FOR ADVISORY CLIENTS, THE FIRM'S SUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDS TRADING DID NOT INCLUDE, AMONG OTHER THINGS, ONGOING REVIEWS OF DAILY TRADE BLOTTERS THAT MIGHT DETECT POTENTIALLY VIOLATIVE CONDUCT SUCH AS THE SPECIFIC TRADING PATTERN AT ISSUE.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED, FINED $180,000 AND UNDERTAKES TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS. THE FINE WAS PAID ON MARCH 24, 2017.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HAD IMPROPERLY USED THE INTERNATIONAL SECURITIES EXCHANGE'S (ISE) SOLICITED ORDER MECHANISM (SOM) AND FAILED TO ADEQUATELY SUPERVISE IN CONNECTION WITH ITS USE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM IMPROPERLY USED THE SOM TO CROSS ORDERS THAT DID NOT INVOLVE SOLICITED CONTRA ORDERS ON 23 OCCASIONS DURING THE REVIEW PERIOD. THE FIRM FAILED TO HAVE ANY SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING WRITTEN SUPERVISORY PROCEDURES AND SEPARATE SYSTEMS OF FOLLOW-UP AND REVIEW, WHICH WERE DESIGNED TO ENSURE COMPLIANCE WITH ISE RULES RELATED TO THE PROPER USE OF THE SOM.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $20,000.00.

Summary: ASSOCIATED MATTER INCLUDES ISE FILE NOS. 2015-265, 2016-036, AND 2016-247.

Resolved: Jul 17, 2017

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT (LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM: ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN POSITIONS TO THE LOPR; AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017. REASONABLE WSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THE IDENTIFICATION OF THE INDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; (II) THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR; (III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW SUCH REVIEWS SHALL BE DOCUMENTED.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO THE EXCHANGE. THE FIRM WAS REQUIRED TO SUBMIT A WRITTEN REPORT WHICH CONFIRMS THAT IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED IN THE AWC WITHIN 120 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC. THE BALANCE OF THE FIRM'S FINE WILL BE PAID TO NYSE ARCA, INC., PURSUANT TO A SEPARATE SETTLEMENT AGREEMENT. THIS AWC BECAME FINAL ON JUNE 9, 2018.

Summary: IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS,PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES. CASE # 20140409820 (INCL. MERGED CASE NO. 20150455242)

Resolved: Jun 9, 2018

Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONS POSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343 INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCES WITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS IN APPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVERED QUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATE ACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTED POSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATE QUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.

Sanction: Censure

How it ended: Decision & Order of Offer of Settlement

Detail: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAINING AMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT A WRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THE DECISION.

Summary: IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, NYSE ARCA CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES.

Resolved: May 8, 2018

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN VIOLATION OF SEC RULE 15C3-5 AND NYSE RULE 3110(B)(1), THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF ITS BUSINESS ACTIVITY. THE FINDINGS STATED THAT THIS MATTER CONCERNS THE ESTABLISHMENT AND IMPLEMENTATION OF CREDIT LIMITS FOR THE ORDERS OF INSTITUTIONAL COUNTERPARTIES THAT WERE EFFECTED ON AN AGENCY BASIS (THE "CUSTOMER ORDERS"). THE FIRM DID NOT PROVIDE THESE CUSTOMERS DIRECT MARKET ACCESS, AND FIRM TRADERS MANUALLY ENTERED THE CUSTOMER ORDERS INTO THE NYSE SUPERDOT. THE FIRM DID NOT ALLOW CUSTOMERS TO ENTER ORDERS INTO NYSE SUPERDOT. THE FIRM FAILED TO SATISFY THE MARKET ACCESS RULE CREDIT THRESHOLD REQUIREMENTS WITH RESPECT TO THE CUSTOMER ORDERS BY ADOPTING AN UNREASONABLE METHODOLOGY FOR DETERMINING CUSTOMER CREDIT THRESHOLDS AND FAILING TO REASONABLY IMPLEMENT ITS CUSTOMER CREDIT THRESHOLDS. THE FIRM'S IMPLEMENTATION OF ITS PRE-TRADE CREDIT THRESHOLDS WAS ALSO UNREASONABLE. THE FIRM FAILED TO UNDERTAKE THE ANALYSIS NECESSARY FOR IT TO DETERMINE AN APPROPRIATE RISK RATING AND CORRESPONDING CREDIT LIMIT FOR CERTAIN FIRM CUSTOMERS. THE FIRM FAILED TO IMPLEMENT AN AUTOMATED PRE-TRADE BLOCK FOR CUSTOMERS NOTWITHSTANDING THAT THE FIRM HAD ASSIGNED SUCH CUSTOMERS A RISK RATING AND CREDIT LIMIT. THE FIRM ALSO FAILED ON CERTAIN INSTANCES TO CORRECTLY ENTER AUTOMATED PRE-TRADE CREDIT THRESHOLDS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO SATISFY BROKER-DEALERS REQUIREMENTS BY FAILING TO IMPLEMENT CERTAIN HARD LIMIT ERRONEOUS ORDER CONTROLS BASED ON THE INDIVIDUAL TRADING CHARACTERISTICS OF THE RELEVANT SECURITY, SHARE QUANTITY, OR A REASONABLE NOTIONAL QUANTITY, AND FAILING TO REASONABLY SUPERVISE THE OVERRIDING OF SOFT LIMIT ERRONEOUS ORDER CONTROLS. THE FIRM USED CERTAIN SOFT LIMITS. HOWEVER, THE FIRM FAILED TO TRAIN OR SUPERVISE ITS TRADERS WITH RESPECT TO THE OVERRIDING OF SUCH LIMITS, AND FAILED TO MAINTAIN ANY RECORDS OF WHEN FIRM TRADERS BYPASSED SUCH SOFT BLOCKS. THUS, THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REGULARLY REVIEW THE EFFECTIVENESS OF ITS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES. THE FIRM CONSIDERED ONLY WHETHER ITS CONTROLS WERE FUNCTIONING, NOT WHETHER THEY WERE APPROPRIATE OR EFFECTIVE GIVEN THE FIRM'S BUSINESS. IN ADDITION, THE FIRM'S MARKET ACCESS RULE REVIEWS FAILED TO INCLUDE AN ANALYSIS OF CUSTOMER CREDIT LIMITS OR AUTOMATED PRE-TRADE BLOCKS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $400,000.00 PAID NOVEMBER 30, 2018.

Summary: THE ACTION WAS SETTLED PURSUANT TO AN ACCEPTANCE, WAIVER AND CONSENT WITH THE NYSE FINALIZED ON NOVEMBER 16, 2018. PURSUANT TO THE AWC, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $400,000.

Resolved: Nov 16, 2018

Allegations: N/A

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

How it ended: Order

Detail: $1,000,000.00 ADMINISTRATIVE FINE PAID 10/8/2018

Summary: ON OCTOBER 8, 2018, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT RAYMOND JAMES & ASSOCIATES, INC. FAILED TO: MAINTAIN ACCURATE BOOKS AND RECORDS; ESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF REGISTERED REPRESENTATIVES AND PRINCIPALS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; HAVE AND CONDUCT INTERNAL INSPECTIONS THAT ARE REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF SECURITIES LAWS AND REGULATIONS; AND OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. IN ADDITION, RAYMOND JAMES & ASSOCIATES, INC. MADE DISCRETIONARY TRANSACTIONS IN CUSTOMERS' ACCOUNTS WITHOUT WRITTEN AUTHORIZATION. PURSUANT TO THE FINAL ORDER, RAYMOND JAMES & ASSOCIATES, INC. AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F. S. AND THE ADMINISTRATIVE RULES THEREUNDER; TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $1,000,000.00; AND TO FULLY COOPERATE IN ANY ADDITIONAL INVESTIGATIONS OR ADMINISTRATIVE ACTIONS RELATED TO THE EMPLOYEES OF THE RAYMOND JAMES & ASSOCIATES, INC. BRANCH LOCATED IN SUN CITY CENTER, FL THAT ARE RELATED TO THIS PROCEEDING TO TESTIFY AND ASSIST IN ANY FURTHER INVESTIGATION OR ADMINISTRATIVE PROCEEDING UPON THE REASONABLE REQUEST OF THE OFFICE, WITHOUT A SUBPOENA, AND AT RAYMOND JAMES'S EXPENSE OR THE EMPLOYEE'S EXPENSE.

Resolved: Oct 8, 2018

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS, REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' SHARE-CLASS RECOMMENDATIONS TO CUSTOMERS OF 529 SAVINGS PLANS. THE FINDINGS STATED THAT THE MATTER INVOLVES THE FIRM'S RESPECTIVE FAILURE TO SUPERVISE ITS ACTIVITIES TO ACHIEVE COMPLIANCE WITH ITS SUITABILITY OBLIGATIONS IN CONNECTION WITH ITS REPRESENTATIVES' 529 PLAN SHARE-CLASS RECOMMENDATIONS. UNTIL 2016, THE FIRM'S TRAINING MATERIALS SIMILARLY DID NOT PROVIDE ANY GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE CLASSES. ALTHOUGH THE FIRM MAINTAINED AN AUTOMATED SURVEILLANCE SYSTEM DESIGNED TO GENERATE EXCEPTION REPORTS TO IDENTIFY POTENTIALLY UNSUITABLE 529 PLAN SHARE-CLASS RECOMMENDATIONS, IT DID NOT HAVE ANY SYSTEM OR PROCEDURES TO TEST THIS SYSTEM AND IT FAILED TO DETECT A BREAKDOWN IN THE SYSTEM. AS A RESULT, THE FIRM FAILED TO CONDUCT A SUPERVISORY REVIEW OF APPROXIMATELY 1.6 MILLION 529 PLAN PURCHASES. IN ADDITION, EVEN WHEN THE SYSTEM GENERATED REPORTS AS INTENDED, THE FIRM DID NOT CONSISTENTLY USE THE REPORTS AND TOOK NO ACTION WHEN A POTENTIALLY UNSUITABLE TRANSACTION WAS FLAGGED. THE FINDINGS ALSO STATED THAT THE FIRM HAS AGREED TO PAY RESTITUTION RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $4,203,182.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND ORDERED TO PAY RESTITUTION IN THE ESTIMATED TOTAL AMOUNT OF $4,203,182, PLUS INTEREST, TO ELIGIBLE CUSTOMERS THAT INCURRED EXCESS FEES DUE TO THEIR INVESTMENTS IN CLASS C SHARES. IN RESOLVING THIS MATTER WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION

Summary: IN RESOLVING THIS MATTER WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION. THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA IN ITS INVESTIGATION, INCLUDING PROVIDING FINRA WITH DETAILED INFORMATION ABOUT THE CHALLENGES ASSOCIATED WITH COLLECTING AND ASSESSING DATA CONCERNING 529 PLANS. IN ADDITION, THE FIRM ENGAGED AN OUTSIDE CONSULTING FIRM TO CONDUCT A COMPLEX ANALYSIS TO IDENTIFY POTENTIALLY DISADVANTAGED CUSTOMERS ON AN EXPEDITED BASIS. THE FIRM THEN ESTABLISHED A PLAN TO PROVIDE BROAD REMEDIATION TO CUSTOMERS HARMED DURING THE RELEVANT PERIOD.

Resolved: Nov 6, 2019

Allegations: THE ADMINISTRATOR INTENDS TO CENSURE AND FINE RAYMOND JAMES & ASSOCIATES, INC. UNDER SECTION 412(3) OF THE SECURITIES ACT, MCL 451.2412(3), BECAUSE IT HAS FAILED TO SUPERVISE ITS AGENTS, WHICH SUPPORTS THE IMPOSITION OF A CENSURE AND A FINE UNDER THE ABOVE- CITED PROVISIONS OF THE MICHIGAN UNIFORM SECURITIES ACT (2002), 2008 PA 551, MCL 451.2101 ET SEQ.

Sanction: Censure

How it ended: Stipulation and Consent

Detail: $50,000 CIVIL FINE

Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER TO RESOLVE THE ALLEGATIONS AND A MONETARY FINE IN THE AMOUNT OF $50,000. THE FIRM ALSO AGREED TO COMPLY WITH THE MICHIGAN UNIFORM SECURITIES ACT IN CONNECTION WITH ALL FUTURE CONDUCT AND ACTIVITIES, INCLUDING BUT NOT LIMITED TO ENSURING THAT IT REASONABLY SUPERVISES ITS AGENTS.

Resolved: Mar 27, 2020

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE AMERICAN AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT AND NYSE AMERICAN RULE 956NY. THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $31,666.67 SHALL BE PAID TO THE EXCHANGE.

Resolved: Jan 13, 2020

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF CERTAIN EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $7,500 SHALL BE PAID TO THE EXCHANGE.

Resolved: Jan 13, 2020

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE ARCA AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT, AND NYSE ARCA RULE 6.68. THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $31,666.66 SHALL BE PAID TO THE EXCHANGE.

Resolved: Jan 13, 2020

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"), AND PHLX RULE 760. THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $24,166.67, SHALL BE PAID TO THE EXCHANGE.

Resolved: Jan 13, 2020

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AS A REMARKETING AGENT FOR VARIABLE RATE DEMAND OBLIGATIONS, SUBMITTED INFORMATION REGARDING THE RESULT OF INTEREST RATE RESETS TO THE MSRB'S SHORT-TERM OBLIGATION RATE TRANSPARENCY (SHORT) SYSTEM, BUT IN CERTAIN INSTANCES, MOST OF WHICH RELATED TO ITS ACQUISITION OF THE BOOK OF ANOTHER BROKER DEALER, FAILED TO INCLUDE THE MINIMUM DENOMINATION OR MAXIMUM INTEREST RATE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO REPORT THE MINIMUM DENOMINATION IN 2,925 SUBMISSIONS (APPROXIMATELY 6.36% ERROR RATE), AND FAILED TO REPORT THE MAXIMUM INTEREST RATE IN 3,133 SUBMISSIONS (APPROXIMATELY 6.81% ERROR RATE). THE REPORTING FAILURES OCCURRED BECAUSE THE FIRM'S REPORTING SYSTEM, WHICH TRANSMITS DATA TO SHORT FOR THE MSRB'S EMMA SYSTEM, DID NOT REQUIRE THE ENTRY OF THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS. FIRM TRADERS MISTAKENLY LEFT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS BLANK. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, THAT WAS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH MSRB REPORTING REQUIREMENTS. THE FIRM'S SUPERVISORY SYSTEM FAILED TO INCLUDE A REVIEW DESIGNED TO DETERMINE WHETHER IT HAD SUBMITTED ALL REQUIRED INFORMATION TO THE SHORT SYSTEM, AND WHETHER THAT SUBMITTED INFORMATION, INCLUDING THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE, WAS ACCURATE. EVEN AFTER THE FIRM UPDATED ITS SUPERVISORY SYSTEM TO INCLUDE A REVIEW TO VERIFY THAT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATES HAD BEEN REPORTED TO SHORT, THE FIRM'S WSPS DID NOT INCLUDE REFERENCE TO THIS REVIEW.

Sanction: Censure

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $47,500. FINE PAID IN FULL ON 10/27/2020.

Resolved: Oct 7, 2020

Allegations: FAILURE TO SUPERVISE 2 SOUTH CAROLINA AGENTS.

Sanction: Censure

How it ended: Consent

Detail: FINE PAID IN FULL ON 10/14/2022.

Resolved: Sep 28, 2022

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") VIOLATED SECTION 15(B)(4)(E) OF THE EXCHANGE ACT BY FAILING TO SUPERVISE REGISTERED REPRESENTATIVE FRED STOW IN THAT RJA FAILED TO DEVELOP POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT STOW'S VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER.

Sanction: Other

How it ended: Order

Detail: THE FIRM IS CENSURED AND SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY. FINE PAID IN FULL ON 10/4/2022.

Resolved: Sep 22, 2022

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT AND AN AFFILIATED COMPANY FAILED TO HAVE A QUALIFIED AND REGISTERED PRINCIPAL AUTHORIZE CHANGES TO THE ACCOUNT NAME OR DESIGNATION ON MORE THAN 7,500 EQUITY ORDERS. THE MATTER ORIGINATED WHEN THE FIRM REPORTED ON A FINRA RULE 4530 FILING THAT IT FAILED TO UNDERTAKE THE PRINCIPAL REVIEW REQUIRED BY FINRA RULE 4515. THE FIRMS HAVE SINCE DESIGNATED REGISTERED PRINCIPALS ON THE TRADE DESKS TO REVIEW AND AUTHORIZE CHANGES TO ACCOUNT NAME AND DESIGNATION ON ORDERS.

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $300,000.

Resolved: Oct 20, 2022

Allegations: THE FINDINGS INCLUDE A VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, NYSE AMERICAN RULE 324, AND NYSE AMERICAN RULE 956NY FOR FAILURE BY THE FIRM TO MAINTAIN ACCURATE AND COMPLETE RECORDS FOR OVER 5000 OPTIONS ORDERS MANUALLY HANDLED BY THE FIRM AND ROUTED TO NYSE FOR EXECUTION. SPECIFICALLY, NYSE FOUND THAT THE FIRM'S TRADE MEMORANDA: (1) CONTAINED INACCURATE ORDER RECEIPT TIME, (2) FAILED TO INDICATE WHETHER AN ORDER IS A MARKET ORDER, AND (3) FAILED TO RECORD MODIFICATIONS TO PRICE AND QUANTITY. THE STAFF ALSO FOUND THERE TO BE VIOLATIONS OF NYSE AMERICAN RULE 320(E) FOR FAILURE TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS BOOKS AND RECORDS OBLIGATIONS.

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

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $200,000.

Resolved: Dec 8, 2022

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SENT CUSTOMERS INACCURATE TRADE CONFIRMATIONS. THE FINDINGS STATED THAT THE FIRM SENT ITS CUSTOMERS AT LEAST 1,850,000 CONFIRMATIONS THAT INACCURATELY DISCLOSED THE FIRM'S EXECUTION CAPACITY OR WHETHER THE TRADE WAS EXECUTED AT AN AVERAGE PRICE, OR INACCURATELY DISCLOSED OR OMITTED ITS STATUS AS A MARKET MAKER IN THE SECURITY. FIRST, WHEN THE FIRM ACTED IN MORE THAN ONE CAPACITY IN EXECUTING ORDERS, IT DID NOT PROVIDE EACH SPECIFIC CAPACITY IN WHICH THE FIRM ACTED ON THE CUSTOMER CONFIRMATIONS. INSTEAD, THE FIRM DISCLOSED THAT IT ACTED IN A MIXED CAPACITY AND THAT THE BREAKDOWN OF EXECUTION CAPACITY IS AVAILABLE UPON REQUEST. THE FIRM'S SYSTEM PREVENTED THE FIRM FROM POPULATING THE SPECIFIC CAPACITIES IN WHICH THE FIRM ACTED IF THE FIRM ACTED IN MORE THAN ONE CAPACITY ON A TRANSACTION. THIS ISSUE AFFECTED APPROXIMATELY 750,000 CONFIRMATIONS. SECOND, DUE TO A PROGRAMING ERROR, THE FIRM SENT CUSTOMERS TRADE CONFIRMATIONS THAT INCORRECTLY DISCLOSED TRANSACTIONS AS AVERAGE PRICE EXECUTIONS WHEN THE FIRM FILLED THE ORDER IN A SINGLE EXECUTION. A REVIEW OF TWO OF THE FIRM'S SIX ORDER MANAGEMENT SYSTEMS REVEALED THAT THE FIRM INCORRECTLY IDENTIFIED SINGLE EXECUTIONS AS AVERAGE PRICE EXECUTIONS ON APPROXIMATELY 1,050,000 CONFIRMATIONS ISSUED TO CUSTOMERS. THIRD, THE FIRM FAILED TO DISCLOSE OR INACCURATELY DISCLOSED THAT IT WAS A MARKET MAKER ON APPROXIMATELY 52,350 CONFIRMATIONS SENT TO CUSTOMERS. THIS ISSUE STEMMED FROM A PROGRAMING ERROR THAT IMPACTED THE INPUT THAT IDENTIFIED THE ACCURATE MARKET MAKER STATUS ON TRADE CONFIRMATIONS. THE FIRM HAS SINCE UPDATED ITS SYSTEMS TO SPECIFY EACH CAPACITY IN WHICH THE FIRM ACTED AND PROPERLY IDENTIFY WHETHER TRANSACTIONS WERE AVERAGE PRICE EXECUTIONS, AS WELL AS CORRECTED THE PROGRAMMING ERROR.

Sanction: Censure

How it ended: Acceptance, Waiver & Consent(AWC)

Detail: THE FIRM WAS CENSURED AND FINED $300,000.

Resolved: Jan 30, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $100,000 TO MASSACHUSETTS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MASSACHUSETTS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $185,000. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF G.L. C. 110A, SEC. 204(A)(2)(J).

Resolved: Jul 10, 2023

Allegations: FROM 12/1/2018 TO 6/23/2020 (RELEVANT PERIOD), RESPONDENT ALLEGEDLY FAILED TO SUPERVISE AT LEAST ONE OF ITS FORMER BROKER-DEALER AGENTS WHO ENGAGED IN DISCRETIONARY TRADING IN AT LEAST FIVE NON-DISCRETIONARY CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR CUSTOMER AUTHORIZATION. RESPONDENT IGNORED RED FLAGS AND FAILED TO REASONABLY TAKE CORRECTIVE ACTION AGAINST AGENT. RESPONDENT'S WRITTEN SUPERVISORY PROCEDURES IN EFFECT DURING THE RELEVANT PERIOD DID NOT ADEQUATELY COMMUNICATE TO SUPERVISORY STAFF STEPS TO BE TAKEN WHEN POTENTIAL REGULATORY ISSUES WERE IDENTIFIED.

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

How it ended: Consent

Detail: RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. PAYMENT WAS PAID IN FULL ON 8/2/2023, UPON EXECUTION OF THE ORDER.

Summary: RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. RESPONDENT, ITS AGENTS AND EMPLOYEES, AND ALL OTHER PERSONS PARTICIPATING IN THE ABOVE-DESCRIBED ALLEGED VIOLATIONS WITH KNOWLEDGE OF THIS ORDER, MUST CEASE AND DESIST FROM ENGAGING IN VIOLATIONS OF 15 CSR 30-51.171 AND CONDUCT AND ACTIVITIES SUBJECT TO DISCIPLINE UNDER SECTIONS 409.4-412(C) AND 409.4-412(D)(9).

Resolved: Aug 2, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MONTANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MONTANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $37,027.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MONTANA CODE ANN. § 30­10­ 201(13)(K).

Resolved: Nov 16, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO COLORADO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN COLORADO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $234,566.40. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF § 11­51­410(1)(I), C.R.S.

Resolved: Oct 31, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO CALIFORNIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CALIFORNIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $465,000.FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF CSL SECTION 25218 AND CODE OF REGULATIONS, TITLE 10, SECTION 260.218.4

Resolved: Jul 10, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WEST VIRGINIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WEST VIRGINIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $41,361.14. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF WEST VIRGINIA CODE SECTION 32-2-204(A)(J).

Resolved: Nov 17, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO INDIANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN INDIANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $238,117.87. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF I.C.§23­19­4­12(D)(9) AND 710 I.A.C.§4­7­6.

Resolved: Sep 27, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WISCONSIN AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WISCONSIN CUSTOMERS IN AN AMOUNT OF NO LESS THAN $109,009.92. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION WI ADMIN CODE DFI-SEC. 4.05(2).

Resolved: Oct 18, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ARKANSAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ARKANSAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $129,802.26. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION ARKANSAS CODE SECTION 23-42- 301(F) AND 23-42-308(A)(2)(J) AND RULE 301.01(C).

Resolved: Oct 3, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO UTAH AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN UTAH CUSTOMERS IN AN AMOUNT OF NO LESS THAN $56,000.23. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF UTAH UNIFORM SECURITIES ACT, SECTION 61-1-6(2)(A)(II)(J).

Resolved: Oct 16, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ILLINOIS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ILLINOIS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $381,578.34. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF ILLINOIS SECURITIES ACT SECTION 8.E(1)(E)(IV).

Resolved: Nov 17, 2023

Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.

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

How it ended: Consent

Detail: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OKLAHOMA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OKLAHOMA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $77,951.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.

Summary: RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF OKLAHOMA SECTION 1-411(D) (9).

Resolved: Nov 28, 2023