RBC Capital Markets, LLC

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Oct 31, 2013

Allegations: THE DIVISION ALLEGES THAT RBC FAILED TO ADEQUATELY SUPERVISE ITS REPRESENTATIVES WITH RESPECT TO CONCENTRATION AND SUITABILITY OF MLP AND TELECOM POSITIONS IN CERTAIN CLIENT ACCOUNTS.

Sanction: Restitution

Summary: THE DIVISION ALLEGES THAT RBC FAILED TO ADEQUATELY SUPERVISE ITS REPRESENTATIVES WITH RESPECT TO CONCENTRATION AND SUITABILITY OF MLP AND TELECOM POSITIONS IN CERTAIN CLIENT ACCOUNTS.

Allegations: FAILURE TO MAKE AND KEEP BOOKS, RECORDS, AND ACCOUNTS, WHICH, IN REASONABLE DETAIL, ACCURATELY AND FAIRLY REFLECT THE TRANSACTIONS AND DISPOSITIONS OF THE ASSETS OF THE ISSUER. FAILURE TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNT CONTROLS SUFFICIENT TO PROVIDE REASONABLE ASSURANCE THAT TRANSACTIONS ARE RECORDED TO PERMIT PREPARATION OF FINANCIAL STATEMENTS IN CONFORMITY WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES.

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

How it ended: Decision & Order of Offer of Settlement

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE-AND-DESIST ORDER.

Resolved: Nov 2, 2023

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

Sanction: Undertaking

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jan 10, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jan 17, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Mar 26, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Mar 21, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Apr 21, 2014

Allegations: IT IS ALLEGED THAT THE FIRM TRANSMITTED TO ORDER AUDIT TRAIL SYSTEM ("OATS") 174 REPORTS FOR WHICH IT DID NOT HAVE AN OATS REPORTING RESPONSIBILITY.

Sanction: Censure

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

Resolved: Jun 27, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jul 2, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jun 16, 2014

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jun 20, 2014

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE 27 CUSTOMER LIMIT ORDERS IN 15 OVER-THE-COUNTER (OTC) SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER.

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

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

Resolved: Sep 16, 2014

Allegations: IT IS ALLEGED THAT DURING THE APPROXIMATE PERIOD FROM IN OR ABOUT MAY 2012 THROUGH IN OR ABOUT APRIL 2013, ON NUMEROUS DATES, RBC CAPITAL MARKETS, LLC FAILED TO SUBMIT ORDER ENTRY OPERATOR IDS PURSUANT TO CFE RULE 303A WITH NUMEROUS ORDERS SENT TO CFE.

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

How it ended: Decision & Order of Offer of Settlement

Resolved: Nov 5, 2014

Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC (RBCCM) FAILED TO REGISTER SEVENTEEN ASSOCIATED PERSONS AS PROPRIETARY TRADERS WITH THE CHICAGO BOARD OPTIONS EXCHANGE (CBOE) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT APRIL 29, 2013. IT IS ALSO ALLEGED THAT RBCCM FAILED TO REGISTER ONE ASSOCIATED PERSON WITH CBOE FROM ON OR ABOUT DECEMBER 18, 2012 THROUGH ON OR ABOUT MAY 13, 2013 AS A PROPRIETARY TRADING PRINCIPAL. IN ADDITION, FROM ON OR ABOUT APRIL 1, 2012 THROUGH ON OR ABOUT APRIL 19, 2013, IT IS ALLEGED THAT RBCCM FAILED TO REGISTER ONE ASSOCIATED PERSON WITH CBOE AS A PROPRIETARY TRADER PRINCIPAL. IT IS ALSO ALLEGED THAT RBCCM FAILED TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER WITH CBOE BY NOVEMBER 5, 2011 PURSUANT TO EXCHANGE RULE 3.6A.

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

How it ended: Settled

Resolved: Dec 1, 2014

Allegations: ROYAL BANK OF CANADA IS ALLEGED TO HAVE VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITION WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER.

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

How it ended: Consent

Resolved: Dec 18, 2014

Allegations: RBC CAPITAL MARKETS, LLC IS ALLEGED TO HAVE VIOLATED SECTION 11-402 OF THE MARYLAND SECURITIES ACT BY FAILING TO REGISTER AN INDIVIDUAL APPROPRIATELY AS AN INVESTMENT ADVISER REPRESENTATIVE BETWEEN AUGUST 3, 2011 AND JUNE 2, 2014.

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

How it ended: Consent

Resolved: Jan 23, 2015

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Mar 18, 2015

Allegations: IT IS ALLEGED THAT BETWEEN 2008 AND 2012, THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND ITS INTERNAL GUIDELINES CONCERNING THE SUITABILITY OF REVERSE CONVERTIBLES THEREFORE VIOLATING NASD RULES 3010(A), 2310, 2110, AND FINRA RULE 2010.

Sanction: Censure

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE TO THE ENTRY OF FINDINGS THAT BETWEEN 2008 AND 2012, THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND ITS INTERNAL GUIDELINES CONCERNING THE SUITABILITY OF REVERSE CONVERTIBLES THEREFORE VIOLATING NASD RULES 3010(A), 2310, 2110, AND FINRA RULE 2010.

Resolved: Apr 23, 2015

Allegations: SEC ADMIN RELEASES 339839;3475233,JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST RBC CAPITAL MARKERS, LLC ("THE FIRM"). THE FIRM WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE FIRM'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. THE FIRM, A REGISTERED BROKER DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN THE FIRM OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY THE FIRM TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.

Sanction: Cease and Desist

How it ended: Order

Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RBC CAPITAL MARKETS, LLC ("THE FIRM") HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") 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, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER THE FIRM AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTSTO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.

Resolved: Jun 18, 2015

Allegations: THE FIRM SELF-REPORTED AN ORDER AUDIT TRAIL SYSTEM ("OATS") REPORTING SYSTEM LOGIC CHANGE IMPLEMENTED IN JANUARY 2012 MAY HAVE CAUSED THE FIRM'S SYSTEM TO CEASE REPORTING REPORTABLE ORDER EVENTS ("ROES"), WHICH AFFECTED APPROXIMATELY 500 MILLION ROES, THEREFORE POTENTIALLY VIOLATING NASD RULE 3010, FINRA RULE 2010, AND FINRA RULE 7450. AFTER IMPLEMENTING A SYSTEM FIX, THE FIRM ENGAGED AN EXTERNAL CONSULTING FIRM TO ASSESS AND EVALUATE THE EFFICACY OF ITS CORRECTIVE ACTIONS. ADDITIONAL OATS REPORTING ISSUES WERE IDENTIFIED AND SUBMITTED VIA SELF-REPORT IN MARCH 2014.

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

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TRANSMIT TO OATS 1,183,844,292 ROES OVER A PERIOD CONSTITUTING APPROXIMATELY 28 MONTHS, THEREFORE VIOLATING FINRA RULE 7450, FINRA RULE 2010, AND NASD RULE 3010.

Resolved: Jul 27, 2015

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON 13 OCCASIONS, THE FIRM VIOLATED NYSE RULE 92(A) BY ENTERING A PROPRIETARY ORDER TO BUY OR SELL AN NYSE-LISTED SECURITY WHILE KNOWINGLY IN POSSESSION OF A CUSTOMER ORDER TO BUY OR SELL SUCH SECURITY THAT COULD BE EXECUTED AT THE SAME PRICE, AND WHICH PROPRIETARY ORDER THEN TRADED ALONG WITH, OR AHEAD OF, THE CUSTOMER ORDER, OR TRADED OUTSIDE OF THE CUSTOMER'S CONSENT PARAMETERS. THE FINDINGS STATED THAT ON TWO OCCASIONS, THE FIRM VIOLATED NYSE RULE 2010 BY FAILING TO DOCUMENT CUSTOMER CONSENT TO THE ALLOCATION SPLIT AS REQUIRED BY NYSE RULE 92(B). THE FINDINGS ALSO STATED THAT THE FIRM VIOLATED NYSE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NYSE RULES AND POLICIES, INCLUDING WITH RESPECT TO TRANSMITTING AND EXECUTING PROPRIETARY AND AGENCY TRADES ON THE NYSE.

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

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

Resolved: Aug 28, 2015

Allegations: FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBC CAPITAL MARKETS, LLC ("RBCCM") IS ALLEGED TO HAVE FAILED TO PROPERLY CLOSE OUT A FAIL-TO-DELIVER POSITION IN SEVEN SAMPLED EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE INCREASED ITS SHORT POSITION WHEN A FAIL-TO-DELIVER POSITION HAD NOT BEEN PROPERLY CLOSED OUT WITHOUT DEMONSTRATING THAT IT MADE ARRANGEMENTS FOR PRE-BORROWING IN SPECIFIC EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH REGULATION SHO RULE 204 IN THAT IT: (1) FAILED TO ASSURE THAT NUMEROUS FAIL-TO-DELIVER POSITIONS WERE CLOSED OUT ON A TIMELY BASIS; AND (2) IMPROPERLY ASSERTED RELIANCE ON CERTAIN EXEMPTIONS UNDER REG. SHO RULE 204 WITHOUT UNDERTAKING SUFFICIENT DUE DILIGENCE TO ASCERTAIN AND DOCUMENT THAT SPECIFIC REQUIREMENTS THEREUNDER WERE MET.

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

How it ended: Decision & Order of Offer of Settlement

Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND AGREED TO PAY A FINE OF $75,000.

Resolved: Apr 11, 2016

Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC ("THE FIRM") FAILED TO AMEND, OR TIMELY AMEND, THE FORMS U4 FOR REGISTERED REPRESENTATIVES TO REPORT UNSATISFIED TAX LIENS AND CIVIL JUDGMENTS. THE FINDINGS STATE THAT THE FIRM RECEIVED WAGE GARNISHMENT ORDERS FROM COURTS AND TAX AUTHORITIES (INCLUDING THE IRS) RESULTING FROM TAX LEVIES, CIVIL JUDGMENTS, AND SIMILAR ACTIONS, FOR REGISTERED REPRESENTATIVES. THE FIRM HOWEVER IS ALLEGED TO HAVE FAILED TO CONSISTENTLY CONDUCT A SUFFICIENT INQUIRY TO DETERMINE IF THE UNDERLYING EVENT TRIGGERING EACH GARNISHMENT ORDER INVOLVED AN EVENT THAT SHOULD HAVE BEEN REPORTED ON THE AFFECTED INDIVIDUAL'S FORM U4. THE FINDINGS ALSO ALLEGED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE THAT IT DISCLOSED REPORTABLE UNSATISFIED LIENS AND JUDGMENTS OF REGISTERED REPRESENTATIVES ON FORMS U4, IN INSTANCES IN WHICH A GARNISHMENT NOTICE WAS SENT TO THE FIRM.

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

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO AMEND, OR TIMELY AMEND, THE FORMS U4 FOR REGISTERED REPRESENTATIVES TO REPORT UNSATISFIED TAX LIENS AND CIVIL JUDGMENTS BETWEEN JANUART 1, 2013 THROUGH JUNE 30, 2015.

Resolved: Mar 1, 2016

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Mar 17, 2016

Allegations: IT IS ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730 AND FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS AND TRACE-ELIGIBLE AGENCY DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730.

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

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730 AND FAILED TO REPORT TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS AND TRACE- ELIGIBLE AGENCY DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730.

Resolved: Mar 31, 2016

Allegations: THE FIRM IS ALLEGED TO HAVE FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO APPLY SALES CHARGE DISCOUNTS TO 4,399 ELIGIBLE UIT PURCHASES RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $502,088.88. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. ALTHOUGH THE FIRM HAD WSPS RELATED TO UIT SALES CHARGE DISCOUNTS, THE FIRM FAILED TO EFFECTIVELY INFORM AND TRAIN REGISTERED REPRESENTATIVES AND SUPERVISORS TO ENSURE THAT REPRESENTATIVES FOLLOWED THESE PROCEDURES AND IDENTIFIED AND APPLIED ALL APPLICABLE DISCOUNTS.

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

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS).

Resolved: Apr 4, 2016

Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKEST, LLC TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA WHICH PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FINDINGS ALSO ALLEGED THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT.

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

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

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA WHICH PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FIRM ALSO CONSENTED TO THE ENTRY OF FINDINGS THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT.

Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC VIOLATED FINRA RULE 2010 AND 2081 WHEN MEDIATING A DISPUTE WITH A CLAIMANT ON OCTOBER, 2014 BY INCLUDING A "A TERM OR CONDITION" THAT "CLAIMANTS WILL NOT OPPOSE EXPUNGEMENT" ON A SETTLEMENT AGREEMENT. ADDITIONALLY, IT IS ALLEGED THAT THE FIRM VIOLATED NASD RULE 3010(A) AND FINRA RULES 3110(A) AND 2010 BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2081. THE FIRM IS ALSO ALLEGED TO HAVE FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) WHICH SHOULD HAVE INCLUDED A DESIGNATED SUPERVISOR RESPONSIBLE FOR CONDUCTING SUPERVISION REGARDING COMPLIANCE WITH RULE 2081, A DESCRIPTION OF THE REVIEW PROCESS THAT SUCH SUPERVISOR WOULD TAKE TO REVIEW FOR COMPLIANCE, THE FREQUENCY OF SUCH REVIEW, HOW SUCH REVIEWS SHOULD BE DOCUMENTED, AS WELL AS WHAT THE FIRM SHOULD DO WHEN DEFICIENCIES IN COMPLIANCE ARE IDENTIFIED, LEADING TO A VIOLATION OF FINRA RULES 3110(B) AND 2010.

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

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

Resolved: Jun 10, 2016

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Jul 22, 2016

Allegations: IT IS ALLEGED THAT ON JANUARY 13, 2014, RBC CAPITAL MARKETS, LLC ("RBCCM") EXECUTED A BLOCK TRADE IN THE MARCH 2014 5YEAR NOTE CONTRACT THAT WAS NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, AND THAT RBCCM REPORTED AN INACCURATE TIME OF EXECUTION OF THE BLOCK TRADE. ADDITIONALLY, IT IS ALLEGED THE RBCCM AGREED TO SELL TO THE CUSTOMER AT ONE PRICE, BUT REPORTED THAT THE BLOCK TRADE WAS EXECUTED AT A DIFFERENT PRICE TO THE EXCHANGE. THIS CONDUCT ALLEGEDLY VIOLATED CBOT RULE 526.F.

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

How it ended: Settled

Resolved: Jul 29, 2016

Allegations: SEC ADMIN RELEASE 3478735, AUGUST 31, 2016: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE THAT CEASE AND DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT"). IT IS ALLEGED THAT RBC CAUSED RURAL/METRO CORPORATION'S VIOLATIONS OF THE PROXY STATEMENT PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE SALE OF RURAL/METRO CORPORATION ("RURAL") IN 2011 TO A PRIVATE EQUITY FIRM. RBC, WHICH SERVED AS RURAL'S LEAD FINANCIAL ADVISER FOR THE SALE, ALLEGEDLY RENDERED A FAIRNESS OPINION TO RURAL'S BOARD OF DIRECTORS THAT CONTAINED MATERIALLY FALSE AND MISLEADING INFORMATION CONCERNING RBC'S VALUATION ANALYSIS. RBC ALLEGEDLY CAUSED THAT INFORMATION TO BE INCLUDED IN THE PROXY STATEMENT THAT RURAL FILED TO SOLICIT VS HAREHOLDER APPROVAL FOR THE SALE. AS A RESULT, RBC ALLEGEDLY CAUSED RURAL TO VIOLATE SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A9 THEREUNDER, WHICH PROHIBITS SOLICITATION BY MEANS OF A PROXY STATEMENT THAT CONTAINS ANY MATERIALLY FALSE OR MISLEADING STATEMENT.

Sanction: Other

How it ended: Order

Resolved: Aug 31, 2016

Allegations: IT IS ALLEGED THAT THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS). IT IS ALSO ALLEGED THAT THE FIRMS SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY CALCULATED TO COMPLY WITH APPLICABLE RULES REGARDING TRANSMITTING ORDERS THAT TOOK PLACE OUTSIDE OF THE FIRM'S OMSS TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.

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

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

Resolved: Oct 19, 2016

Allegations: IT IS ALLEGED THAT DURING THE PERIODS OF APRIL 2011 THROUGH APRIL 2014 AND NOVEMBER 2002 THROUGH DECEMBER 29, 2014, THE FIRM EXPERIENCED SYSTEMS ISSUES DURING THE REVIEW PERIODS THAT RESULTED IN VIOLATION OF NASD RULES 2110 (FOR CONDUCT PRIOR TO DECEMBER 15, 2008), 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND 3310 (FOR CONDUCT PRIOR TO FEBRUARY 15, 2010), AND FINRA RULES 2010 (FOR CONDUCT ON AND AFTER DECEMBER 15, 2008), 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014), AND 5210 (FOR CONDUCT ON AND AFTER FEBRUARY 15, 2010). THE FIRM IS ALLEGED TO HAVE OVERSTATED ITS ADVERTISED TRADE VOLUME DUE TO A COMPUTER CODING ERROR. DUE TO A SEPARATE COMPUTER CODING ERROR, IT IS ALLEGED THAT THE ADVERTISED TRADE VOLUME FROM THE FIRM'S ELECTRONIC TRADING DESK WAS REPORTED WITH THE WRONG EXECUTION DATE. ADDITIONALLY, THE FIRM IS ALLEGED TO HAVE FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES, CONCERNING ADVERTISED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM ALLEGEDLY DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.

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

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

Resolved: Oct 18, 2016

Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC AND RBC CAPITAL MARKETS ARBITRAGE, S.A. (BOTH NOTED TOGETHER AS "RBC" HEREAFTER) FAILED TO RETAIN ELECTRONIC RECORDS IN WORM ("WRITE ONCE, READ MANY") FORMAT. RBC IS ALSO ALLEGED TO HAVE FAILED TO IMPLEMENT AN AUDIT SYSTEM REGARDING THE INPUTTING OF RECORDS IN ELECTRONIC STORAGE MEDIA. RBC IS ALLEGED TO HAVE FAILED TO OBTAIN AN ATTESTATION FROM THEIR THIRD PARTY VENDOR. RBC'S SUPERVISORY SYSTEM WAS ALLEGEDLY NOT REASONABLY DESIGNED TO ENFORCE SPECIFIC PROCEDURES CONCERNING STORAGE OF ELECTRONIC BROKER-DEALER RECORDS IN WORM FORMAT.

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

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

Resolved: Dec 21, 2016

Allegations: IT IS ALLEGED THAT THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS IN WHICH THE SPECIAL HANDLING CODE FIELD WAS NOT POPULATED TO INDICATE WHETHER THE ORDERS WERE "HELD" OR "NOT HELD." THE FINDINGS ALLEGED 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 TRANSMITTING ACCURATE INFORMATION TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FOR A REVIEW OF THE FIRM'S OATS REPORTS THAT WAS REPRESENTATIVE OF THE TYPES OF BUSINESS IN WHICH THE FIRM ENGAGED TO ENSURE ITS SUBMISSIONS WERE ACCURATE. THE FINDINGS ALSO ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE ELIGIBLE CORPORATE DEBT SECURITIES THAT IT WAS REQUIRED TO REPORT. IN THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. THE FINDINGS ALSO ALLEGED THAT THE FIRM EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE, WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULE. FINRA ALLEGED THAT THE FIRM ALSO FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. FINRA ALSO ALLEGED THAT THE FIRM FAILED TO REPORT INFORMATION REGARDING 18,634 PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REALTIME TRANSACTION REPORTING SYSTEM (RTRS). FOR APPROXIMATELY 1,500 OF THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED.

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

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

Summary: FINRA CASE NUMBER 20150464695 INCLUDES CASE NUMBERS 20150465800, 20160492672, 20160494357, AND 2016052372

Resolved: May 3, 2017

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON ONE TRADE, IT HAD MODIFIED AN EXPIRING EXERCISE DECLARATION (EED) SUBMISSION AFTER THE 5:30 P.M. (ET) CUT-OFF TIME, WITHOUT AN ALLOWABLE EXCEPTION AND BASED ON AFTER-HOURS TRADING INFORMATION, IN VIOLATION OF BOX RULE 9000, AND ALSO HAD RELATED SUPERVISORY DEFICIENCIES. THE FINDINGS STATED THAT THIS CUT-OFF TIME WAS ESTABLISHED TO PREVENT OPTION HOLDERS FROM WAITING FOR MATERIAL INFORMATION TO DETERMINE IF THE UNDERLYING PRICE WILL VARY SUBSTANTIALLY FROM THE CLOSING PRICE ON EXPIRATION, UNFAIRLY DISADVANTAGING THE SHORT OPTION HOLDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENSURE THAT ANY EXERCISE INSTRUCTIONS SUBMITTED AFTER THE APPLICABLE CUT-OFF TIME ARE THE RESULT OF A GOOD FAITH ERROR OR OTHER APPLICABLE EXCEPTION, AND ARE NOT BASED ON MATERIAL INFORMATION, INCLUDING AFTER-HOURS TRADING ACTIVITY, RELEASED AFTER THE CUT-OFF TIME. AS A RESULT, A FIRM TRADER SUBMITTED THIS PARTICULAR MODIFIED EED TO THE FIRM'S OPERATIONS DEPARTMENT BASED ON AFTER-HOURS TRADING AFTER THE 5:30 P.M. CUT- OFF TIME, AND THE OPERATIONS STAFF SUBMITTED THE MODIFIED EED TO THE FIRM'S CLEARING FIRM WITHOUT COMPLETELY UNDERSTANDING THE RULES GOVERNING EED SUBMISSIONS. IN ADDITION, THE FIRM FAILED TO HAVE ADEQUATE SUPERVISORY POLICIES AND SYSTEMS, INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS"), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH BOX RULES RELATING TO THE OBLIGATIONS OF A BOX PARTICIPANT WHEN EXERCISING OPTIONS CONTRACTS. SPECIFICALLY, THE FIRM'S WSPS LACKED REFERENCES TO THE IDENTITY OF THE INDIVIDUAL RESPONSIBLE FOR SUPERVISION; THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE DESIGNATED SUPERVISOR; THE FREQUENCY OF SUCH REVIEWS; AND HOW SUCH REVIEWS SHOULD BE DOCUMENTED.

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

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

Resolved: Sep 13, 2017

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES.

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

How it ended: Order

Summary: AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED.

Resolved: Aug 28, 2017

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS 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 THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA.

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

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

Summary: ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855

Resolved: Oct 18, 2017

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT ON THE REVIEW DATE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO AVOID DISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION, WITHOUT SIMULTANEOUSLY ROUTING AN ISO TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF ANY PROTECTED QUOTATION THAT WAS A LOCKING QUOTATION OR CROSSING QUOTATION. 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 THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. THE FIRM'S REGULATION NMS COMPLIANCE ISO EXCEPTION REPORTS, WHICH WERE REVIEWED BY FIRM PERSONNEL, DID NOT IDENTIFY THAT THE FIRM HAD LOCKED OR CROSSED A PROTECTED QUOTATION ON THE REVIEW DATE.

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

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

Summary: ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855

Resolved: Oct 18, 2017