{"firms":{"165899":"Mackenzie Investments","106508":"CIBC Global Asset Management","282637":"LMR Partners Limited","309263":"Morgan Stanley | Eaton Vance CLO Manager LLC","161814":"Pag","301084":"Notion Capital","159792":"Tudor Investment Corporation","167992":"Virage Capital Management LP","110653":"Eagle Asset Management Inc","323648":"Ge Investment Management","6210":"Wilshire","104517":"Franklin Advisers, Inc.","305225":"Orca Capital, LLC","110670":"Gam London Limited","79":"J.P. Morgan Securities LLC","172116":"Squarepoint Ops LLC","108633":"Aew Capital Management LP","106585":"Schroder Investment Management North America Ltd","137312":"Senvest Management, LLC","106595":"Wellington Management Company LLP","104555":"Strategic Advisers LLC","104559":"Pacific Investment Management Company LLC","106614":"BlackRock Advisors, LLC","108674":"Davis Selected Advisers LP","108679":"D. E. Shaw & Co., L.P.","106631":"The Putnam Advisory Company, LLC","104599":"Kayne Anderson Rudnick Investment Management, LLC","106661":"Renaissance Technologies LLC","8361":"A.G.P / Alliance Global Partners","104626":"Nuveen Fund Advisors, LLC","157876":"Deerfield Management Company","125109":"Anson Funds Management LP","110783":"Brandywine Global Investment Management, LLC","157907":"Prescott General Partners LLC","231":"BNY Mellon Securities Corporation","162024":"Nine Masts Capital Limited","135405":"Sterling Capital Management LLC","307440":"Triodos Investment Management","116978":"Faithward Advisors, LLC","143606":"Redmile Group","10489":"Caldwell Sutter Capital, Inc.","250":"Edward Jones","110843":"Asset Management One Co., Ltd.","160000":"Lone Star Funds","106753":"Charles Schwab Investment Management, Inc","6413":"LPL Financial LLC","174350":"Kudu Investment Holdings, LLC","149777":"Morgan Stanley","307488":"Responsability Investments AG","106793":"Oaktree Capital Management, L.P.","289075":"Tikehau Capital North America LLC","149822":"NB Alternatives Advisers LLC","133449":"Mercer Investments LLC","361":"Goldman Sachs & Co. LLC","29037":"Syndicated Capital, Inc.","307575":"Sourcerock Group LLC","158071":"Valiant Capital Management, L.P.","164231":"Talkot Capital, LLC","41353":"Thompson Davis Asset Management","110987":"Silchester International Investors","104859":"Eaton Vance Management","104864":"Charles Pratt & Company, L.L.C.","137637":"Fiera Capital (UK) Limited","158117":"Millennium Management LLC","160173":"Hite Hedge Asset Management LLC","160174":"Ra Capital Management, LP","131517":"NXG Investment Management","158143":"Parallax Volatility Advisers, L.P.","283077":"Point72 Asset Management, L.P.","109002":"Principal Asset Management","336332":"O'Connor Alternative Investments, LLC","117198":"RBC Rochdale, LLC","463":"Janney Montgomery Scott LLC","109008":"Principal Real Estate","307662":"Helikon Investments Limited","162264":"Jefferies Finance LLC","31194":"RBC Capital Markets, LLC","106975":"Vaughan Nelson Investment Management, L.P.","172522":"HSBC Management (Guernsey) Limited","158187":"Deccan Value Investors L.P.","158197":"Corvex Management LP","162296":"Mangrove Partners","20989":"JPMorgan Alternative Asset Management","141823":"First Pacific Advisors, LP","162309":"Abrdn Investments Limited","143883":"Santander Asset Management SA Sgiic","104983":"Oppenheimerfunds Inc","111128":"The Carlyle Group","141854":"WL Ross & Co. LLC","291361":"Rockefeller Capital Management","283173":"M&G Alternatives Investment Management Limited","168496":"Select Equity Group, L.P.","137779":"Asset Value Investors Limited","158263":"Ew Healthcare Partners","160318":"Tiger Global Management, LLC","154176":"Alphadyne Asset Management LP","160328":"Mirabella Financial Services LLP","145995":"Insight Investment","129612":"Fortress Investment Group","111179":"Lasalle Investment Management Securities","283221":"Goldman Sachs Asset Management Co., Ltd.","107105":"BlackRock Financial Management, Inc","111208":"Newton Investment Management Ltd","160366":"Squadra Investments - Gestao de Recursos Ltda.","152175":"Cerberus Capital Management, L.P.","158319":"Samsung Asset Management Company, Ltd.","137842":"Gates Capital Management, Inc.","170628":"Hatteras Investment Partners, LP","146052":"Universa Investments L.P.","324239":"Masterworks Advisers, LLC","160404":"GMT Capital Corp.","137883":"Hillsdale Investment Management Inc.","107168":"TIAA-CREF Investment Management LLC","158371":"Cannell Capital LLC","12963":"Money Concepts Advisory Service","160440":"Ratan Capital Management, LP","289466":"Stronghold Resource Partners","705":"Raymond James & Associates, Inc.","111298":"Arrowstreet Capital, Limited Partnership","340676":"Andera Partners","137927":"Third Point LLC","156384":"Egerton Capital (UK) LLP","283363":"Ursa Fund Management LLC","119537":"Citigroup Alternative Investments LLC","166644":"Clearance Capital Ltd","29433":"Heartland Advisors, Inc.","301819":"Ieq Capital, LLC","111361":"Franklin Advisory Services, LLC","111364":"Franklin Templeton Investments Corp.","111376":"Franklin Mutual Advisers, LLC","11025":"Wells Fargo Advisors","111382":"Templeton Asset Management Ltd.","111383":"Templeton Global Advisors Limited","135960":"JPMorgan Asset Management (UK) Limited","793":"Stifel, Nicolaus & Company, Incorporated","160535":"Palestra Capital Management LLC","299809":"Navy Capital Green Management, LLC","293667":"JM Financial Limited","131889":"TSP Capital Management Group, LLC","174904":"Raymond James Investment Management","107322":"Farallon Capital Management, L.L.C.","301896":"Fidelity Institutional Wealth Adviser LLC","156508":"QVT Financial LP","131934":"Consilium Investment Management LLC","162659":"Sabby Management, LLC","142188":"Western Asset Management Company Pte Ltd","877":"Wedbush Securities Inc.","330606":"Dockside Platforms","324468":"HSBC Asset Management (India) Private Limited","160630":"Fenway Partners, LLC","310138":"Murchinson Ltd.","138111":"Balyasny Asset Management L.P.","105348":"Creative Planning","105360":"Invesco Advisers, Inc.","7059":"Citigroup Global Markets Inc.","105377":"Loomis, Sayles & Company, L.P.","160679":"Adage Capital Management, L.P.","160695":"Encap Investments L.P.","156610":"Verition Fund Management LLC","158672":"Benefit Street Partners L.L.C.","109530":"The Baupost Group, L.L.C.","173027":"Ab Private Credit Investors LLC","113638":"Fiera Capital Inc.","162791":"Partners Group AG","162793":"Dexus Capital Investors Limited","302067":"Infini Capital Management Limited","175092":"Churchill Asset Management LLC","15356":"Mutual of America Life Insurance Company","168978":"Armistice Capital LLC","107557":"Connor Clark & Lunn Investment Management Ltd","140336":"York Capital Management","107584":"Invesco Private Capital, Inc.","160833":"Enterprise Investors","158789":"Kiltearn Partners","283720":"GQG Partners","154700":"HSBC Global Asset Management (UK) Limited","154703":"Perceptive Advisors","156752":"Ci Global Investments Inc.","140370":"Deer Park Road Management Company, LP","326747":"Pinegrove Venture Partners, LLC","156781":"Lightyear Capital LLC","142463":"MetLife Investment Management, LLC","171144":"Slow Ventures, LLC","121995":"Whitebox Advisors LLC","144533":"Kohlberg Kravis Roberts & Co. L.P.","19616":"Wells Fargo Advisors","105633":"Brown Capital Management, LLC","160932":"JZ Partners","107689":"Royce Investment Partners","105642":"BNY Mellon Investment Adviser, Inc.","316590":"Brookfield Renewable Energy Group LLC","107717":"Mackay Shields LLC","163016":"GLG Partners LP","105673":"Advent International, L.P.","156873":"Pentwater Capital Management LP","167121":"Ecor1 Capital, LLC","142558":"Managed Account Advisors LLC","134366":"Morgan Stanley Private Equity Asia, Inc.","1252":"William Blair & Company L.L.C.","158959":"Mesa West Capital","25853":"Raymond James (USA) Ltd","105734":"Russell Investments","130320":"Capital Dynamics, Inc.","165153":"Montanova Capital, LLC","173355":"Candriam S.C.A.","103727":"Gagnon Securities, LLC","294197":"Rockefeller Capital Management","290111":"Titan","40258":"Northland Asset Management","111940":"Institutional Shareholder Services Inc.","161110":"Pointstate Capital LP","152922":"Euro Pacific Asset Management, LLC","286067":"Goldman Sachs Asset Management (Singapore) Pte. Ltd.","281984":"Schonfeld Strategic Advisors LLC","308609":"Dalton Investments, Inc.","157056":"First Reserve","107913":"Sculptor Capital LP","118156":"Carlson Capital, L.P.","157073":"Monroe Capital Management Advisors LLC","159127":"Bridge Investment Group","226714":"Atalan Capital Partners, LP","109979":"Contrarian Capital Management LLC","161180":"Canaan Partners","3496":"Stephens","142766":"Canaras Capital Management, LLC","161205":"Highland Capital Partners","128450":"Channing Capital Management, LLC","105922":"Morgan Stanley Investment Management Limited","157124":"Steadfast Capital Management LP","110045":"MFS Investment Management","161251":"Engaged Capital","105958":"Vanguard Group Inc","331241":"Arini Capital Management Limited","161257":"Lloyds Bank PLC","159215":"Alpinvest Partners B.V.","130566":"Winton Capital Management Ltd.","7691":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","282125":"HPS Investment Partners, LLC","165390":"Yorkville Advisors Global, LP","106006":"Barings LLC","149018":"Raymond James Financial Services Advisors, Inc","290336":"BlackRock Capital Investment Advisors, LLC","1588":"Davenport & Company LLC","161339":"New Silk Route","161344":"Black Creek Investment Management Inc.","7754":"Benjamin Securities, Inc.","155216":"Private Advisor Group, LLC","169553":"Nyl Investors LLC","106081":"Wasatch Advisors LP","124513":"Opaleye Management Inc.","138854":"Ejf Capital LP","134776":"Highbridge Capital Management, LLC","161413":"Walleye Capital LLC","269959":"Beryl Capital Management, LLC","46727":"Advisors Asset Management, Inc.","114317":"Burgundy Asset Management Ltd.","153232":"RTW Investments LP","142994":"Insight Venture Partners","151190":"Vulcan Value Partners LLC","155299":"The Catalyst Capital Group Inc.","306863":"Jupiter Asset Management Limited","134852":"Bain Capital Credit, LP","124613":"Marathon Asset Management, L.P.","112324":"Asset Management Group of Bank of Hawaii","313036":"Tikehau Investment Management","315088":"Fidelity Diversifying Solutions LLC","7897":"Instinet, LLC","165598":"Stone Ridge Asset Management LLC","136932":"Glazer Capital, LLC.","161512":"Global Alpha Capital Management Ltd.","106220":"Grantham Mayo van Otterloo & Co LLC","149236":"P. Schoenfeld Asset Management LP","124674":"Ancora Advisors LLC","110338":"Mackenzie Investments","161539":"Seaf","106256":"Cbre Investment Management Listed Real Assets LLC","110353":"Morgan Stanley Investment Management Inc.","145186":"Axiom Asset Management","300838":"DWS Investment S.A.","288555":"Greenhaven Road Investment Management, LP","173887":"Maple Rock Capital Partners Inc.","106305":"1ST & Main Growth Partners","137028":"Clearbridge Investments, LLC","157509":"Kingdon Capital Management, L.L.C.","143177":"Value Partners Limited","110411":"Nomura Corporate Research and Asset Management Inc","157517":"Chatham Asset Management, LLC","110427":"Western Asset Management Company Limited","173916":"Redwood Wealth Management, LLC","114527":"M&G Investment Management Ltd.","8032":"Commonwealth Financial Network","110441":"Western Asset Management Company","110453":"Claret Asset Management Corp","106357":"Thornburg Investment Management Inc","282487":"Willow Wealth","137080":"Wealth Management","132982":"Pershing Square Capital Management, L.P.","110458":"Gam USA Inc.","139138":"Polus Capital Management Limited","157571":"Orbis Investment Management Limited","173961":"William Blair Investment Management, LLC","169878":"Lendingrobot","159639":"LMR Partners LLP","155551":"Hound Partners","145323":"Hightower Advisors, LLC","155564":"Weiss Asset Management","126896":"Morgan Stanley Investment Management Company","137137":"Two Sigma Investments, LP","155584":"Nuveen Asset Management, LLC","167882":"Ahl Partners LLP","307151":"Elliott Investment Management L.P.","2002":"Gilder Gagnon Howe & Co. LLC","171988":"Inspire Investing, LLC","122836":"Lazard Asset Management LLC","319448":"Corient","8158":"Robert W. Baird & Co. Incorporated","309234":"Apogem Capital LLC","161788":"HG Vora Capital Management, LLC"},"rows":[{"d":"2026-09-22","di":"2026-09-22","dr":"2026-09-22","k":"Regulatory Action","rg":"State regulator","reg":"The Colorado Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"2025-CDS-034","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), The Colorado Division of Securities (\"the division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 11-51-410(1)(I), C.R.S.","res":"Consent","sm":"Edward jones was notified on September 22, 2026 that Colorado entered an order. The division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 11-51-410(1)(I), C.R.S. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of section 11-51-410(1)(I), C.R.S., to provide restitution to affected Colorado customers in an amount no less than $231,455.29, to pay a monetary fine in the amount of $100,000, and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1},{"d":"2026-09-21","di":"2026-09-21","dr":"2026-09-21","k":"Regulatory Action","rg":"Other","reg":"District of Columbia - Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"SB-CO-08-25","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the District of Columbia department of insurance, securities and banking (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of D.C. Official code § 31­5602.07(a)(12) of the District of Columbia uniform Securities Act.","res":"Consent","sm":"On September 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of D.C. Official code § 31­5602.07(a)(12) of the District of Columbia uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of D.C. Official code § 31­5602.07(a)(12) to provide restitution to affected District of Columbia customers in an amount of no less than $2,980.13, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2},{"d":"2026-09-14","di":"2026-09-14","dr":"2026-09-14","k":"Regulatory Action","rg":"Other","reg":"Saudi Central Bank (\"Sama\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5600.0,"dk":"B/26155","al":"On September 14, 2026, the Saudi Central Bank (\"Sama\") found that Deutsche Bank AG, Riyadh branch (\"DBAG\") violated a corrective action plan regarding the employment of Saudi nationals, including violations of quarterly reporting requirements and failing to obtain approval for delays in addressing regulatory findings.","res":"Order","sm":"On September 14, 2026, sama found that dbag violated a corrective action plan regarding the employment of Saudi nationals, including violations of quarterly reporting requirements and failing to obtain approval for delays in addressing regulatory findings. Dbag was fined sar 21,100 (which is approximately $5,600 usd), which will be timely paid.","ab":"Deutsche Bank AG, Riyadh","firms":[300838],"id":3},{"d":"2026-09-03","di":"2026-09-03","dr":"2026-09-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":250000.0,"dk":"2024081737701","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that, from October 2010 through September 2024, JPMS (1) failed to establish procedures to assure that certain customers received margin account disclosures required by rule 10B-16(a)(2) of the Securities Exchange Act of 1934 (\"Exchange Act\") on account statements, resulting in JPMS failing to provide certain information in its margin account disclosures for certain customer accounts from October 2010 through February 2024, in violation of Exchange Act rule 10B-16(a)(2) and FINRA rule 2010; and (2) failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with Exchange Act rule 10B-16(a)(2), in violation of FINRA rules 3110(a) and (b) and 2010 and NASD rule 3010","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":4},{"d":"2026-09-03","di":"2026-09-03","dr":"2026-09-03","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Department of Insurance Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"27E018","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Kansas department of insurance, securities division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) of the Kansas uniform Securities Act.","res":"Consent","sm":"On September 3, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) of the Kansas uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) to provide restitution to affected Kansas customers in an amount of no less than $23,441.71, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":5},{"d":"2026-08-24","di":"2026-08-24","dr":"2026-08-24","k":"Regulatory Action","rg":"State regulator","reg":"State of New Jersey Department of Banking and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":5000.0,"dk":"ORDER NUMBER: E26-96","al":"The commissioner of banking and insurance (the \"commissioner\"), state of New Jersey, alleged that, Edward D. Jones & Co., L.P. (\"Edward jones\") failed to report a consent order issued on January 8, 2025 by the New Jersey bureau of securities (\"NJBOS\") to the commissioner, within 30 days of the disciplinary action, in violation of N.J.S.A. 17:22A-40A(2) and (19).","res":"Consent","sm":"On August 24, 2026, the commissioner alleged that, Edward jones failed to report a consent order issued on January 8, 2025 by the njbos to the commissioner, within 30 days of the disciplinary action, in violation of N.J.S.A. 17:22A-40A(2) and (19). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to cease and desist from conduct in violation of N.J.S.A. 17:22A-40A(2) and (19), and to pay a monetary fine in the amount of $5,000. The monetary fine was paid in accordance with the terms of the consent order on July 20, 2026.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":6},{"d":"2026-08-21","di":"2026-08-21","dr":"2026-08-21","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Securities Regulation","san":"Cease and Desist","os":"Fine, costs and undertakings","st":"Final","fine":25000.0,"dk":"COM2024-0002","al":"In 2023, RBC agent's mom and step-dad became incapacitated and poa, agents brother, had authority over their investment accounts. Agent was conflicted because he was a named beneficiary and there was a family dispute over mom's affairs. Agent did not step away from the accounts and RBC allowed mom to make decisions over the accounts beneficiaries and the poa without obtaining a letter of renewed capacity from a physician.","res":"Consent","sm":"See above","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":7},{"d":"2026-08-20","di":"2026-08-20","dr":"2026-08-20","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Department of Insurance, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"DOCKET NO.: 27E016, KSC NO.: 2027-7597","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Kansas department of insurance assistant commissioner, securities division (\"assistant commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17- 12A412(d)(9).","res":"Consent","sm":"On August 20, 2026, the assistant commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of K.A.R. 81- 3-7(a)(4) and K.S.A. 17-12A412(d)(9), to provide restitution to affected Kansas customers in an amount no less than $186,475.73, to pay a monetary fine in the amount of $100,000, and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":8},{"d":"2026-08-20","di":"2026-06-30","dr":"2026-08-20","k":"Regulatory Action","rg":"Other","reg":"Bank Indonesia (\"Bi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":113000.0,"dk":"NO. 28/335/DSMM/SRT/RHS","al":"On July 13, 2026, Bank Indonesia (\"Bi\"), pursuant to a thematic on-site visit/supervisory review,alleged that between April and May 2026, Deutsche Bank AG, Jakarta branch (\"DBJK\") facilitatedforeign exchange transfers either conducted by customers not licensed in indonesia toengage in such transactions or otherwise falling outside the scope of permitted underlyingeconomic activities under BI's FX market transaction regulation specifically relating to thirdparty FX transactions as per BI regulation no. 11 of 2024, article 17, and deemed violation oflaw no. 3 of 2011, article 69(1). In addition, BI has alleged that certain reported transactionpurposes were not fully aligned with the corresponding underlying documentation, inviolation of BI regulation no. 21/23/padg/2019.","res":"Order","ab":"Deutsche Bank AG, Jakarta","firms":[300838],"id":9},{"d":"2026-08-18","di":"2026-08-18","dr":"2026-08-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":125000.0,"dk":"2023078630201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report fractional share transactions. The findings stated that the firm has allowed customers to participate in a dividend reinvestment program (DRIP), which automatically reinvests dividends from designated securities into additional shares of the same security. At times, this results in customers holding fractional share positions in their accounts. When a client sells or transfers through the automated customer account transfer service (ACATS) a DRIP-related position with a fractional share, the firm routes out for execution the whole share portion, acting in an agency capacity, and automatically exchanges the fractional share portion for cash, acting in a principal capacity. The firm did not report approximately 2.56 million liquidations of DRIP-related fractional shares executed in a principal capacity to the FINRA/Nasdaq trade reporting facility (TRF) and the over- the-counter reporting facility (ORF) because it treated the fractional share liquidations as journal entries, not trades. As a result, the firm did not pay the regulatory transaction fees associated with the fractional share trades. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA's trade reporting rules. The firm's supervisory system was not reasonably designed to achieve compliance with its reporting obligations for fractional share trades, as the firm did not conduct any supervisory reviews specific to fractional share transactions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $125,000, and required to comply with the undertaking enumerated in this AWC. The entire portion is levied against rja. No portion of the penalty was waived. Penalty has not been paid yet.","sm":"No Information Filed","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":10},{"d":"2026-08-07","di":"2026-07-08","dr":"2026-08-07","k":"Regulatory Action","rg":"Other","reg":"Financial Services Commission, South Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":710.0,"dk":"CAPITAL MARKETS INVESTIGATION GENERAL DIVISION - 1524","al":"The south korean financial supervisory service (\"FSS\") claimed that on December 10, 2021, The Vanguard Group, Inc. (\"VGI\") engaged in the sale of one south korean listed security without corresponding ownership of the position, a practice which is prohibited under south korean law.","res":"Decision & Order of Offer of Settlement","sd":"On August 7, 2026, ~$710 usd (KRW 1 million) was submitted as voluntary payment.","sm":"On July 8, 2026, the south korean financial services commission imposed an administrative fine in the amount of ~$710 usd (KRW 1 million) on vgi in connection with one incident during 2021 in which vgi sold a south korean listed security without corresponding ownership of the position, a practice that is prohibited under south korean law.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":11},{"d":"2026-07-28","di":"2026-07-28","dr":"2026-07-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":275000.0,"dk":"2022075967301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to develop and implement an AML compliance program reasonably designed to detect and cause the reporting of suspicious transactions. The findings stated that the firm introduced three new transaction monitoring rules that were intended to identify red flags of suspicious money movements. However, the firm configured the parameters and thresholds of these monitoring rules in a manner that did not capture many of the types of transactions the rules were intended to detect. The firm configured one monitoring rule to trigger alerts based on an account's margin balance, which was typically less than the minimum threshold balance, instead of the account balance. The second monitoring rule failed to trigger useful alerts because the thresholds for total credits were set too high. The third monitoring rule generated a high volume of false positives because it captured routine transfers between accounts belonging to the same person or related parties. Because the firm improperly configured the parameters and thresholds of these monitoring rules, they either failed to generate useful alerts or otherwise did not identify red flags of suspicious money movements that the firm should have investigated. In practice the firm failed to effectively review the monitoring rules to determine whether the rules were identifying suspicious money movements in customer accounts so as to enable the firm to investigate and report the suspicious transactions. In addition, the firm delegated to two different groups responsibilities for assessing the effectiveness of the transaction monitoring rules and for decommissioning ineffective rules, but the firm did not have procedures for the two groups to coordinate or escalate concerns. Consequently, the three rules that failed to generate useful alerts remained in place for years and the firm failed to identify, investigate, and report suspicious transactions that these rules were designed to detect. The firm ultimately updated its procedures to require periodic assessments of its automated transaction monitoring rules to determine whether they are effectively enabling the firm to detect and cause the reporting of suspicious transactions.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":12},{"d":"2026-07-15","di":"2026-07-15","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Other","os":"Notice of hearing under rule 4(3) r/w 4(5) of sebi (procedures for holding inquiry and imposing penalties) rules. 1995","st":"Pending","dk":"SEBI/HO/QJC/QJC-2/P/OW/2025/0000028344/1-20","al":"The Securities and Exchange Board of India (\"SEBI\") alleges that gagan Joshi, while an employee of Advent india pe advisors private limited, became an \"insider\" with access to unpublished price sensitive information (\"UPSI\") regarding a significant investment in yes bank limited. SEBI further alleges that MR. Joshi communicated this UPSI to an unauthorized third party on July 29, 2022, in violation of regulation 3(1) of the SEBI (prohibition of insider trading) regulations, 2015, and section 12a(e) of the SEBI act, 1992.","sm":"On July 15, 2026, sebi issued a \"notice of hearing\" to gagan Joshi, an employee of Advent india pe advisors private limited in order to conduct an inquiry as per rule 4 of the sebi (procedure for holding inquiry and imposing penalties) rules, 1995. The matter is currently pending. While MR. Joshi and the registrant strongly disagree with the allegations contained in the show cause notice, MR. Joshi is fully cooperating with sebi in this matter. No sanctions have been ordered, and there has been no finding of wrongdoing at this time. No information Filed","ab":"Joshi, Gagan","firms":[105673],"id":13},{"d":"2026-07-13","di":"2026-07-13","dr":"2026-07-13","k":"Regulatory Action","rg":"State regulator","reg":"The Kansas Department of Insurance Assistant Commissioner, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"27E003","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":14},{"d":"2026-07-09","di":"2026-07-09","dr":"2026-07-09","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"dk":"URE-475-09","al":"CBOE Futures Exchange, LLC (\"CFE\") alleged that J.P. Morgan Securities LLC (\"JPMS\") violated CFE rule 410a by reporting inaccurate open interest in various futures contracts to the options clearing corporation.","res":"Consent","sm":"The allegations, dispositions, findings and sanctions of the letter of consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":15},{"d":"2026-07-09","di":"2026-07-09","dr":"2026-07-09","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"OFI-2025-06","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Louisiana Office of Financial Institutions (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of lac 10:XIII.1901 and 704(a)(9) of the Louisiana securities law.","res":"Consent","sm":"On July 9, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in lac 10:XIII.1901 and 704(a)(9) of the Louisiana securities law. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of lac 10:XIII.1901 and 704(a)(9), to provide restitution to affected Louisiana customers in an amount of no less than $47,947.14, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":16},{"d":"2026-07-08","di":"2026-07-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Plaintiff seeks damages exceeding US$50,000,000, rescissionary and restitutionary relief where legally available, a complete","st":"Pending","al":"Plaintiff seeks damages exceeding US$50,000,000, rescissionary and restitutionary relief where legally available, a complete accounting of collateral movements and ownership records, declaratory relief concerning plaintiff's rights and defendants' duties, injunctive relief to prevent further dissipation or concealment of collateral and records, pre- and post-judgment interest, costs, attorneys' fees where permitted by law or contract, and all other relief the court deems just and proper.","ab":"Canaras Capital Management, LLC","self":true,"firms":[142766],"id":17},{"d":"2026-07-07","di":"2018-05-04","dr":"2026-07-07","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Final","al":"Alleged fraudulent tax refund scheme to deceive skat into paying approximately $2.1 billion (US) of allegedly withheld dividend tax.","res":"Settled","sd":"In July 2026, pursuant to a settlement agreement between skat, doston Bradley and each of the plans involved, skat voluntarily dismissed its claims against the defendants with prejudice in exchange for payment by the defendants of an agreed-upon settlement amount.","ab":"Bradley, Doston","firms":[152175],"id":18},{"d":"2026-06-29","di":"2026-06-29","dr":"2026-06-29","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"2024.04.0446","al":"Between September 2020 and January 2023, the firm failed to implement risk management controls and supervisory procedures that were reasonably designed to prevent the entry of erroneous orders. Specifically, and due to a coding error, the firm failed to apply its average daily volume control for outbound orders to certain orders that were directed to the firm's algorithmic trading strategies. As a result, those orders were only subject to the firm's max quantity control, which was set at a threshold that was not reasonably designed to prevent the entry of erroneous orders. Based on the foregoing, the firm violated section 15(c)(3), rules 15C3-5(b) and 15C3-5(c)(l)(II) thereunder, and Nasdaq rule general 9, sections !(a) and 20(a).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":19},{"d":"2026-06-29","di":"2026-06-29","dr":"2026-06-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":7500000.0,"dk":"FILE NO. 3-22652","al":"The Securities and Exchange Commission (SEC) alleged that, from April 8, 2020 through September 10, 2024, Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&s) failed to file certain suspicious activity reports (SARS) with the U.S. Treasury department's financial crimes enforcement network, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and rule 17A-8 thereunder.","res":"Order","sm":"Without admitting the findings, MLPF&s agreed to the imposition of a cease-and-desist order, a censure, and payment of a civil monetary penalty in the amount of $7,500,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":20},{"d":"2026-06-26","di":"2026-06-26","dr":"2026-06-26","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Insurance and Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"CASE NUMBER: SO-25-908","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the North Dakota insurance commissioner (the \"commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of n.d.c.c section 10-04-11(1)(m).","res":"Consent","sm":"On June 26, 2026, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of n.d.c.c section 10-04-11(1)(m). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of n.d.c.c section 10-04-11(1)(m), to provide restitution to affected North Dakota customers in an amount no less than $46,425.80, to pay a monetary fine in the amount of $100,000, and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":21},{"d":"2026-06-26","di":"2026-06-26","dr":"2026-06-26","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"2025-CDS-036","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Colorado Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 11-51-410(1)(I), C.R.S. Of the Colorado Securities Act.","res":"Consent","sm":"On June 26, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 11-51-410(1)(I), C.R.S. Of the Colorado Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 11-51-410(1)(I), C.R.S. To provide restitution to affected Colorado customers in an amount of no less than $58,176.12, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":22},{"d":"2026-06-18","di":"2026-06-18","dr":"2026-06-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":175000.0,"dk":"2022073414901","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from January 2021 through September 2023, Merrill Lynch, Pierce, Fenner & Smith (\"Merrill lynch\") failed to provide material disclosures regarding certain municipal securities purchased with market discounts in self-directed customer accounts, in violation of municipal securities rulemaking board (\"MSRB\") rule g- 47, and failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with Merrill lynch's obligation to provide self-directed customers with all material information concerning municipal securities transactions subject to a market discount at or prior to the time of trade, in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, Merrill lynch agreed to the imposition of a censure and a fine in the amount of $175,000. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":23},{"d":"2026-06-17","dr":"2026-06-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida, Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"CASE NUMBER: 130174-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the State of Florida, Office of Financial Regulation (the \"office\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of rule 69W-600.013(1)(h)1.,Florida administrative code.","res":"Consent","sm":"On June 17, 2026, the office alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of rule 69W-600.013(1)(h)1.,Florida administrative code. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of rule 69W-600.013(1) (h)1.,Florida administrative code, to provide restitution to affected Florida customers in an amount no less than $589,389.76, to pay a monetary fine in the amount of $100,000, and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":24},{"d":"2026-06-17","di":"2022-01-01","dr":"2026-06-17","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Office of the Attorney General, Securities Division, Maryland Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":75000.0,"dk":"2022-0004","al":"Consent order finds that Masterworks, LLC (1) offered and sold securities of its issuer affiliates in the state of Maryland without first submitting required regulation a, tier II notice filings, in violation of section 11-501 of the Maryland Securities Act; and (2) offered and sold such securities through persons not registered as issuer agents, in violation of section 11-401 of the act. Masterworks self-reported the notice filing lapse in January 2022, submitted all required filings, and subsequently registered issuer agents in the state. No investor harm was alleged.","res":"Order","sd":"Civil monetary penalty of $75,000 paid by respondent at the time of issuance of the consent order with no portion waived.","sm":"Consent order was signed by the Maryland securities commissioner and consented to by respondent on June 17, 2026. No information Filed","ab":"Masterworks, LLC","firms":[324239],"id":25},{"d":"2026-06-16","di":"2026-06-16","dr":"2026-06-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; and undertakings","st":"Final","fine":125000.0,"dk":"NO. 2020067346401","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that Edward D. Jones & Co., L.P. (\"Edward jones\" or the \"firm\") failed (1) to report certain fractional share liquidations to the FINRA/Nasdaq trade reporting facility or the over-the-counter reporting facility in violation of FINRA rules 6380a, 6622 and 2010; and (2) failed to establish, maintain and enforce a supervisory system, including written supervisory procedures, reasonably designed to comply with its trade reporting obligations for fractional share trades, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On June 16 2026, the firm became subject to an AWC issued by FINRA regarding the allegations discussed in response to item 7. Without admitting or denying the findings in the AWC, the firm agreed to be censured, pay a $125,000 fine and complete certain undertakings. The fine will be paid in accordance with the terms of the AWC.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":26},{"d":"2026-06-16","di":"2026-06-16","dr":"2026-06-16","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Secretary of the Commonwealth of Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; cease and desist; and undertakings","st":"Final","fine":50000.0,"dk":"DOCKET NO. R-2026-1072","al":"In connection with an investigation conducted by the registration, inspections, compliance, and examinations (\"RICE\") section of the securities division of the office of the secretary of the commonwealth of Massachusetts (the \"division\"), the division alleged that, Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure that one of its investment adviser representatives was properly registered with Massachusetts, in violation of M.G.L. C. 110a, section 201(d)(II).","res":"Consent","sm":"On June 16, 2026, the division alleged that, Edward jones failed to ensure one of its investment adviser representatives was properly registered with Massachusetts, in violation of M.G.L. C. 110a, section 201(d)(II). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of M.G.L. C. 110a and the regulations promulgated thereunder at 950 CRM 10.00-14.413, to pay a monetary fine in the amount of $50,000, and to comply with certain undertakings. The monetary fine has been paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":27},{"d":"2026-06-15","di":"2026-06-15","dr":"2026-06-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, restitution","st":"Final","fine":20000.0,"dk":"OFI-2025-04","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":28},{"d":"2026-06-15","di":"2026-06-15","dr":"2026-06-15","k":"Regulatory Action","rg":"Other","reg":"Kentucky","san":"Cease and Desist","os":"Censure. Restitution. Administrative fine.","st":"Final","fine":20000.0,"dk":"2025-DFI-0141","al":"Respondent's minimum commission practices for certain equity transactions failed to ensure transactions were executed at a fair and reasonable price. Respondent did not reasonably supervise transactions which applied the minimum equity commission.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":29},{"d":"2026-06-10","di":"2026-06-10","dr":"2026-06-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Administrative penalty/fine","st":"Final","fine":225000.0,"dk":"2024081776401","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from January 2018 through December 2023, Merrill Lynch, Pierce, Fenner & Smith (\"Merrill lynch\") failed to accurately report summary and statistical customer complaint information to FINRA, in violation of FINRA rules 4530(d) and 2010, and failed to establish, maintain and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with FINRA rule 4530(d), in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, Merrill lynch agreed to the imposition of a censure and a fine in the amount of $225,000. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":30},{"d":"2026-06-08","di":"2026-06-08","dr":"2026-06-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan Department of Licensing and Regulatory Affairs Corporations, Securities, and Commercial Licensing Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"ENF-25-020117","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":31},{"d":"2026-06-05","di":"2026-06-05","dr":"2026-06-05","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan Department of Licensing and Regulatory Affairs, Corporations, Securities, and Commercial Licensing Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ENF-25-020116","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the State of Michigan Department of Licensing and Regulatory Affairs, Corporations, Securities, and Commercial Licensing Bureau (the \"bureau\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of MCL 451.2412(4)(I).","res":"Consent","sm":"On June 5, 2026, the bureau alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of MCL 451.2412(4)(I). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of MCL 451.2412(4)(I), to provide restitution to affected Michigan customers in an amount no less than $397,295.72, to pay a monetary fine in the amount of $100,000, and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":32},{"d":"2026-06-05","di":"2026-06-05","dr":"2026-06-05","k":"Regulatory Action","rg":"Other","reg":"California Department of Financial Protection and Innovation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"NA","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the California Department of Financial Protection and Innovation (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of California corporations code section 25218 and code regulations, title 10 section 260.218.4.","res":"Consent","sm":"On June 5, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation code of regulations, title 10 section 260.218.4. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of code of regulations, title 10 section 260.218.4, to provide restitution to affected California customers in an amount of no less than $217,067.99, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":33},{"d":"2026-06-05","di":"2026-06-05","dr":"2026-06-05","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure.","st":"Final","fine":100000000.0,"dk":"FILE NO. 3-22646","al":"On June 5, 2026, following an offer of settlement, the U.S. Securities and Exchange Commission issued an order instituting administrative and cease-and-desist proceedings, making findings, and imposing remedial sanctions and a cease-and-desist order against registrant (the \"order\") relating to certain trade allocations of the registrant's former co-CIO involving U.S. Treasury derivatives from 2021 to 2023 in certain portfolios managed by the registrant. In the order, the SEC found, among other things, that the registrant failed to implement policies and procedures reasonably designed to detect and prevent violations of the Advisers Act and failed reasonably to supervise the former co-CIO. The SEC found that the registrant thereby violated sections 203(e)(6), 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder. The order required the registrant to pay a $100 million civil penalty. Without admitting the SEC's findings, registrant consented to the entry of the order.","res":"Decision & Order of Offer of Settlement","sd":"$100,000,000","ab":"Western Asset Management Company, LLC","self":true,"firms":[110441],"id":34},{"d":"2026-06-04","di":"2026-06-04","dr":"2026-06-04","k":"Regulatory Action","rg":"Other","reg":"Michigan Department of Licensing and Regulatory Affairs; Corporations, Securities, and Commercial Licensing Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"ENF-25-020115","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Michigan department of licensing and regulatory affairs (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of MCL 451.2412(4)(I) of the Michigan uniform Securities Act.","res":"Consent","sm":"On June 4, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of MCL 451.2412(4)(I) Michigan uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed tothe imposition of a censure, to cease and desist from conduct in violation of MCL 451.2412(4)(I)of the Michigan uniform Securities Act, to provide restitution to affected Michigan customers in an amount of no less than $61,870.64, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":35},{"d":"2026-06-03","di":"2026-06-03","dr":"2026-06-03","k":"Regulatory Action","rg":"Other","reg":"District of Columbia - Department of Insurance, Securities and Banking.","san":"Cease and Desist","os":"Censure, restitution, civil and administrative fines","st":"Final","fine":20000.0,"dk":"SB-CO-07-25","al":"The respondent charged commissions in excess of 5% of the principal amount on 89,000 equity transactions over a five-year period, totaling $3,400,000.00.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The administrative fine of $20,000.00 received.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":36},{"d":"2026-05-27","di":"2026-05-27","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief the court may deem just and proper","st":"Pending","al":"On May 27, 2026, a shareholder derivative action was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital corp as a nominal defendant and certain current and former officers and directors of BlackRock TCP Capital corp as defendants. The complaints asserts claims on behalf of BlackRock TCP Capital corp for alleged violations of the Securities Exchange Act of 1934, breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024, and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.","ab":"BlackRock TCP Capital","firms":[290336],"id":37},{"d":"2026-05-21","di":"2026-05-21","dr":"2026-05-21","k":"Regulatory Action","rg":"Other","reg":"Minnesota","san":"Cease and Desist","os":"Censure; restitution; civil and administrative fines","st":"Final","fine":20000.0,"dk":"99069","al":"The respondent charged unreasonable commissions in excess of 5% of the principal amount on 89900 equity transactions over a five-year period totaling approximately $3400000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":38},{"d":"2026-05-20","di":"2026-05-20","k":"Civil Judicial Action","san":"Injunction","os":"Declaratory judgment; civil money penalties; attorneys' fees and costs; any other relief as ordered by the court.","st":"Pending","al":"The complaint alleges that iss has engaged in deceptive and unfair trade practices in connection with the provision of proxy advice that includes ESG related content.","ab":"Institutional Shareholder Services Inc.","self":true,"firms":[111940],"id":39},{"d":"2026-05-20","di":"2026-05-20","k":"Civil Judicial Action","san":"Injunction","os":"Declaratory judgment; civil penalties; restitution, disgorgement or other equitable relief; prosecution costs and fees; any","st":"Pending","al":"The complaint alleges that iss has engaged in deceptive trade practices and unfair practices in connection with the provision of proxy advice to West Virginia's residents that includes ESG-related content.","ab":"Institutional Shareholder Services Inc.","self":true,"firms":[111940],"id":40},{"d":"2026-05-14","di":"2026-05-14","dr":"2026-05-14","k":"Regulatory Action","rg":"Other","reg":"Korean Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15695.0,"dk":"N/A","al":"Allegation that on December 9, 2021, LMR Partners Limited short sold shares of a Korean-listed issuer, which it did not own.","res":"Order","sm":"On May 14, 2026, the Korean Securities and Futures Commission imposed an administrative penalty of approximately $15,695 on LMR Partners Limited (\"LMR HK\") in connection with a trade executed by LMR HK on December 9, 2021, which inadvertently resulted in an uncovered short position in the securities of an issuer listed on the korea exchange. The short position was the result of a manual operational error, which was quickly remediated and the position covered. No information Filed","ab":"LMR Partners Limited","self":true,"firms":[282637],"id":41},{"d":"2026-05-14","di":"2026-05-14","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief the court may deem just and proper.","st":"Pending","al":"On May 14, 2026, a shareholder derivative action was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital corp as a nominal defendant and certain current and former officers and directors of BlackRock TCP Capital corp as defendants. The complaint asserts claims on behalf of BlackRock TCP Capital corp for alleged violations of the Securities Exchange Act of 1934, breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024, and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.","ab":"BlackRock TCP Capital","firms":[290336],"id":42},{"d":"2026-05-12","di":"2026-05-12","dr":"2026-05-12","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Department of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"FINAL ORDER 25ADM002","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the North Carolina Department of the Secretary of State, Securities Division (the \"securities division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of N.C. Gen. Stat. Section 78a- 39(A1).","res":"Consent","sm":"On May 12, 2026, the securities division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of N.C. Gen. Stat. Section 78A-39(A1). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of N.C. Gen. Stat. Section 78A-39(A1), to provide restitution to affected North Carolina customers in an amount no less than $579,290.41, to pay a monetary fine in the amount of $100,000 (the amount paid includes a civil penalty of $10,000, and investigation costs in the amount of $90,000), and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":43},{"d":"2026-05-08","di":"2026-05-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"(1) declarations that plaintiff may maintain the action on behalf of franklin BSP realty trust, inc. and that plaintiff is an","st":"Pending","al":"Allegations that certain individual defendants breached their fiduciary duties as directors and/or officers of franklin BSP realty trust, inc. by making and/or causing the company to make materially false and misleading statements regarding the company's earnings power and ability to maintain its dividend. The complaint also alleges violations of sections 10(b), 20(a), and 14(a) of the Securities Exchange Act of 1934 and SEC rule 10B-5; unjust enrichment; abuse of control; gross mismanagement; waste of corporate assets; and, with respect to Byrne, baglien, and comparato, contribution under sections 10(b) and 21d of the Exchange Act..","ab":"Byrne, Richard, Jan","firms":[158672],"id":44},{"d":"2026-05-07","di":"2026-04-02","dr":"2026-05-07","k":"Regulatory Action","rg":"Other","reg":"Arizona Corporation Commissions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"S-21393A-26-0071","al":"Respondent violated A.R.S. § 44­32()l(a)((>) by permitting a person to render investment advice in violation of the investment management act.","res":"Consent","sd":"Fine in the amount of $7,500 paid in full on May 14, 2026.","sm":"The division concluded that Hightower Advisors, LLC, failed to obtain fingerprints for its iar's registration application with Arizona in a timely manner while the iar maintained a place of business and provided investment advisory services in Arizona. Hightower Advisors LLC, without admitting nor denying the conclusions of the division, agreed to settle the matter on the terms disclosed above. No information Filed","ab":"Hightower Advisors, LLC","self":true,"firms":[145323],"id":45},{"d":"2026-05-05","di":"2026-05-05","dr":"2026-05-05","k":"Regulatory Action","rg":"State regulator","reg":"Washington State Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; investigation costs; and undertakings","st":"Final","fine":100000.0,"dk":"ORDER NO. S-25-3996-25-CO01","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Washington State Department of Financial Institutions securities division (the \"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward","res":"Consent","sm":"On May 5, 2026, the department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of wac 460-20C-150(1)(e). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of wac 460-20C-150(1)(e), to provide restitution to affected Washington customers in an amount no less than $361,844.96, to pay an administrative fine in the amount of $100,000, to pay investigation costs in the amount of $25,000, and to comply with certain undertakings. The administrative fine and investigation costs were paid on May 5, 2026, and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":46},{"d":"2026-05-04","di":"2025-05-09","dr":"2026-05-04","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen - Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":162600.0,"dk":"25-14288","al":"Effective as of May 4, 2026, sweden's finansinspektionen (the \"sfsa\") issued a penalty, equivalent to approximately US$162,600.00, against The Goldman Sachs Group, inc. (\"GS group\") based on a finding that, during the period between March 20, 2024 and April 9, 2025, GS group failed to timely report changes in certain shareholdings held in proprietary accounts of one or more of its subsidiaries within the statutory time limits required under the Swedish financial instruments trading act.","res":"Decision","sm":"A penalty of sek 1,500,000 (approximately US$162,600) was imposed by sfsa, which was paid by GS group on May 29, 2026.","ab":"The Goldman Sachs Group,","firms":[361],"id":47},{"d":"2026-05-04","di":"2025-05-09","dr":"2026-05-04","k":"Regulatory Action","rg":"Other","reg":"Sweden's Finansinspektionen (Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":162600.0,"dk":"25-14288","al":"Effective as of May 4, 2026, sweden's finansinspektionen (the \"sfsa\") issued a fine, equivalent to approximately US $162,600.00, against The Goldman Sachs Group, inc. (\"GS group\") based on a finding that, during the period between March 20, 2024 and April 9, 2025, GS group failed to timely report changes in certain shareholdings held in proprietary accounts of one or more of its subsidiaries within the statutory time limits required under the swedish financial instruments trading act.","res":"Decision","sd":"Fine of sek 1,500,000 (approximately US $162,600) was imposed by sfsa. GS group expects to pay the fine in full on or before it is due on June 5, 2026.","sm":"Effective as of May 4, 2026, sfsa issued a fine, equivalent to approximately US $162,600.00, against GS group based on a finding that, during the period between March 20, 2024 and April 9, 2025, GS group failed to timely report changes in certain shareholdings held in proprietary accounts of one or more of its subsidiaries within the statutory time limits required under the swedish financial instruments trading act. GS group expects to pay the fine in full on or before it is due on June 5, 2026. No information Filed","ab":"The Goldman Sachs Group,","firms":[283221,286067],"id":48},{"d":"2026-04-30","di":"2026-04-30","dr":"2026-04-30","k":"Regulatory Action","rg":"Other","reg":"Office of Financial Sanctions Implementation (\"Ofsi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":223801.0,"dk":"BR/2022/2180952","al":"On April 30, 2026, Deutsche Bank AG, London branch (\"DBAG\") entered into a settlement with the united kingdom's Office of Financial Sanctions Implementation (\"Ofsi\") in which OFSI found that DBAG violated regulation 12 of the russia (SANCTIONS) (EU exit) regulations 2019 for processing two payment transactions to a company wholly owned by a designated person in June 2022 and July 2022.","res":"Settled","ab":"Deutsche Bank AG, London","firms":[300838],"id":49},{"d":"2026-04-29","di":"2024-03-27","dr":"2026-04-29","k":"Regulatory Action","rg":"State regulator","reg":"Secretary of State of Mississippi","san":"Cease and Desist","st":"Final","dk":"LS-24-6726","al":"On March 27, 2024, BlackRock, Inc., BlackRock investments, LLC, BlackRock Advisors, LLC, BlackRock Fund Advisors, and iShares trust (collectively, \"BlackRock\") were served with a summary cease and desist order and notice of intent to impose administrative penalty from the Mississippi Secretary of state. The summary order alleges that BlackRock has made misleading statements in fund prospectuses, marketing material, public statements, and on our website regarding BlackRock's ESG practices and approach to proxy voting. The summary order, which was issued to BlackRock without any prior notice or opportunity to be heard, finds that BlackRock violated the Mississippi securities laws, and orders BlackRock to refrain from future violations of those laws. On April 25, 2024, BlackRock exercised its right under Mississippi to request an administrative hearing to contest the allegations.","res":"Vacated","sd":"Not applicable","sm":"On April 29, 2026, the Mississippi Secretary of state vacated the administrative order that was issued in March 2024.","ab":"BlackRock Advisors, LLC; BlackRock Fund Advisors; BlackRock, Inc.","firms":[106614,107105,282125,290336],"id":50},{"d":"2026-04-23","di":"2026-04-23","dr":"2026-04-23","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Office of the Attorney General of the State of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"20252028","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Securities Division of the Office of the Attorney General of the State of South Carolina (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of S.C. Code ann. Section 35-1-412(d)(9).","res":"Consent","sm":"On April 23, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of S.C. Code ann. Section 35-1-412(d)(9). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of S.C. Code ann. Section 35-1-412(d)(9), to provide restitution to affected South Carolina customers in an amount of no less than $37,905.65, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":51},{"d":"2026-04-22","di":"2026-04-22","dr":"2026-04-22","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Financial Institutions","san":"p","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"2025-DFI-0142","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Kentucky department of finance institutions (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b) of the Kentucky Securities Act.","res":"Consent","sm":"On April 22, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b) of the Kentucky Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b), to provide restitution to affected Kentucky customers in an amount of no less than $37,092.78, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":52},{"d":"2026-04-22","di":"2026-04-20","dr":"2026-04-22","k":"Regulatory Action","rg":"Other","reg":"The Dutch Authority for the Financial Markets (Afm)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":350000.0,"dk":"NONE","al":"On April 20, 2026, The Dutch Authority for the Financial Markets (Afm) imposed an administrative fine of eur 297,000 (approximately $350,000) on Arrowstreet. The fine was levied in response to Arrowstreet proactively identifying and notifying the AFM that it had incorrectly reported certain short positions in two issuers between July 2020 and November 2024. The AFM concluded that these reporting errors were in violation of article 5(1) and article 6(1) of the short selling regulation (SSR). The administrative fine was paid on April 22, 2026.","res":"Decision","sd":"On April 20, 2026, The Dutch Authority for the Financial Markets (Afm) imposed an administrative fine of eur 297,000 (approximately $350,000) on Arrowstreet. The administrative fine was paid on April 22, 2026.","sm":"On April 20, 2026, The Dutch Authority for the Financial Markets (Afm) imposed an administrative fine of eur 297,000 (approximately $350,000) on Arrowstreet. The administrative fine was paid on April 22, 2026. No information Filed","ab":"Arrowstreet Capital, Limited Partnership","self":true,"firms":[111298],"id":53},{"d":"2026-04-21","di":"2026-04-21","dr":"2026-04-21","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"SB-2025-106","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Idaho Department of Finance (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of rule 105.01 and rule 105.03(d) of the Idaho uniform Securities Act.","res":"Consent","sm":"On April 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of rule 105.01 and rule 105.03(d) of the Idaho uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of rule 105.01 and rule 105.03(d), to provide restitution to affected Idaho customers in an amount of no less than $13,237.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":54},{"d":"2026-04-13","di":"2026-04-13","dr":"2026-04-13","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"2025-DFI-0145","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Kentucky Department of Financial Institutions (the \"department\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of 808 Kentucky administrative regulations (\"KAR\") 10:030, sections 3 and 4(1).","res":"Consent","sm":"On April 13, 2026, the department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of 808 kar 10:030, sections 3 and 4(1). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of 808 kar 10:030, sections 3 and 4(1), to provide restitution to affected Kentucky customers in an amount no less than $181,263.55, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":55},{"d":"2026-04-13","di":"2026-04-13","dr":"2026-04-13","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Kentucky Public Protection Cabinet Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"2025-DFI-0146","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":56},{"d":"2026-04-13","di":"2026-04-13","dr":"2026-04-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, undertaking","st":"Final","fine":125000.0,"dk":"NO. 2019062519601","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that Wells Fargo Clearing Services, LLC (\"WFCS\"), from January 2018 through July 2022, failed to report certain fractional share trades to the FINRA/Nasdaq trade reporting facility (\"FNTRF\") or the over-the counter reporting facility (\"ORF\"), in violation of FINRA rules 6380a(b), 6622(b) and 2010; from January 2018 through October 2023, failed to report certain error correction trades to the FNTRF or ORF, in violation of FINRA rules 6380a(b), 6622(b) and 2010; from January 2019 to April 2022, failed to identify the contra side executing broker-dealer in certain fractional share trade reports submitted to the FNTRF or ORF, in violation of FINRA rules 7230a(d), 7330(d) and 2010; and from January 2018 to October 2023, failed to establish, maintain and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with its trade reporting obligations, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On April 13, 2026, WFCS became subject to an AWC issued by FINRA regarding allegations that WFCS, from January 2018 through July 2022, failed to report fractional share trades to the FINRA/Nasdaq trade reporting facility (\"FNTRF\") or the over-the counter reporting facility (\"ORF\"), in violation of FINRA rules 6380a(b), 6622(b) and 2010; from January 2018 through October 2023, failed to report certain error correction trades to the FNTRF or ORF, in violation of FINRA rules 6380a(b), 6622(b) and 2010; from January 2019 to April 2022, failed to identify the contra side executing broker-dealer in certain fractional share trade reports submitted to the FNTRF or ORF, in violation of FINRA rules 7230a(d), 7330(d) and 2010; and from January 2018 to October 2023, failed to establish, maintain and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with its trade reporting obligations, in violation of FINRA rules 3110(a) and (b) and 2010.. Without admitting or denying the findings in the AWC, WFCS agreed to be censured, pay a $125,000 fine and complete certain undertakings. The fine will be paid in accordance with the terms of the AWC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":57},{"d":"2026-04-09","di":"2026-04-09","dr":"2026-04-09","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"MATTER NO. OFI-2025-02","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Louisiana Office of Financial Institutions (\"LOFI\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Louisiana securities law section 51:704(a)(9) and Louisiana administrative code (\"LAC\") 10:XIII.1901.","res":"Consent","sm":"On April 9, 2026, lofi alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Louisiana securities law section 51:704(a)(9) and lac 10:XIII.1901. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of Louisiana securities law section 51:704(a)(9) and lac 10:XIII.1901, to provide restitution to affected Louisiana customers in an amount no less than $180,147.98, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":58},{"d":"2026-04-07","di":"2026-04-07","dr":"2026-04-07","k":"Regulatory Action","rg":"Other","reg":"Puerto Rico Office of the Commissioner of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"NA","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Puerto Rico Office of the Commissioner of Financial Institutions (OCFI) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 204(a)(2)(j) of the Puerto Rico uniform Securities Act.","res":"Consent","sm":"On April 7, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the ocfi regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 204(a)(2)(j) of the Puerto Rico uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 204(a)(2)(j), to provide restitution to affected Puerto Rico customers in an amount of no less than $477.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":59},{"d":"2026-04-06","di":"2026-04-06","dr":"2026-04-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3250000.0,"dk":"2020067014002","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that, from at least January 2016 through April 2020, JPMS failed to reasonably supervise a registered representative's recommended investment strategy for suitability and his exercise of discretion in customer accounts without prior written authorization, in violation of FINRA rules 3110(a) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":60},{"d":"2026-04-02","di":"2026-04-02","dr":"2026-04-02","k":"Regulatory Action","rg":"Other","reg":"Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"2026-05","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Maine Office of Securities (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 32 M.R.S. 16412(4)(I) of the Maine uniform Securities Act.","res":"Consent","sm":"On April 2, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 32 M.R.S. 16412(4)(I) of the Maine uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 32 M.R.S. 16412(4)(I), to provide restitution to affected Maine customers in an amount of no less than $18,847.50, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":61},{"d":"2026-04-01","di":"2026-04-01","dr":"2026-04-01","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Office of the Nevada Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"FILE NO. INV25-163","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Securities Division of the Office of the Nevada Secretary of State (the \"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of NRS 90.420(1)(1) of the Nevada uniform Securities Act.","res":"Consent","sm":"On April 1, 2026, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of NRS 90.420(1)(1). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of NRS 90.420(1)(1), to provide restitution to affected Nevada customers in an amount no less than $66,759.57, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":62},{"d":"2026-04-01","di":"2026-04-01","dr":"2026-04-01","k":"Regulatory Action","rg":"State regulator","reg":"The State of Colorado Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"2025-CDS-038","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":63},{"d":"2026-03-27","di":"2026-03-27","dr":"2026-03-27","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"130178-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Florida Office of Financial Regulation (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 69W-600.013(1)(h)1 of the Florida administrative code.","res":"Consent","sm":"On March 27, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 69W-600.013(1)(h)1 of the Florida administrative code. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 9W-600.013(1)(h)1, to provide restitution to affected Florida customers in an amount of no less than $136,409.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":64},{"d":"2026-03-27","di":"2026-03-27","k":"Regulatory Action","dk":"25-00601-A","ab":"Ramirez, Ricardo","firms":[7691],"id":65},{"d":"2026-03-26","di":"2026-03-26","dr":"2026-03-26","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ORDER NO: SB-CO-06-25","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the District of Columbia Department of Insurance, Securities and Banking (the \"department\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of D.C. Official code section 31-5602.07(a)(12).","res":"Consent","sm":"On March 26, 2026, the department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of D.C. Official code section 31-5602.07(a)(12). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of D.C. Official code section 31- 5602.07(a)(12), to provide restitution to affected District of Columbia customers in an amount no less than $8,783.59, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":66},{"d":"2026-03-24","di":"2026-03-24","dr":"2026-03-24","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"(1) cease and desist from further acts and practices in violation of the act and regulations; (2) censure with respect to the","st":"Final","fine":100000.0,"dk":"R-2025-1343","al":"Without admitted nor denying the statement of facts nor the violations of law the division concluded that Hightower Advisors LLC failed to properly register its iar, who had a place of business in Massachusetts, with Massachusetts prior to providing investment advisory services.","res":"Order","sd":"Fine in the amount of $100,000 paid in full on April 7, 2026.","sm":"The division concluded that Hightower Advisors LLC failed to properly register its iar, who had a place of business in Massachusetts, with Massachusetts prior to providing investment advisory services. Hightower Advisors LLC, without admitting nor denying the conclusions of the division, agreed to settle the matter on the terms disclosed above. The subject iar was registered in another state with Hightower Advisors LLC during the subject period.","ab":"Hightower Advisors, LLC","self":true,"firms":[145323],"id":67},{"d":"2026-03-23","di":"2026-03-20","dr":"2026-03-23","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"(1) cease and desist from further acts and practices in violation of the act and regulations; (2) censure with respect to the","st":"Final","fine":57500.0,"dk":"R-2025-0421","al":"Robert W. Baird & Co. Incorporated engaged in acts and practices in violation of the act and regulations by not ensuring that its investment adviser representatives, who had a place of business in Massachusetts, were properly registered with Massachusetts prior to providing investment advisory services.","res":"Order","sd":"Administrative fine in the amount of $57,500 paid in full on 3/24/2026.","sm":"The Massachusetts Securities Division alleged that the firm failed to ensure that two investment adviser representatives with a place of business in Massachusetts were properly registered as investment adviser representatives in the state prior to providing investment advisory services. Specifically, the division alleged that the representatives began providing advisory services while their Massachusetts investment adviser representative registrations were incomplete due to the absence of required criminal offender record information (CORI) acknowledgement forms. As a result, the representatives provided investment advisory services to Massachusetts clients while unregistered. No client harm was alleged. Baird cooperated fully and corrected the issue. As part of the settlement, baird agreed to: a censure, cease and desist from further violations, review its applicable written supervisory policies and procedures, and pay a $57,500 administrative fine. After the division made baird aware of their unique form requirements, the firm promptly obtained the necessary documents to complete the application process, baird also took steps to modify its written supervisory procedures to align with the division's requirements to avoid recurrence of this issue. No information Filed","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":68},{"d":"2026-03-20","di":"2026-03-20","dr":"2026-03-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"CONSENT ORDER NO. 2026-03","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":69},{"d":"2026-03-17","di":"2026-03-17","dr":"2026-03-17","k":"Regulatory Action","rg":"State regulator","reg":"Washington Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":25000.0,"dk":"S-25-3997-26-CO01","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Washington Securities Division (securities division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wac 460-20C-150 of the Washington Securities Act.","res":"Consent","sm":"On March 17, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the securities division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wac 460-20C-150 of the Washington Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of wac 460-20C-150, to provide restitution to affected Washington customers in an amount of no less than $61,456.75, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":70},{"d":"2026-03-17","di":"2024-08-13","dr":"2026-03-17","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt Fur Finanzdienstleistungsaufsicht (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fees for cost of proceeding.","st":"Final","fine":580000.0,"dk":"ZR 7-WP 3120/00031#00030","al":"The BAFIN alleged that in a single instance in 2021, NBSH willfully filed a voting rights notification of dropping below 3% holdings in one german issuer six weeks after the filing deadline.","res":"Settled","sd":"The entire 580,000 euro fine was levied against firm's affiliate, NBSH. NBSH paid the fine on March 27, 2026.","sm":"NBSH settled a matter relating to a single late shareholder notification reporting a small reduction in position size that was due to a clerical error. The BAFIN noted the firm's cooperation in the matter. The firm has since enhanced its systems to prevent future occurrences. No information Filed","ab":"NBSH Acquisition, LLC","firms":[149822],"id":71},{"d":"2026-03-13","di":"2026-03-13","dr":"2026-03-13","k":"Regulatory Action","rg":"State regulator","reg":"Illinois Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"2500302","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Illinois Securities Department (securities department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8.E.1.EIV of the Illinois Securities Act.","res":"Consent","sm":"On March 13, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the securities department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8.E.1.EIV of the Illinois Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 8.E.1.EIV, to provide restitution to affected Illinois customers in an amount of no less than $124,665.76, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":72},{"d":"2026-03-12","di":"2026-03-12","dr":"2026-03-12","k":"Regulatory Action","rg":"Other","reg":"Saudi Central Bank (\"Sama\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1331.0,"dk":"B/26045","al":"On March 12, 2026, the Saudi Central Bank (\"Sama\") found that Deutsche Bank AG, Riyadh branch (\"DBAG\") violated article 17 of the Saudi banking control law for deposit reporting discrepancies in DBAG's September 2025 and October 2025 reports to SAMA.","res":"Order","sm":"On March 12, 2026, sama found that dbag violated article 17 of the Saudi banking control law for deposit reporting discrepancies in dbag's September 2025 and October 2025 reports to sama. Dbag was fined sar 5,000 (which is approximately $1,331 usd), which will be timely paid.","ab":"Deutsche Bank AG, Riyadh","firms":[300838],"id":73},{"d":"2026-03-09","di":"2026-03-09","dr":"2026-03-09","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"INV25-164","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Nevada Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of NRS 90.420(1)(1) of the Nevada uniform Securities Act.","res":"Consent","sm":"On March 9, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of NRS 90.420(1)(1) of the Nevada uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of NRS 90.420(1)(1), to provide restitution to affected Nevada customers in an amount of no less than $21,656.39, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":74},{"d":"2026-03-06","di":"2026-03-06","dr":"2026-03-06","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"25ADM006","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the North Carolina Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.C.G.S. 78a of the North Carolina Securities Act.","res":"Consent","sm":"On March 6, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.C.G.S. 78a of the North Carolina Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation ofn.c.g.s. 78a, to provide restitution to affected North Carolina customers in an amount of no less than $62,646.37, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":75},{"d":"2026-03-04","di":"2026-03-04","dr":"2026-03-04","k":"Regulatory Action","rg":"State regulator","reg":"Wisconsin Department of Financial Institutions Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"DFI CASE NO. S-251169 (LX)","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Wisconsin division of securities (the \"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of wis. Admin. Code section dfi-SEC 4.05(2).","res":"Consent","sm":"On March 4, 2026, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of wis. Admin. Code section dfi-SEC 4.05(2). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of wis. Admin. Code section dfi-SEC 4.05(2), to provide restitution to affected Wisconsin customers in an amount no less than $334,797.49, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":76},{"d":"2026-03-04","di":"2025-12-10","dr":"2026-03-04","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Authority of Norway (Finanstilsynet)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"al":"On December 10, 2025, the firm received a letter (the \"letter\") from the financial authority of norway (NW.: finanstilsynet) (the \"nfsa\"), notifying the firm that nfsa was considering imposing a violation penalty of nok 100,000 on the firm with regard to a trade made by York tactical energy fund, L.P. and York tactical energy fund aiv-an, L.P. (collectively, the \"ytef funds\") in shares of BLUENORD asa (\"BLUENORD\"). The ytef funds participated in a tender offer conducted by BLUENORD and ultimately sold 250,556 shares pursuant to the tender offer. The firm was uncertain as to both the number of shares that would be accepted by BLUENORD in the tender offer and the final settlement date. As a result of this sale, the firm's aggregate holdings in BLUENORD fell below 5% and a notification filing was required pursuant to the norwegian Securities Act (\"NSTA\"). While the firm made its notification filing immediately upon its compliance team being notified that the trade was accepted and had settled, nfsa indicated in the letter that it believed the firm failed to timely meet its disclosure obligations under the NSTA and, accordingly, was considering imposing the violation penalty. The nfsa issued a final determination that the firm failed to timely meet its disclosure obligations with regard to the shares sold pursuant to the tender offer and imposed a fine of nok 100,000, which the firm understands is a standard fine issued in similar circumstances. The nfsa decision was published February 19, 2026. The firm had three weeks to appeal the decision, but, to avoid the distraction and expense of litigation, the firm has elected to accept the determination instead of seeking an appeal of the decision.","res":"Decision","sd":"The fine is for nok 100,000. York paid the nok 100,000 promptly upon receipt of the final invoice from the nfsa.","ab":"York Capital Management Global Advisors, LLC","self":true,"firms":[140336],"id":77},{"d":"2026-02-27","di":"2026-02-27","dr":"2026-02-27","k":"Regulatory Action","rg":"Other","reg":"Vermont","san":"Restitution","st":"Final","fine":20000.0,"dk":"25-019-S","al":"The consent order is a result of a multistate investigation spearheaded by the north american securities administrators association, inc. the nasaa investigation revealed that from May 16, 2020, to May 16, 2025, the firm charged unreasonable fixed commissions of $95 on certain equity transactions for retail brokerage customers. The commission rate exceeded the 5% limit set out in FINRA rules. In VT, 169 equity transactions included an unreasonable commission, totaling $6872. The firm failed to establish and maintain a system to reasonably supervise its agents, in violation of V.S.R. 2-2(b)(2), incorporating FINRA rule 3110(a).","res":"Stipulation and Consent","sm":"See 13b","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":78},{"d":"2026-02-26","di":"2024-11-27","dr":"2026-02-26","k":"Civil Judicial Action","san":"Other","os":"Not applicable","st":"Final","al":"Violation of section 7 of the clayton act, 15 U.S.C. § 18; violations of section 1 of the sherman act 15 U.S.C. § 1; Texas, Montana and West Virginia state law antitrust claims.","res":"Dismissed","sd":"Not applicable","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":79},{"d":"2026-02-26","di":"2026-02-26","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Reasonable costs and expenses incurred in the action, including counsel fees and expert fees","st":"Pending","al":"A putative securities class action alleges violations of sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and rule 10B-5. The complaint alleges that defendants made materially false and misleading statements and omissions regarding the company's dividend sustainability, earnings, and business prospects, including statements concerning the company's ability to maintain its dividend and expected future earnings, during the period from November 5, 2024 through February 11, 2026. Plaintiff alleges that these statements artificially inflated the price of the company's securities and that investors suffered damages following corrective disclosures, including a dividend reduction.","ab":"Baglien, Jerome, Stephen","firms":[158672],"id":80},{"d":"2026-02-25","di":"2026-02-25","dr":"2026-02-25","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"MATTER NO. 20252027","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Securities Commissioner of South Carolina (\"commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of S.C. Code ann. Section 35-1-412(d)(9).","res":"Consent","sm":"On February 25, 2026, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of S.C. Code ann. Section 35-1-412(d)(9). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of S.C. Code ann. Section 35-1-412(d)(9), to provide restitution to affected South Carolina customers in an amount no less than $321,397.88, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":81},{"d":"2026-02-25","di":"2026-02-25","dr":"2026-02-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure","st":"Final","fine":900000.0,"dk":"3-22599","al":"The SEC found that between March 2020 and May 2020, when the coronavirus pandemic disrupted the U.S. financial markets, Madison Capital Funding LLC (\"Madison capital\"), a predecessor firm to Apogem Capital, did not price principal trades made with funds it advised at fair market value, contrary to its representations to investors. Without admitting or denying the SEC's findings, Madison capital agreed to pay a civil money penalty in the amount of $900,000 and consented to a cease and desist order that included a censure.","res":"Order","sd":"Madison capital was ordered to pay a civil money penalty in the amount of $900,000, which will be paid by March 11, 2026.","sm":"On February 25, 2026, Madison capital, without admitting or denying the SEC's findings, consented to the entry of an administrative order by the SEC finding that Madison capital violated sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-8 thereunder.","ab":"Madison Capital Funding","firms":[309234],"id":82},{"d":"2026-02-24","di":"2026-02-24","dr":"2026-02-24","k":"Regulatory Action","rg":"Other","reg":"Puerto Rico Office of the Commissioner of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"CONSENT ORDER","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the commissioner of the Puerto Rico Office of the Commissioner of Financial Institutions (\"OCFI\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 204(a)(2)(j) of the Puerto Rico uniform Securities Act (\"PRUSA\").","res":"Consent","sm":"On February 24, 2026, the ocfi alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 204(a)(2)(j) of the prusa. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of section 204(a)(2)(j) of the prusa, to provide restitution to affected Puerto Rico customers in an amount no less than $498.48, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":83},{"d":"2026-02-24","di":"2026-02-24","dr":"2026-02-24","k":"Regulatory Action","rg":"State regulator","reg":"State of North Dakota - North Dakota Insurance and Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"SO-25-911-25-2017","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":84},{"d":"2026-02-24","di":"2026-02-24","dr":"2026-02-24","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Insurance & Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"SO-25-910-25-2018","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the North Dakota Insurance & Securities Department (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.D.C.C. 10-04-11(1)(m).","res":"Consent","sm":"On February 24, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.D.C.C. 10-04-11(1)(m). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of N.D.C.C. 10-04-11(1) (m), to provide restitution to affected North Dakota customers in an amount of no less than $17,500.09, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":85},{"d":"2026-02-24","di":"2026-02-24","dr":"2026-02-24","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance","san":"Restitution","st":"Final","fine":20000.0,"dk":"SD 25-30751","al":"Excessive fees","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":86},{"d":"2026-02-24","di":"2026-02-24","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief as the court may deem just and","st":"Pending","al":"On February 24, 2026, a purported shareholder derivative action was filed in the United States district court for the central district of California. The complaint asserts claims on behalf of BlackRock TCP Capital corp for alleged breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024 and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.","ab":"BlackRock TCP Capital","firms":[290336],"id":87},{"d":"2026-02-20","di":"2026-02-20","dr":"2026-02-20","k":"Regulatory Action","rg":"State regulator","reg":"Illinois Secretary of State Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"FILE NO.: 2500298","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Illinois Secretary of State Securities Department (the \"securities department\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 8.E.1.E.IV of the Illinois securities law.","res":"Consent","sm":"On February 20, 2026, the securities department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 8.E.1.E.IV of the Illinois securities law. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of section 8.E.1.E.IV of the Illinois securities law, to provide restitution to affected Illinois customers in an amount no less than $654,428.95, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":88},{"d":"2026-02-20","di":"2025-06-20","dr":"2026-02-20","k":"Regulatory Action","rg":"Other","reg":"Mississippi","san":"Restitution","os":"Administrative fine","st":"Final","fine":22188.9,"dk":"LS-25-8156 HTTPS://WWW.SOS.MS.GOV/SECURITIES/SECURITIES-ENFORCEMENT-ACTIONS","al":"RBC charged unreasonable commissions on certain small principal equity transactions. The firm was ordered to pay restitution in the amount of $2,188.90 to Mississippi customers and an administrative penalty of $20,000.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":89},{"d":"2026-02-19","di":"2026-02-19","dr":"2026-02-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":140000.0,"dk":"2022073427701","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that (1) from May 2018 to June 2024, JPMS submitted inaccurate and incomplete Form G-32 filings to the municipal securities rulemaking board's (\"MSRB\") electronic municipal market access system (\"EMMA\") in connection with certain primary offerings of municipal securities, in violation of MSRB rule G-32; (2) from June 2020 to November 2022, JPMS did not timely submit certain offering documents to EMMA, in violation of MSRB rule G-32; and (3) from May 2018 to June 2024, JPMS's supervisory system, including written supervisory procedures, was not reasonably designed to achieve compliance with the requirement to submit accurate and complete Form G-32 filings to EMMA pursuant to MSRB rule G-32(b), in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":90},{"d":"2026-02-18","di":"2026-02-18","dr":"2026-02-18","k":"Regulatory Action","rg":"Other","reg":"Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":17000.0,"dk":"25-020-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Vermont Department of Financial Regulation (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the V.S.R. Section 2-2(b)(2) of the Vermont uniform Securities Act.","res":"Consent","sm":"On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of V.S.R. Section 2-2(b)(2)of the Vermont uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of V.S.R. Section 2-2(b)(2), to provide restitution to affected Vermont customers in an amount of no less than $3,000.00, to pay an administrative fine in the amount of $17,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":91},{"d":"2026-02-18","di":"2026-02-18","dr":"2026-02-18","k":"Regulatory Action","rg":"Other","reg":"Hawaii Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"SEB20250012","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the commissioner of securities of the state of Hawaii Department of Commerce and Consumer Affairs (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 485A-412(d)(9) of the Hawaii uniform Securities Act.","res":"Consent","sm":"On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 485A-412(d)(9) of the Hawaii uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 485A-412(d)(9), to provide restitution to affected Hawaii customers in an amount of no lessthan $13,43.05, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":92},{"d":"2026-02-11","di":"2024-12-04","dr":"2026-02-11","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"None","st":"Final","al":"This is a derivative action alleging breaches of fiduciary duty and related claims in connection with the management of a private investment fund.","res":"Dismissed","sd":"Not applicable","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":93},{"d":"2026-02-10","di":"2026-02-10","dr":"2026-02-10","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, restitution","st":"Final","fine":20000.0,"dk":"130175-S","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":94},{"d":"2026-02-05","di":"2026-02-05","dr":"2026-02-05","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities: Contact Counsel Charles Vance 717-705-2298","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution, censure, cease and desist, and undertakings","st":"Final","fine":20000.0,"dk":"260005","al":"RBC Capital Markets, LLC charged unreasonable commissions on certain equity transactions and did not reasonably surveil these transactions to ensure that respondents charged customers a reasonable commission and fee.","res":"Consent","sm":"Consent order issued to RBC Capital Markets, LLC.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":95},{"d":"2026-02-03","di":"2026-02-03","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Compensatory damages, interest, attorneys' fees and costs, and other relief.","st":"Pending","al":"On February 3, 2026, a putative securities class action lawsuit was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital Corp and certain of its current and former executive officers as defendants. The complaint purports to be brought on behalf of a class of persons who purchased or otherwise acquired BlackRock TCP Capital Corp's securities between November 6, 2024 and January 23, 2026, and alleges violations of sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and rule 10B-5 promulgated thereunder, based on alleged materially false and misleading statements and/or omissions concerning BlackRock TCP Capital Corp's business, operations and financial condition.","ab":"BlackRock TCP Capital; BlackRock TCP Capital Corp","firms":[106614,107105,290336],"id":96},{"d":"2026-01-28","di":"2026-01-28","dr":"2026-01-28","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Indiana Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d) of the Indiana uniform Securities Act.","res":"Consent","sm":"On January 28, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissionsto retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d) of the Indiana uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of acensure, to cease and desist from conduct in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d), to provide restitution to affected Indiana customers in an amount of no less than $54,428.90, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":97},{"d":"2026-01-27","di":"2026-01-27","k":"Regulatory Action","san":"Cease and Desist","os":"Cease and desist - for both Hatteras Investment Partners (HIP) and david b. Perkins censure - for both HIP and Perkins civil","st":"Final","fine":250000.0,"dk":"A-04132","al":"Allege violations of sections 206(1), (2), and (4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder.","res":"Decision & Order of Offer of Settlement","sd":"A $250,000 monetary fine applies solely to Perkins with payment terms as follows: $50,000 within 14 days $75,000 within 120 days $75,000 within 210 days $50,000 within 365 days (plus all accrued interest) Hatteras Investment Partners was not issued a monetary fine.","sm":"On January 27, 2026, the firm received a wells notice of the SEC's investigation of alleged violations of sections 206(1),(2),and (4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder arising from the management of Hatteras-sponsored funds. The wells notice provided Hatteras the opportunity to submit a response regarding the proposed recommendations. Counsel for Hatteras subsequently discussed the matter with the SEC. on September 18, 2026, the SEC found that Hatteras Investment Partners, LP and david b. Perkins willfully violated section 206(2) of the Investment Advisers Act of 1940 in connection with a transaction involving beneficient and funds advised by hip. The SEC ordered hip and Perkins to cease and desist from future violations and censured both. Perkins was also ordered to pay a $250,000 civil monetary penalty. The matter was resolved through settlement without an admission of the SEC's findings, subject to a limited exception for Perkins under certain federal bankruptcy provisions.","ab":"Perkins, David, Brien","firms":[170628],"id":98},{"d":"2026-01-21","di":"2026-01-21","dr":"2026-01-21","k":"Regulatory Action","rg":"State regulator","reg":"Investor Protection Director of the State of Delaware","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"N/A","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":99},{"d":"2026-01-21","di":"2026-01-21","dr":"2026-01-21","k":"Regulatory Action","rg":"Department of Justice","reg":"Delaware Department of Justice","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"NA","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the investor protection unit of the Delaware Department of Justice (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC(LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 6 del","res":"Consent","sm":"On January 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 6 del. C 73-304(a)(10) of the Securities Act of Delaware. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of acensure, to cease and desist from conduct in violation of 6 del. C 73-304(a)(10), to provide restitution to affected Delaware customers in an amount of no less than $13,791.58, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":100},{"d":"2026-01-21","di":"2026-01-21","dr":"2026-01-21","k":"Regulatory Action","rg":"Other","reg":"Missouri","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; cease and desist; and undertakings","st":"Final","fine":25000.0,"dk":"AP-25-06","al":"From May 16, 2020 to May 16, 2025, RBC Capital Markets, LLC allegedly charged unreasonable commissions in excess of 5% of the principal amount on certain small principal equity transactions and did not reasonably supervise transactions which applied the minimum equity commission charge to ensure that respondent charged customers a reasonable commission.","res":"Consent","sm":"RBC Capital Markets, LLC paid the administrative fine of $25,000 on 1/21/2026 and agrees to provide restitution within 120 days of the execution of this order.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":101},{"d":"2026-01-16","di":"2026-01-16","dr":"2026-01-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and civil money penalty","st":"Final","fine":200000.0,"dk":"3-22578","al":"On January 16, 2026, the SEC announced an order settling administrative cease-and-desist proceedings against Engaged Capital. According to the SEC order, Engaged Capital failed to disclose conflicts of interest regarding Engaged Capital, its personnel, and its clients' ownership of the sponsor of a special purpose acquisition company into which Engaged Capital invested client assets to provide financing for the closing of a business combination. Without admitting or denying the findings, Engaged Capital consented to the entry of the SEC's order finding that it violated section 206(2) of the Advisers Act and agreed to a cease and desist order, a censure, and a $200,000 civil penalty to settle the charges.","res":"Decision & Order of Offer of Settlement","sd":"$200,000 civil monetary penalty was paid on January 21, 2026","ab":"Engaged Capital, LLC","self":true,"firms":[161251],"id":102},{"d":"2026-01-15","di":"2026-01-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"INV25-166","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":103},{"d":"2026-01-15","di":"2026-01-15","dr":"2026-01-15","k":"Regulatory Action","rg":"Other","reg":"Utah","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"SD-25-0030","al":"Respondent charged unreasonable commissions on certain low principal equity transactions and failed to reasonably supervise low principal equity transactions where the minimum commission was in excess of 5%.","res":"Stipulation and Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":104},{"d":"2026-01-15","di":"2026-01-15","k":"Regulatory Action","rg":"Other","reg":"The Federal Financial Supervisory Authority (Bundesanstalt FÜR Finanzdienstleistungsaufsicht ­ \"BAFIN\")","st":"Pending","dk":"GZ: ZR 7-WP 3120/00032*00019","al":"The matter relates to the timing of initial filings associated with voting rights notifications of holdings in certain german issuers during the period 2019 through 2021.","sm":"Brown Capital Management LLC (\"BCM\") is currently involved in a pending administrative proceeding before a foreign financial regulatory authority pursuant to December 2025 correspondence in which BCM learned the nature of the administrative matter. Confirmation of the matter occurred on January 15, 2026. BCM has since submitted its formal response. The proceeding is administrative in nature, and while still pending, does not involve allegations of fraud, misappropriation of client assets, or intentional misconduct. No information Filed","ab":"Brown Capital Management, LLC","self":true,"firms":[105633],"id":105},{"d":"2026-01-14","di":"2026-01-14","dr":"2026-01-14","k":"Regulatory Action","rg":"Other","reg":"Office of the Commissioner of Financial Institutions San Juan, Puerto Rico","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"N/A","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":106},{"d":"2026-01-13","di":"2026-01-13","dr":"2026-01-13","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":20000.0,"dk":"NA","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Nebraska department of banking and finance (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8-1103(9)(a)(XI) of the Securities Act of Nebraska.","res":"Consent","sm":"On January 13, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8-1103(9)(a)(XI) of the Securities Act of Nebraska. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 8-1103(9)(a)(XI), to provide restitution to affected Nebraska customers in an amount of no less than $21,431.97, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":107},{"d":"2026-01-12","di":"2026-01-12","dr":"2026-01-12","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":25000.0,"dk":"AP-25-04","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Missouri Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 409.6-604 of the Missouri Securities Act of 2003 (Securities Act) and the regulations promulgated thereunder 15 CSR 30-51.010 to 15CSR 30-51.180 (regulations).","res":"Consent","sm":"On January 12, 2026, in connection with a investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Securities Act, to provide restitution to affected Missouri customers in an amount of no less than $73,920.98, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":108},{"d":"2026-01-08","di":"2026-01-08","dr":"2026-01-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1250000.0,"dk":"NO. 2022073287901","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that Wells Fargo Clearing Services, LLC (\"WFCS\"), from November 2016 through November 2023: failed to timely cancel or close out 209 failed inter-dealer municipal securities transactions totaling approximately $6.5 million and failed to timely deliver 106 municipal securities totaling approximately $3.8 million, in violation of municipal securities rulemaking board (\"MSRB\") rule G-12(h); failed to promptly obtain physical possession or control of 178 short positions totaling approximately $4.1 million resulting from failures to receive municipal securities, in violation of section 15(c)(3) of the Securities Exchange Act of 1934 (\"Exchange Act\"), Exchange Act rule 15C3-3(d)(2), and FINRA rule 2010; and failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with MSRB rule G-12(h) and Exchange Act rule 15C3-3(d)(2), in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On January 8, 2026, WFCS became subject to an AWC issued by FINRA regarding allegations that WFCS, from November 2016 through November 2023: failed to timely cancel or close out 209 failed inter-dealer municipal securities transactions totaling approximately $6.5 million and failed to timely deliver 106 municipal securities totaling approximately $3.8 million, in violation of municipal securities rulemaking board (\"MSRB\") rule G-12(h); failed to promptly obtain physical possession or control of 178 short positions totaling approximately $4.1 million resulting from failures to receive municipal securities, in violation of section 15(c)(3) of the Exchange Act, Exchange Act rule 15C3-3(d)(2), and FINRA rule 2010; and failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with MSRB rule g- 12(h) and Exchange Act rule 15C3-3(d)(2), in violation of MSRB rule G-27. Without admitting or denying the findings in the AWC, WFCS agreed to be censured and pay a $1,250,000 fine. The fine will be paid in accordance with the terms of the AWC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":109},{"d":"2026-01-07","di":"2026-01-07","dr":"2026-01-07","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Department of State Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution, and undertaking","st":"Final","fine":20000.0,"dk":"I-2025000057","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the state of New Hampshire department of state , BUREAU of securities regulation (BUREAU) alleged that, from April 30, 2020 to April 30,2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act.","res":"Consent","sm":"On January 7, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the bureau regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act,to provide restitution to affected New Hampshire customers in an amount of no less than $14,755.02, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":110},{"d":"2026-01-05","dr":"2026-01-05","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"20252030","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":111},{"d":"2026-01-05","di":"2026-01-05","dr":"2026-01-05","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Mississippi Secretary of State Office","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution, and undertaking","st":"Final","fine":20000.0,"al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the securities division of the office of the Mississippi secretary of state (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 75-71-412(d)(9) of the Mississippi Securities Act","res":"Consent","sm":"On January 5, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 75-71-412(d)(9) of the Mississippi Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 75-71-412(d)(9) of the Mississippi Securities Act, to provide restitution to affected Mississippi customers in an amount of no less than $25,095.18, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":112},{"d":"2025-12-31","di":"2025-12-31","dr":"2025-12-31","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington Department of Financial Institutions Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":30000.0,"dk":"S-25-4007-25-CO01","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":113},{"d":"2025-12-30","di":"2025-12-30","dr":"2025-12-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"A fine and an undertaking","st":"Final","fine":88079.0,"dk":"2020068424201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it did not file, or filed untimely or inaccurate, notifications with FINRA in connection with its participation in 47 distributions of securities subject to Regulation M under the Securities Exchange Act of 1934. The findings also stated that the firm failed to reasonably supervise its compliance with rule 101 of Regulation M and FINRA rule 5190.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine of 88079.00 paid on 1/12/2026.","sm":"The fine was paid on 1/12/2026.","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":114},{"d":"2025-12-30","di":"2025-12-30","dr":"2025-12-30","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","os":"A fine and an undertaking","st":"Final","fine":56921.0,"dk":"2020068424202","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it violated Nasdaq rule equity 2, section 10(e) and its predecessor, Nasdaq rule 4619(e),1 and Nasdaq rule general 9, section 1(a) by failing to file, or filing untimely, restricted period notifications and trading notifications in connection with its participation in eight distributions of securities subject to Regulation M under the Securities Exchange Act of 1934. The findings also stated that the firm failed to establish and maintain a supervisory system, including WSPS, reasonably designed to achieve compliance with Nasdaq's notification rules related to Regulation M.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine of 56921.00 debited as per Nasdaq instructions and deemed paid.","sm":"Fine debited as per Nasdaq instructions and deemed paid.","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":115},{"d":"2025-12-26","di":"2025-12-26","dr":"2025-12-26","k":"Regulatory Action","rg":"Other","reg":"Multi Commodity Exchange of India Limited","san":"Other","os":"Monetary fine","st":"Final","fine":7047.0,"dk":"NOT APPLICABLE","al":"MCX vide email dated December 26, 2025, has levied a penalty of RS. 6,34,900 ($7047) for the abnormal trades executed in crudeoilm option contracts by one of the client. Matter closed.","res":"Settled","sd":"Monetary fine - RS. 6,34,900/- ($7047)","ab":"JM Financial Services Limited","firms":[293667],"id":116},{"d":"2025-12-24","di":"2025-12-24","dr":"2025-12-24","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution, and undertaking","st":"Final","fine":20000.0,"dk":"99067","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Minnesota Department of Commerce (department) alleged that, from April 30, 2020 to April 30,2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act.","res":"Consent","sm":"On December 24,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act, to provide restitution to affected Minnesota customers in an amount of no less than $51,658.27, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":117},{"d":"2025-12-23","di":"2025-12-23","dr":"2025-12-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Wisconsin Department of Financial Institutions Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"S-251171 (LX)","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":118},{"d":"2025-12-19","di":"2025-12-19","dr":"2025-12-19","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; investigation costs; and undertakings","st":"Final","fine":100000.0,"dk":"LID-25-CAF-01","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Texas State Securities Board (the \"TSSB\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 115.10(a) of the Texas State Securities Board rules (\"board rules\")promulgated under the Texas Securities Act.","res":"Consent","sm":"On December 19, 2025, the TSSB alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 115.10(a) of the board rules. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of section 115.10(a) of the board rules, to provide restitution to affected Texas customers in an amount no less than $1,074,395.63, to pay an administrative fine in the amount of $100,000, to pay investigation costs in the amount of $25,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":119},{"d":"2025-12-19","di":"2025-12-19","dr":"2025-12-19","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":30000.0,"dk":"LID-25-CAF-04","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":120},{"d":"2025-12-19","di":"2025-12-19","dr":"2025-12-19","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, restitution and undertaking","st":"Final","fine":25000.0,"dk":"ORDER NO. LID-25-CAF-02","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Texas State Securities Board (board) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Texas Securities Act, tex. Gov't code 4001.001-4008.105.","res":"Consent","sm":"On December 19,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the board regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Texas Securities Act, tex. Gov't code 4001.001-4008.105. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 115.10(a) the Texas Securities Act, to provide restitution to affected Texas customers in an amount of no less than $146,235.88, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":121},{"d":"2025-12-19","di":"2025-12-19","dr":"2025-12-19","k":"Regulatory Action","rg":"Other","reg":"Texas","san":"Restitution","os":"Reprimand","st":"Final","fine":25000.0,"dk":"LID-25-CAF-03","al":"From May 16, 2020, to May 16, 2025, RBC Capital Markets, LLC, allegedly charged unreasonable commissions (in excess of 5% of the principal amount) on certain low principal equity transactions. Respondent did not reasonably supervise transactions which applied the minimum equity commission charge to ensure that respondent charged customers a reasonable commission. Respondent has agreed to provide resitution to affected customers in the amount charged over 5% in addition to a fine by the TSSB. Respondent has also agreed to revisit respondent's policies and procedures to ensure that respondent include safeguards to prevent the charging of excessive fees in the future.","res":"Order","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":122},{"d":"2025-12-18","di":"2025-12-18","dr":"2025-12-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist and restitution","st":"Final","fine":20000.0,"dk":"CO-25-202524-S","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":123},{"d":"2025-12-17","di":"2025-12-17","dr":"2025-12-17","k":"Regulatory Action","rg":"State regulator","reg":"The State of North Carolina Department of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25ADM004","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":124},{"d":"2025-12-16","di":"2025-04-11","dr":"2025-12-16","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":135000.0,"dk":"CASE NO. 2025-2","al":"Bloomberg SEF LLC (\"BSEF\") found that Deutsche Bank AG (\"Dbag\") failed to report error tradesin a timely manner in accordance with BSEF rules, and that DBAG failed to administersupervisory procedures to ensure that error trades were properly reported and correctedon BSEF.","res":"Settled","sm":"On December 16, 2025, dbag, without admitting or denying the findings contained therein,entered into a settlement with BSEF in which BSEF found that dbag failed to report errortrades in a timely manner in accordance with BSEF rules, and that dbag failed to administersupervisory procedures to ensure that error trades were properly reported and correctedon BSEF. Dbag agreed to a fine of usd $135,000, which will be timely paid.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":125},{"d":"2025-12-15","di":"2025-12-15","dr":"2025-12-15","k":"Regulatory Action","rg":"State regulator","reg":"Enforcement Section of the Missouri Securities Division of the Office of the Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":125000.0,"dk":"AP-25-08","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Enforcement Section of the Missouri Securities Division of the Office of the Secretary of State (the \"Enforcement section\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of 15 CSR 30-51.171(2) (a).","res":"Consent","sm":"On December 15, 2025, the Enforcement section alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of 15 CSR 30-51.171(2)(a). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of 15 CSR 30-51.171(2)(a), to provide restitution to affected Missouri customers in an amount no less than $526,569.72, to pay a monetary fine in the amount of $125,000 (the amount paid includes an administrative fine in the amount of $100,000, and investigation costs in the amount of $25,000), and to comply with certain undertakings. The monetary fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":126},{"d":"2025-12-15","di":"2025-12-15","dr":"2025-12-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Nebraska Department of Banking and Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"N/A","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":127},{"d":"2025-12-13","di":"2025-12-13","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"On December 13, 2025, an individual investor in two exchange-traded funds managed by Samsung Asset Management Company, Ltd. filed a civil lawsuit seeking damages, alleging that losses were incurred during the operation of the ETFS.","ab":"Samsung Asset Management Company, Ltd.","self":true,"firms":[158319],"id":128},{"d":"2025-12-10","di":"2025-12-10","dr":"2025-12-10","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"CBOT 25-1882-BC","al":"The Chicago Board of Trade (\"CBOT\") business conduct COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") contractually agreed to a period of time during which the firm's full discretion to determine when and under what circumstance positions could be liquidated was restricted, in violation of CBOT rule 930.k.","res":"Decision","sm":"Without admitting or denying the rule violation or factual findings in the decision, the firm agreed to pay a fine in the amount of $150,000. The fine was paid in accordance with the terms of the decision.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":129},{"d":"2025-12-10","di":"2025-12-10","dr":"2025-12-10","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"SECURITIES DOCKET NO 2022-0022","al":"On December 10, 2025, the Maryland Securities Commissioner issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Maryland Securities Act section 11-301(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Maryland Securities Act section 11-412(a)(10), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":130},{"d":"2025-12-08","di":"2025-12-08","dr":"2025-12-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Missouri Office of Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; cease and desist; and undertakings","st":"Final","fine":30000.0,"dk":"AP-25-07","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":131},{"d":"2025-12-04","di":"2025-12-04","dr":"2025-12-04","k":"Regulatory Action","rg":"Other","reg":"Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"N/A","al":"On December 4, 2025, the Oklahoma Department of Securities issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated section 1-501 of the Oklahoma uniform Securities Act of 2004, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated section 1-411(d)(9) of the Oklahoma uniform Securities Act of 2004 of the Oklahoma act, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":132},{"d":"2025-12-03","di":"2025-12-03","dr":"2025-12-03","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securites and Insurance, Office of the Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":30000.0,"dk":"SEC-2025-58E","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":133},{"d":"2025-12-03","di":"2025-12-03","dr":"2025-12-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Louisiana, Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"MATTER NO. OFI-2025-01","al":"On December 3, 2025, the state of Louisiana office of financial institutions issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated R.S. 51:712(a)(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated lac 10:XIII.1901(a), as promulgated under R.S. 51:704(a)(9), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":134},{"d":"2025-12-03","di":"2024-05-13","dr":"2025-12-03","k":"Regulatory Action","rg":"Other","reg":"National Stock Exchange of India Limited","san":"Other","os":"Monetary fine","st":"Final","fine":6083.0,"dk":"NOT APPLICABLE","al":"Nse vide its letter dated May 13, 2024 has levied a penalty of RS. 6,08,000/- ($7,296) for observations raised in inspection conducted for the period October 01, 2022 to September 30, 2023.","res":"Settled","sd":"Nse vide its letter dated May 13, 2024 has levied a penalty of RS. 6,08,000/- ($7296) for observations raised in inspection conducted for the period October 01, 2022 to September 30, 2023. Nse member committee vide its letter dated December 03, 2025, has decided to waive off the penalty of RS. 1,00,000/- ($1197) only levied with respect to inspection of branches / registered authorized persons. Matter closed.","ab":"JM Financial Services Limited","firms":[293667],"id":135},{"d":"2025-11-25","di":"2025-11-25","dr":"2025-11-25","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Censure","st":"Final","fine":7500.0,"dk":"STIPULATION #2025-0394-S","al":"Agp failed to report to the superintendent of NY department of financial services within 30 days of the final disposition of the matter, an administrative action brought by the insurance commissioner of the state of California in violation of section 2110(I) of NY insurance law; from April 2019 to September 2025 the agp website used insurance company logos without the full name and principal address of each insurer in violation of section 2122(b) of NY insurance law; agp failed to register a satellite office in violation of section 2129 of the insurance law and regulation 125.","res":"Stipulation and Consent","sd":"Fine of $7,500.00 was paid on November 25, 2025.","sm":"The violations were inadvertent and the firm paid the $7,500.00 fine to resolve the matter. No information Filed","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":136},{"d":"2025-11-25","di":"2025-11-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida, Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NUMBER: 126925","al":"On November 25, 2025, the state of Florida office of financial regulation issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated section 517.301(1)(a)2., Florida statutes, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated rule 69W-600.013, Florida administrative code, and section 517.161(1)(a), Florida statutes, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":137},{"d":"2025-11-20","di":"2025-11-20","dr":"2025-11-20","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"N/A","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":138},{"d":"2025-11-20","di":"2025-05-28","dr":"2025-11-20","k":"Regulatory Action","rg":"Other","reg":"Oregon Division of Financial Regulation","san":"Restitution","os":"Civil penalties, agreement to cease and desist from future violations, censure","st":"Final","fine":20000.0,"dk":"S-25-0035","al":"The division, in connection with a multistate task for coordinated among members of the north american securities administrators association, found that RBC charged unreasonable commissions to retail customers in excess of five percent of the principal amount.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":139},{"d":"2025-11-20","di":"2025-08-29","dr":"2025-11-20","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":375000.0,"al":"The allegation is that on June 29, 2022 the funds sold securities that were not in custody in violation of korean regulatory prohibitions on short sales.","res":"Decision","sd":"In October 2025, the Securities and Futures Commission of Korea fined Invesco Capital management LLC KRW 532,300,000 (equivalent to approximately $375,000 usd) for the violation of short sale restrictions on June 29, 2022. Invesco Capital management LLC paid the fine on November 20, 2025.","sm":"In October 2025, the Securities and Futures Commission of Korea fined Invesco Capital management LLC KRW 532,300,000 (equivalent to approximately $375,000 usd) for the violation of short sale restrictions on June 29, 2022. Invesco Capital management LLC paid the fine on November 20, 2025. No information Filed","ab":"Invesco Capital","firms":[104983],"id":140},{"d":"2025-11-20","di":"2025-11-20","k":"Civil Judicial Action","san":"Injunction","os":"Declaratory judgment; civil penalties and attorneys' fees; actual damages; court costs and restitution; and other legal or","st":"Pending","al":"The complaint alleges that iss and another proxy adviser/co-defendant have engaged in deceptive trade practices and unfair conduct arising in connection with the provision of proxy advice to Florida residents that includes ESG and dei-related content.","ab":"Institutional Shareholder Services Inc.","self":true,"firms":[111940],"id":141},{"d":"2025-11-19","di":"2025-11-19","dr":"2025-11-19","k":"Regulatory Action","rg":"Department of Justice","reg":"Delaware Department of Justice, Investor Protection Unit","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ADMINISTRATIVE CONSENT ORDER","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the director of the investor protection unit of the Delaware Department of Justice (the \"director\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Delaware Securities Act, 6 del.","res":"Consent","sm":"On November 19, 2025, the director alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of 6 del. C. Section 73-304(a)(10). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of 6 del. C. Section 73-304(a)(10), to provide restitution to affected Delaware customers in an amount no less than $30,736.41, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":142},{"d":"2025-11-18","di":"2025-11-18","dr":"2025-11-18","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securities and Insurance, Office of the Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"SEC-2025-58A","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Commissioner of securities and insurance, Montana state auditor's office (the \"Commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Montana code annotated (\"MCA\") section 30- 10-201(13)(k).","res":"Consent","sm":"On November 18, 2025, the Commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of mca section 30-10-201(13)(k). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of mca section 30-10-201(13)(k), to provide restitution to affected Montana customers in an amount no less than $67,601.53, to pay an administrative fine in the amount of $100,000, to pay investigation costs in the amount of $25,000, and to comply with certain undertakings. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":143},{"d":"2025-11-17","di":"2025-11-17","dr":"2025-11-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ADMINISTRATIVE CONSENT ORDER","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Minnesota commissioner of commerce (the \"commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Minnesota statute section 80A.67(d)(9).","res":"Consent","sm":"On November 17, 2025, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Minnesota statute section 80A.67(d)(9). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of Minnesota statute section 80A.67(d)(9), to provide restitution to affected Minnesota customers in an amount no less than $261,074.01, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":144},{"d":"2025-11-14","dr":"2025-11-14","k":"Regulatory Action","rg":"State regulator","reg":"New Hampshire Department of State Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"I-2025000054","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the New Hampshire Department of State Bureau of Securities Regulation (the \"bureau\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of New Hampshire uniform Securities Act rsa section 421-b:4- 412(d)(9).","res":"Consent","sm":"On November 14, 2025, the bureau alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of New Hampshire uniform Securities Act rsa section 421-b:4-412(d)(9). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of New Hampshire uniform Securities Act rsa section 421-b:4-412(d)(9), to provide restitution to affected New Hampshire customers in an amount no less than $63,079.49, to pay an administrative fine in the amount of $100,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":145},{"d":"2025-11-14","di":"2025-11-14","dr":"2025-11-14","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois Secretary of State - Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"2500299","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":146},{"d":"2025-11-14","di":"2025-11-14","dr":"2026-12-16","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF","st":"Final","fine":5000.0,"dk":"BLB CASE # 403","al":"On May 27, 2025, Arini, in executing an offsetting trade in the itraxx crossover index series 43 (\"ITRXEX543\") swap contract on BSEF with another participant, violated BSEF rule 516. Specifically, BSEF determined that the parties had engaged in offsetting and correcting trades of a partial notional of an initial trade executed between Arini and the participant. Pursuant to the BSEF rulebook, an \"offsetting trade\" means \"a trade executed and submitted for clearing to a clearing house, with terms and conditions that economically reverse an error trade that was accepted for clearing\" (emphasis added). Similarly, a \"correcting trade\" means \"a trade executed and submitted for clearing to a clearing house, with the same terms and conditions as an error trade other than any corrections to any operational or clerical error and the time of execution\" (emphasis added). Arini violated BSEF rule 516 when it engaged in offsetting and correcting trades that, respectively, (I) did not economically reverse the error trade and (II) did not have the same terms and conditions as the error trade. The violation did not result in financial harm to customers.","res":"Other","sd":"$5000 fine paid on December 16, 2025.","ab":"Arini Capital Management Limited","self":true,"firms":[331241],"id":147},{"d":"2025-11-12","di":"2025-11-12","dr":"2025-11-12","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6000.0,"dk":"25-1813","al":"On November 12, 2025, CME Group market regulation (\"CME\") provided notice of the conclusion of its 2025 electronic trading recordkeeping exam of Goldman Sachs & Co. LLC (\"GSCO\") for trade dates April 1 through June 30, 2025. During the review, CME identified an issue concerning certain operator ids that were active and required to be registered in the exchange fee system but were not registered until after the review period, in violation of CME rule 576 (\"identification of globex terminal operators\"). CME confirmed the operator ids were registered as of September 2, 2025.","res":"Decision","sm":"CME imposed a summary fine of $6,000, which gsco paid on December 1, 2025.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":148},{"d":"2025-11-12","di":"2025-11-12","dr":"2025-11-12","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"25-016","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Ohio Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL)charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of Ohio revised code 1707.19(a)(1)(I)('the act\") and the regulations promulgated thereunder at O.A.C. 1301:6-3 (the regulations).","res":"Consent","sm":"On November 12, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of Ohio revised code 1707.19(a)(1)(I). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of Ohio revised code 1707.19(a)(1)(I), to provide restitution to affected Ohio customers in an amount of no less than $83,284.52, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":149},{"d":"2025-11-10","di":"2025-11-10","dr":"2025-11-10","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"CO-2025-0028","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Alabama Securities Commission (commission) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation title 8, chapter 6, code of 1975, the Alabama Securities Act (the act) and the regulations promulgated thereunder at chapter 830-X1, et seq. (The regulations).","res":"Consent","sm":"On November 10, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the commission regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the act and regulations, to provide restitution to affected Alabama customers in an amount of no less than $32,983.40, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":150},{"d":"2025-11-07","di":"2025-11-07","dr":"2025-11-07","k":"Regulatory Action","rg":"State regulator","reg":"The State of North Carolina, Department of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"FILE NO. 22SEC057","al":"On November 7, 2025, The State of North Carolina, Department of the Secretary of State, Securities Division issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated N.C.G.S. Chapter §78a, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated N.C.G.S. §78a­39(A1)(1) and (2)(a), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":151},{"d":"2025-11-06","di":"2025-11-06","dr":"2025-11-06","k":"Regulatory Action","rg":"State regulator","reg":"State of Minnesota - Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":152},{"d":"2025-11-06","di":"2025-11-06","dr":"2025-11-06","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the New Mexico Regulation and Licensing Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"MX23-7-10-3","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Securities Division of the New Mexico Regulation and Licensing Department (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL)charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the New Mexico uniform Securities Act, (nmsa 1978 58-13C-412(c)(9)(the act).","res":"Consent","sm":"On November 6, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 58-13C-412(c)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the act, to provide restitution to affected New Mexico customers in an amount of no less than $7,923.15, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":153},{"d":"2025-11-05","di":"2025-11-05","dr":"2025-11-05","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securities and Office of the Insurance, Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"SEC-2025-58B","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Montana Commissioner of securities and insurance (Commissioner) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation the Securities Act of Montana, mon. Code ann. Title 30, chapter 10 parts 1-3 (Securities Act) and the regulations promulgated thereunder at admin rules of Montana, chapter 6.10, subchapters 1-7 (regulations).","res":"Consent","sm":"On November 5, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Securities Act, to provide restitution to affected Montana customers in an amount of no less than $16,711.73, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":154},{"d":"2025-10-30","di":"2025-10-30","dr":"2025-10-30","k":"Regulatory Action","rg":"State regulator","reg":"State of Alabama - Alabama Securities Commmission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":30000.0,"dk":"CO-2025-0027","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":155},{"d":"2025-10-27","di":"2025-10-27","dr":"2025-10-27","k":"Regulatory Action","rg":"Other","reg":"The Alaska Department of Commerce, Community, and Economic Development Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ORDER NO. 25-61-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the department of commerce, community, and economic development, division of banking and securities (the \"administrator\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Alaska statute (\"AS\") 45.56.440(d)(9) of the Alaska Securities Act (\"the act\").","res":"Consent","sm":"On October 27, 2025, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of as 45.56.440(d)(9) of the act. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of as 45.56.440(d)(9)of the act, to provide restitution to affected Alaska customers in an amount no less than $28,642.40, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":156},{"d":"2025-10-27","di":"2025-10-27","dr":"2025-10-27","k":"Regulatory Action","rg":"Other","reg":"Alaska Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"25-69-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Alaska Division of Banking and Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Alaska Securities Act, Alaska statue 45.56 et seq. (The act).","res":"Consent","sm":"On October 23, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 45.56.440(d)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desistfrom conduct in violation of section 45.56.440(d)(9) of the act, to provide restitution to affected Alaska customers in an amount of no less than $3,298.02, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":157},{"d":"2025-10-24","di":"2025-10-24","dr":"2025-10-24","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"SB-CO-05-25","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":158},{"d":"2025-10-23","di":"2025-10-23","dr":"2025-10-23","k":"Regulatory Action","rg":"Other","reg":"Commodity Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"25-1896","al":"Commodity Exchange, Inc. (\"COMEX\") alleged that J.P. Morgan Securities LLC (\"JPMS\") violated COMEX rule 971.A.1 by failing to maintain the total amount required to be on deposit in a secured Commodity Futures Trading Commission rule 30.7 account.","res":"Settled","sm":"The allegations, dispositions, findings and sanctions of the notice of disciplinary action are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":159},{"d":"2025-10-23","dr":"2025-10-23","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"DOCKET NO. SD-25-00-16","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Utah Division of Securities (\"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the Utah uniform Securities Act (\"act\") section 61-1-6(2)(a)(II)(j).","res":"Consent","sm":"On October 23, 2025, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of section 61-1-6(2)(a)(II)(j) of the act. Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of section 61-1-6(2)(a)(II)(j) of the act and the regulations thereunder, to provide restitution to affected Utah customers in an amount no less than $58,049.54, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":160},{"d":"2025-10-23","di":"2025-10-23","dr":"2025-10-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana Office of the Secretary of State - Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25-0012 CA","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":161},{"d":"2025-10-23","di":"2025-10-23","dr":"2025-10-23","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"SD-25-0025","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Utah Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Utah uniform Securities Act, Utah code ann. Section 61-1-1 et seq (the act) and the regulations promulgated thereunder.","res":"Stipulation and Consent","sm":"On October 23, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desistfrom conduct in violation of section 61-1-6(2)(a)(II)(j) of the act, to provide restitution to affected Utah customers in an amount of no less than $18,174.47, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":162},{"d":"2025-10-23","di":"2025-10-23","dr":"2025-10-23","k":"Regulatory Action","rg":"Other","reg":"The Arizona Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. S-21363A-25-0170 DECISION NO. 81513","al":"On October 23, 2025, The Arizona Corporation Commission issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated A.R.S. § 44­1991(a)(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated A.R.S. § 44­1961(a)(12) and ariz. Admin. Code § R14­4­131, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":163},{"d":"2025-10-21","di":"2025-10-21","dr":"2025-10-21","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Department of State Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"I-2025000058","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":164},{"d":"2025-10-21","di":"2025-10-21","dr":"2025-10-21","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"25-0058","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the West Virginia Securities Commission (commission) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the West Virginia uniform Securities Act, w.va. Code section 32-1-101 et seq. (The act) and the regulations promulgated thereunder.","res":"Consent","sm":"On October 21,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the commission regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of w.va. Code section 3-2-204(a)(2)(j) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of w.va. Code section 3-2-204(a)(2)(j) of the act, to provide restitution to affected West Virginia customers in an amount of no less than $10,306.73, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":165},{"d":"2025-10-20","di":"2025-10-20","dr":"2025-10-20","k":"Regulatory Action","rg":"State regulator","reg":"Department of Financial Protection and Innovation of the State of California","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":166},{"d":"2025-10-17","di":"2025-10-17","dr":"2025-10-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii Department of Commerce and Consumer Affairs.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"SEB20250014","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":167},{"d":"2025-10-16","di":"2025-10-16","dr":"2025-10-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25-021-S","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":168},{"d":"2025-10-16","di":"2025-10-16","dr":"2025-10-16","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"SD 25-30384","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the South Dakota Division of Insurance (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the South Dakota uniform Securities Act of 2022,SDLC CH.47-31B('the act\") and the regulations promulgated thereunder at ARSD20:08.","res":"Consent","sm":"On October 16, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 47-31B-412(d)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 47-31B-412(d)(9) of the act, to provide restitution to affected South Dakota customers in an amount of no less than $9,779.75, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":169},{"d":"2025-10-15","di":"2025-10-15","dr":"2025-10-15","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Other","os":"Summary fine","st":"Final","fine":10000.0,"dk":"2025-001","al":"ICE Futures U.S., Inc. (\"IFUS\") alleged that Citigroup Global Markets Inc. (the \"firm\") failed to timely deliver allowances in satisfaction of its entire delivery obligation for the December 2024 California carbon allowance vintage 2024 future delivery obligation, on December 27, 2024, in violation of IFUS rule 18.06(a). Cgmi ultimately fulfilled its delivery obligation and self- reported the matter to IFUS.","res":"Order","sm":"Effective October 15, 2025, the firm consented to a summary fine of $10,000 by the market regulation department of ifus in connection with allegations that it failed to timely deliver allowances in satisfaction of its entire delivery obligation for the December 2024 California carbon allowance vintage 2024 future delivery obligation, on December 27, 2024, in violation of ifus rule 18.06(a). Cgmi ultimately fulfilled its delivery obligation and self-reported the matter to ifus.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":170},{"d":"2025-10-14","di":"2025-10-14","dr":"2025-10-14","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the New Mexico Regulation and Licensing Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"CASE NO. MS 25-07-10-2","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the director of the Securities Division of the New Mexico Regulation and Licensing Department (the \"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the New Mexico uniform Securities Act 1978 section 58-13C-412(c)(9).","res":"Consent","sm":"On October 14, 2025, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of nmsa 1978 section 58-13C-412(c)(9). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the New Mexico uniform Securities Act, to provide restitution to affected New Mexico customers in an amount no less than $75,472.63, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":171},{"d":"2025-10-13","di":"2025-10-13","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"ORDER NO. S-25-0017-25-OR01","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Arkansas Securities Department (\"staff\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of ark. Code ann. Sections 23-42-301(f)(1).","res":"Consent","sm":"On October 13, 2025, the Arkansas Securities Department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of ark. Code ann. Sections 23-42-301(f)(1). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of Arkansas Securities Act and the regulations thereunder, to provide restitution to affected Arkansas customers in an amount no less than $170,530.58, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":172},{"d":"2025-10-13","di":"2025-10-13","dr":"2025-10-13","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":20000.0,"dk":"S-25-0019","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Arkansas Securities Department (department) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ark. Code ann. Section 23-42-301(f)(1).","res":"Consent","sm":"On October 13, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ark. Code ann. Section 23-42-301(f)(1). Without admitting or denying the statement of facts or violation of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of the Arkansas Securities Act's supervision requirement for broker-dealers, to provide restitution to affected Arkansas customers in an amount of no less than $30,825.89, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":173},{"d":"2025-10-10","di":"2024-09-04","dr":"2025-10-10","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"None","st":"Final","al":"This is a derivative action alleging breaches of fiduciary duty and related claims in connection with the management of a private investment fund.","res":"Dismissed","sd":"Not applicable","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":174},{"d":"2025-10-09","di":"2025-10-09","dr":"2025-10-09","k":"Regulatory Action","rg":"Other","reg":"Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"DOCKET NO. 25-018-S","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Vermont Department of Financial Regulation (\"department\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Vermont securities regulation section 2-2(b)(2).","res":"Consent","sm":"On October 9, 2025, the department alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Vermont securities regulation section 2-2(b)(2). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of Vermont's uniform Securities Act and the regulations thereunder, to provide restitution to affected Vermont customers in an amount no less than $33,919.48, to pay an administrative fine in the amount of $85,000, and to contribute $15,000 to the Vermont financial services education and victim restitution special fund. The administrative fine, the contribution and the restitution will be paid in accordance with the terms of the consent order","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":175},{"d":"2025-10-08","di":"2025-10-08","dr":"2025-10-08","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"CAUSE NO. 25-0009 CA","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Indiana securities commissioner (\"commissioner\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the Indiana uniform Securities Act (\"IUSA\") section v.","res":"Consent","sm":"On October 8, 2025, the commissioner alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of iusa I.C. Sections 23-19-4-12(d)(9) and iac sections 4-7-6(d). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of iusa I.C. Sections 23- 19-4-12(d)(9) and iac sections 4-7-6(d)and the regulations thereunder, to provide restitution to affected Indiana customers in an amount no less than $431,170.81, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":176},{"d":"2025-10-07","di":"2025-10-07","dr":"2025-10-07","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":20000.0,"dk":"250033(SEC-CAO)","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Pennsylvania Department of Banking and Securities (department) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 70 P.S. Section 1- 305(a)(VII).","res":"Consent","sm":"On October 7, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 70 P.S. Section 1-305(a)(VII). Without admitting or denying the statement of facts or violation of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of the Pennsylvania Securities Act of 1972, to provide restitution to affected Pennsylvania customers in an amount of no less than $111,354.16, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":177},{"d":"2025-10-06","di":"2025-10-06","dr":"2025-10-06","k":"Regulatory Action","rg":"Other","reg":"Oregon Division of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":20000.0,"dk":"S-25-0036","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Oregon Division of Financial Regulation (division) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ors section 59.205(13) and oar section 441-205-0210(1).","res":"Consent","sm":"On October 6, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ors section 59.205(13) and oar section 441-205-0210(1). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of ors 59.205(13), to provide restitution to affected Oregon customers in an amount of no less than $31,526.08, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":178},{"d":"2025-09-29","di":"2025-09-29","dr":"2025-09-29","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, restitution, undertaking","st":"Final","fine":75000.0,"dk":"SEC-2024-00004","al":"The Commonwealth of Virginia State Corporation Commission (commission) alleged Raymond James & Associates, Inc. and Raymond James Financial services, inc. (collectively, the respondents) charged unreasonable commissions on low-principal equity transactions to ensure that respondents charged customers a reasonable commission and fee.","res":"Order","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Virginia and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Virginia customers in an amount no less than $216,401.88. Further, total restitution to participating states in an amount no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the facts, allegations or violations of 21 vac 5-20-260d and 21 vac 5-20-280 A9.","ab":"Raymond James Financial","firms":[705],"id":179},{"d":"2025-09-25","di":"2025-09-25","dr":"2025-09-25","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":100000.0,"dk":"DIVISION ORDER NO: 25-014","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Ohio Division of Securities (\"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the Ohio revised code 1707.19(a)(1)(I).","res":"Consent","sm":"On September 25, 2025, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Ohio revised code 1707.19(a)(1)(I). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the Ohio revised code and the regulations thereunder, to provide restitution to affected Ohio customers in an amount no less than $506,326.10, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":180},{"d":"2025-09-24","di":"2025-09-24","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"On September 24, 2025, elliott investment management and certain of its affiliates (together \"elliott\") sued certain Stronghold entities for alleged breach of contract (among other claims) relating to a prior settlement agreement between the parties. Elliott moved for summary judgment on the breach of contract claim, seeking an order that Stronghold had breached the settlement agreement by failing to sell certain assets owned by SRP opportunities II, LP and srpo-II partners I, LP, two funds managed by Stronghold entities. Stronghold claimed that it was not obligated to sell the assets of those two funds because of a fiduciary exception in the settlement agreement designed to enable it to protect the interests of other limited partners in those two funds. On February 6, 2026, the Delaware court issued a partial judgment imposing a sales process largely as proposed by Stronghold for the assets of those two funds as well as a restriction on those particular funds from directly or indirectly acquiring certain types of new assets","ab":"Stronghold Resource","firms":[289466],"id":181},{"d":"2025-09-23","di":"2025-09-23","dr":"2025-09-23","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s) ( ) ( )","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":182},{"d":"2025-09-19","di":"2025-09-19","dr":"2025-09-19","k":"Regulatory Action","rg":"State regulator","reg":"State of North Dakota, Insurance & Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"SO-25-906 25-1955","al":"On September 19, 2025, the State of North Dakota, Insurance & Securities Department issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated N.D.C.C. § 10­04­15(2)(b), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated N.D.C.C. § 10­04­11­(1)(m), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":183},{"d":"2025-09-19","di":"2024-03-07","dr":"2025-09-19","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Other","os":"No action taken by sebi","st":"Final","fine":314856.0,"dk":"NOT APPLICABLE","al":"Prima facie violation of certain regulations issued by sebi.","res":"Settled","sd":"As per the settlement terms, JM Financial Limited (\"JMFL\") agreed to a voluntary debarment from acting as a lead manager in any public issue of debt securities for a period of three months from the date of the settlement order, I.E., September 19, 2025.","sm":"Within the space provided). In respect of the orders issued by sebi against JM Financial Limited (the \"JMFL\"), viz., an interim ex-parte order dated March 7, 2024 in the matter of public issue of certain debt securities, which was confirmed by the hon'ble whole time member of sebi vide the confirmatory order dated June 20, 2024, JMFL made voluntary settlement application under the sebi (settlement proceedings) regulations, 2018. Pursuant to the above application, sebi vide its order dated September 19, 2025 (the \"settlement order\") settled the proceedings that may have been initiated against JMFL in the subject matter upon JMFL making payment of the settlement amount of inr. 1,56,27,512/- ($176,591) and the disgorgement amount of inr. 1,22,35,849/- ($138,265), without JMFL admitting or denying the findings of facts and conclusions of law. Additionally, JMFL also agreed to voluntary debarment from acting as a lead manager in any public issue of debt securities for a period of 3 months from the date of the settlement order, viz. September 19, 2025. (Matter closed)","ab":"JM Financial Limited","self":true,"firms":[293667],"id":184},{"d":"2025-09-19","di":"2024-03-07","dr":"2025-09-19","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Disgorgement","os":"Public of issue of debt securities","st":"Final","dk":"NOT APPLICABLE","al":"JMFSL has been referred in the interim ex parte order dated March 7, 2024 passed by sebi against JM Financial Limited (JMFL) in the matter of public of issue of certain debt securities. The said confirmatory order imposed restrictions on JMFL to undertake any new mandate for public issue of debt securities till March 31, 2025 but clarified that JMFL can undertake public issue of equity instruments.","res":"Settled","sd":"Settlement amount . RS. 191,60,599/- ($216,515) disgorgement amount: RS. . 1,33,35,239/- ($150,688)","sm":"Within the space provided). JMFL has adhered to the said orders. JMFSL made a voluntary settlement application under the sebi (settlement proceedings) regulations, 2018. Pursuant to the said application, sebi vide its order dated September 19, 2025 (the \"settlement order\") settled the proceedings that may have been initiated against JMFSL in the subject matter upon JMFSL making payment of the settlement amount of RS. 191,60,599/- ($216,515) and the disgorgement amount of RS. 1,33,35,239/- ($150,688), without JMFSL admitting or denying the findings of facts and conclusions of law. Additionally, JMFSL also agreed to voluntary debarment from acting as a distributor in any public issue of debt securities for a period of 3 months from the date of the settlement order, viz. September 19, 2025.","ab":"JM Financial Services Limited","firms":[293667],"id":185},{"d":"2025-09-19","di":"2024-03-07","dr":"2025-09-19","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Board of India (\"Sebi\")","san":"Other","os":"Interim ex-parte order and confirmatory order","st":"Final","fine":49900.0,"dk":"NOT APPLICABLE","al":"JMFPL had been referred in the orders issued by sebi against JM Financial Limited (\"JMFL\"), viz., an interim ex-parte order dated March 7, 2024 and confirmatory order dated June 20, 2024 in the matter of public issue of certain debt securities.","res":"Settled","sd":"JMFPL made voluntary settlement application under sebi (settlement proceedings) regulations, 2018 in respect of sebi orders dated March 7, 2024 and June 20, 2024 by neither admitting nor denying the findings of fact and conclusions of law. Pursuant to the above application, sebi vide its order dated September 19, 2025 settled the proceedings that may have been initiated against JMFPL after payment of RS. 44,00,000/- ($49,900) as settlement amount. Further, JMFPL agreed for voluntary debarment from undertaking the business of initial public offer financing for a period of 3 months from the date of settlement order.","ab":"JM Financial Products Limited","firms":[293667],"id":186},{"d":"2025-09-19","di":"2023-10-31","dr":"2025-09-19","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (CME)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"N/a","st":"Final","fine":15000.0,"dk":"24-1736-BC","al":"The sro alleged that Infini Capital Management LTD. failed to adequately supervise a trader who, on October 31, 2023, executed wash type trades in CME 3 month SOFR options and CBOT 10 year U.S. Treasury note futures and options between accounts with common beneficial ownership, with the purpose of internally transferring positions, thereby breaching each exchange's rule 432.w on diligent supervision.","res":"Settled","sm":"Pursuant to an offer of settlement in which Infini neither admitted nor denied the rule violation or factual findings, a panel of the Chicago mercantile exchange business conduct committee found on September 17, 2025 that Infini violated CME rule 432.w by failing to diligently supervise a trader's wash trade activity on October 31, 2023. No suspension, bar or other conditions were imposed. No information Filed","ab":"Infini Capital Management Limited","self":true,"firms":[302067],"id":187},{"d":"2025-09-17","di":"2025-09-17","dr":"2025-09-17","k":"Regulatory Action","rg":"State regulator","reg":"Secretary of State, State of Illinois, Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NUMBER 2200547","al":"On September 17, 2025, the Illinois Secretary of state, securities department issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated 815 ilcs 5/12.g, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated 815 ilcs 5/8e(1)e by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":188},{"d":"2025-09-16","di":"2025-09-16","dr":"2025-09-16","k":"Regulatory Action","rg":"State regulator","reg":"The Assistant Commissioner, Securities Division of the Kansas Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. 25E071 / KSD NO. 2023-6858","al":"On September 16, 2025, The Assistant Commissioner, Securities Division of the Kansas Department of Insurance issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated K.S.A. 17-12A501(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated K.S.A. 17-12A412(d)(9) and K.A.R. 81-3-7(a)(2) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":189},{"d":"2025-09-16","di":"2025-09-16","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"Complaint alleges peter d. Schiff, together with qenta, inc. and brent de jong, participated in a scheme to misappropriate approximately $50 million in customer assets (including precious metals) associated with the international bank during its ocif- ordered liquidation, in violation of the commodity Exchange Act (7 U.S.C. § 1 et seq.) And rico (18 U.S.C. § 1962)","ab":"Schiff, Peter, David","firms":[152922],"id":190},{"d":"2025-09-15","di":"2025-09-15","dr":"2025-09-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Department of Commerce Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25-013","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":191},{"d":"2025-09-11","di":"2025-09-11","dr":"2025-09-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25-231","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":192},{"d":"2025-09-05","di":"2025-09-05","dr":"2025-09-05","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist","st":"Final","fine":100000.0,"dk":"DOCKET NO. 250026 (SEC-ORD)","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the department of banking and securities (\"department\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the Pennsylvania Securities Act, 70 P.S. §1­305(a)(VII).","res":"Consent","sm":"On September 5, 2025, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of the Pennsylvania Securities Act, 70 P.S. §1­305(a)(VII). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the Pennsylvania code and the regulations thereunder, to provide restitution to affected Pennsylvania customers in an amount no less than $241,040.51, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":193},{"d":"2025-09-04","di":"2025-09-04","dr":"2025-09-04","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Monetary fine, undertaking","st":"Final","fine":500000.0,"dk":"CFTC DOCKET NO. 25-01","al":"On September 4, 2025, the U.S. commodities futures trading commission (\"CFTC\") issued a settled administrative order against the bank of New York mellon (\"BNYM\") and BNY Mellon Securities Corporation (\"BNYSC\"), which found that BNYSC violated section 4g of the Commodity Exchange Act (\"CEA\") and CFTC regulation 1.35(a)(3), and that bynm violated CEA sections 4s(f)(1)(b) and 4s(g)(1) and CFTC regulations 23.201(a)(1), 23.202(a)(1) and (b)(1). Specifically, the order found that from at least May 2020 to September 2025, BNYM and BNYSC personnel communicated on platforms that were not approved for business purposes, many of which were not preserved by BNYM or BNYSC. The order also found that BNYSC failed to diligently supervise its activities in violation of CFTC regulation 166.3 and that BNYM failed to diligently supervise its activities in violation of CEA section 4s(h)(1)(b) and CFTC regulation 23.602(a).","res":"Decision & Order of Offer of Settlement","sd":"BNYM was ordered to cease and desist from violating cea sections 4s(f)(1)(b), 4s(g)(1), and 4s(h)(1)(b) and CFTC regulations 23.201(a)(1), 23.202(a)(1) and (b)(1), and 23.602(a); bnysc was ordered to cease and deist from violating cea section 4g and CFTC regulations 1.35(a)(3) and 166.3. BNYM and bnysc were jointly ordered to pay a penalty of $500,000 and to comply with certain undertakings, including implementing the recommendations of an independent compliance consultant.","sm":"Provided). BNYM and bnysc consented to entry of the order, without admitting or denying the findings or conclusions therein. The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"BNY Mellon Securities Corporation","self":true,"firms":[231],"id":194},{"d":"2025-09-04","di":"2025-09-04","dr":"2025-09-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Oregon Department of Consumer and Business Services Division of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist;","st":"Final","fine":100000.0,"dk":"CASE NO. S-25-0038","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the DIRECTOR of the department of consumer and business services (\"DIRECTOR\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of Oregon revised statutes 59.205(13) and Oregon administrative rule 441-205-0210(1).","res":"Consent","sm":"On September 4, 2025, the division alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of ors 59.205(13) and oar 441-205-0210(1). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the Oregon Securities Act and the regulations thereunder, to provide restitution to affected Oregon customers in an amount no less than $203,494.79, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":195},{"d":"2025-09-04","di":"2025-09-04","dr":"2025-09-04","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":1500000.0,"dk":"25-02","al":"The Commodity Futures Trading Commission (\"CFTC\") entered into a settlement order (\"order\") with Citigroup Global Markets Inc. (\"CGMI\") settling an administrative action that found CGMI (a) from at least 2015 to November 2022, failed to file accurate large trader reports, in violation of section 4g(a) of the Commodity Exchange Act (\"act\") and CFTC regulation 17.00(a)(1); (b) failed to maintain reliable regulatory records regarding a ten-week period in 2023, in violation of CFTC regulation 1.31(c); and (c) failed to maintain adequate supervisory controls to detect and prevent certain regulatory reporting and recordkeeping issues, in violation of CFTC regulation 166.3.","res":"Order","sm":"Without admitting or denying any of the conclusions or findings in the order, cgmi consented to: (a) the entry of the CFTC's findings; (b) cease and desist from violating section 4g(a) of the act, and CFTC regulations 1.31(c), 17.00(a)(1), and 166.3, (c) pay a civil monetary penalty in the amount of $1,500,000, and (d) comply with certain conditions and undertakings.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":196},{"d":"2025-09-03","di":"2025-09-03","dr":"2025-09-03","k":"Regulatory Action","rg":"Other","reg":"North Carolina Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5500.0,"dk":"ASD FILE #96200","al":"The North Carolina Department of Insurance alleged, pursuant to North Carolina generalstatute section 58-33-32(k), that Edward jones failed to timely report administrative actionstaken with respect to its license within 30 days after disposition of matters with state andterritory regulators following an investigation coordinated among members of the northamerican administrators association (NASAA) of its conduct.","res":"Settled","sm":"Pursuant to a voluntary settlement agreement, Edward jones agreed to pay civil penalty of$5,500.00 to the North Carolina Department of Insurance, which was paid September 3, 2025.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":197},{"d":"2025-09-03","di":"2025-09-03","dr":"2025-09-03","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist;","st":"Final","fine":100000.0,"dk":"CASE NO.: 25-0060","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the West Virginia Securities Commission alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (the \"time period\"), Edward D. Jones & Co., L.P. (\"Edward jones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of West Virginia uniform Securities Act, w. Va. Code section 32-2-204(a)(2)(j).","res":"Consent","sm":"On September 3, 2025, the West Virginia Securities Commission alleged that, during the time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of West Virginia Securities Act section 32-2-204(a)(2)(j). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the West Virginia Securities Act and the regulations thereunder, to provide restitution to affected West Virginia customers in an amount no less than $58,901.77, and to pay an administrative fine in the amount of $100,000. The administrative fine and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":198},{"d":"2025-09-03","di":"2025-09-03","dr":"2025-09-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Oregon Department of Consumer and Business Services Division of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"S-25-0037","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":199},{"d":"2025-09-03","di":"2017-04-12","dr":"2025-09-03","k":"Regulatory Action","rg":"Other","reg":"Securities & Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"N.A.","al":"The securities and exchange board of INDIA, the regulatory authority for securities and commodities market in INDIA, by letter dated April 11, 2017 informed HSBC Securities & Capital markets (INDIA) private limited (HSCI) regarding the initiation of adjudication proceedings under sebi act, 1992. The matter was in connection with one of the open offer transaction managed by HSCI.","res":"Other","ab":"HSBC Securities & Capital","firms":[324468],"id":200},{"d":"2025-09-02","di":"2025-09-02","dr":"2025-09-02","k":"Regulatory Action","rg":"State regulator","reg":"The Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"S-25-0020-25-OR01","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":201},{"d":"2025-08-26","di":"2025-08-26","dr":"2025-08-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"2021072799801","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that, from January 1, 2018 through December 30, 2021, JPMS's supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with applicable preliminary initial public offering (\"IPO\") prospectus delivery requirements for IPO allocations to JPMS's institutional customers, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":202},{"d":"2025-08-25","di":"2025-06-09","dr":"2025-08-25","k":"Regulatory Action","rg":"Other","reg":"Hong Kong Securities and Futures Commission (\"SFC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3050000.0,"dk":"[CONFIDENTIAL]","al":"The securities and futures commission of Hong Kong (the \"SFC\") commenced investigations into Deutsche Bank AG, Hong Kong branch (\"DBHK\") following self-reports made by DBHK regarding self-identified incidents, which the SFC found violated general principles 2 (DILIGENCE), 7 (compliance), and paragraphs 2.1 (accurate representations), 12.1 (compliance: general), and 16.5 (disclosure of relevant business relationships) of the code of conduct for persons licensed by or registered with the SFC. These incidents concerned incorrect assignment of product risk ratings to certain exchange-traded funds, incorrect valuation of certain floating rate debt instruments, private equity funds, and real estate funds resulting in DBHK overcharging some clients custodian and management fees, failure to apply discounted management fee rates agreed with clients to certain discretionary portfolio management accounts resulting in DBHK overcharging certain accounts management fees, and failure to disclose DBHK's investment banking relationships in certain single stock and industry research reports. DBHK conducted reviews to identify the root causes and extent of the breaches, remediated them (including fully refunding overcharged fees to the relevant client accounts), and strengthened its internal systems and controls upon identifying the breaches.","res":"Settled","sm":"DBHK cooperated with the SFC in resolving the SFC's concerns and accepted the SFC's findings and disciplinary action. Following the resolution, on August 28, 2025, the SFC issued a public reprimand and fined DBHK HKD $23.8 million (approximately usd $3,050,000), which was timely paid by DBHK. The SFC's investigation is now concluded. DBHK conducted reviews to identify the root causes and extent of the breaches, remediated them (including fully refunding overcharged fees to the relevant client accounts), and strengthened its internal systems and controls upon identifying the breaches. The SFC also publicly acknowledged DBHK's cooperation with the SFC, and that DBHK's breaches were inadvertent and did not involve any deliberate or intentional misconduct.","ab":"Deutsche Bank AG, Hong","firms":[300838],"id":203},{"d":"2025-08-22","dr":"2025-08-22","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"SD 250014","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":204},{"d":"2025-08-22","di":"2025-05-14","dr":"2025-08-22","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"None","st":"Final","al":"This is a derivative action alleging breaches of fiduciary duty, unjust enrichment, and related claims in connection with the management of a private investment fund.","res":"Dismissed","sd":"Not applicable","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":205},{"d":"2025-08-20","di":"2025-08-20","dr":"2025-08-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Alaska Department of Commerce, Community, and Economic Development Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"25-62-8","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":206},{"d":"2025-08-14","di":"2025-08-14","dr":"2025-08-14","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico Regulation and Licensing Department Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"MS-25-7-10-5","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":207},{"d":"2025-08-14","di":"2025-08-14","dr":"2025-08-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":175000.0,"dk":"2022073415101","al":"Findings that it violated rule 606(a) of regulation NMS by publishing 16 inaccurate or incomplete information in its rule 606 reports. The findings stated that the reports inaccurately disclosed the net aggregate amount of payment for order flow received by the firm, payment received by the firm related to profit-sharing relationships, transaction fees paid by the firm, and transaction rebates received by the firm. Additionally, in 11 quarterly rule 606 reports, the firm misidentified three broker- dealers as execution venues which did not quality as execution venues for purposes of rule 606 reporting. The findings also stated that the firm failed to establish and maintain a supervisory system, including WSPS, reasonably designed to achieve compliance with rule 606(a). The firm retained a third-party vendor to prepare its rule 606 reports, using data provided by the firm to generate statistical information concerning the routing of customer orders. However, the firm's WSPS did not require, and the firm did not conduct, any review to ensure that the data provided to the vendor was complete and accurate. The firm also had no supervisory system or WSPS requiring review of the material aspects disclosures in its rule 606 reports before they were published. The firm's WSPS did not require the firm to review its rule 606 reports after they were published to achieve compliance with the disclosure requirements of rule 606(a). The firm has updated its supervisory system related to rule 606 reporting, including by establishing supervisory reviews of the information provided to the vendor and published in the firm's rule 606 reports and updated its WSPS to reflect these new procedures.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":208},{"d":"2025-08-13","di":"2025-08-13","dr":"2025-08-13","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO. IC-25-CAF-04","al":"On August 13, 2025, the Texas State Securities Board issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated § 4008.052 of the Texas Securities Act, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated § 115.10 of the Texas State Securities Board rules, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":209},{"d":"2025-08-12","di":"2025-08-12","dr":"2025-08-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":90000.0,"dk":"2022075470401","al":"G g y (y p p p ) without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including WSPS, reasonably designed to achieve compliance with the provisions of MSRB rule G-37(b) governing political contributions by firms and municipal finance professionals (MFPS). The findings stated that the firm's WSPS concerning political contributions by the firm's MFPS included procedures designed to determine whether the intended recipient of a political contribution was an issuer official. However, the firm employed a different process which was not memorialized in the firm's WSPS or elsewhere for the majority of MFP political contributions to candidates for state-level offices, which were made by one of the firm's MFPS. For these political contributions, the firm outsourced its responsibility to determine whether the candidates were issuer officials to a third party. The firm directed the third party to obtain a signed certification from each candidate attesting that the candidate was not an issuer official within the meaning of MSRB rule G-37 before the MFP's contribution was made. However, the firm had no system or procedures to review whether the third party obtained a signed certification from the candidate as required before delivering a political contribution, and the firm did not conduct such reviews. The firm therefore failed to timely detect that, in some instances, the third party delivered contributions from the MFP without first receiving signed certifications, including one instance in which a political contribution was made to an issuer official and exceeded MSRB rule G-37's de minimis exception. The firm's unreasonable supervision created the risk that the firm would engage in municipal securities business in violation of MSRB rule G-37. Ultimately, the firm terminated its relationship with the third party involved in determining whether candidates were issuer officials and began requiring the legal department to review and pre-approve all MFP political contributions. Subsequently, the firm updated its WSPS to reflect these new procedures.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $90,000.","sm":"Within the space provided). This action concluded on August 12, 2025, when Stephens Inc. submitted and FINRA accepted a letter of acceptance, waiver and consent, whereby Stephens settled the matter by consenting to a censure and a $90,000 fine. No information Filed","ab":"Stephens Inc.","self":true,"firms":[3496],"id":210},{"d":"2025-08-12","di":"2025-08-12","dr":"2025-08-12","k":"Regulatory Action","rg":"State regulator","reg":"The Commissioner of Commerce and Insurance for the State of Tennessee","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"MATTER NO. 25-0000056","al":"On August 12, 2025, The Commissioner of Commerce and Insurance for the State of Tennessee issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated tenn. Code ann. § 48­1­121(a)(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated tenn. Code ann. § 48­1­112(a)(2)(j), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":211},{"d":"2025-08-12","di":"2025-08-12","dr":"2025-08-12","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii, Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NO. SEB20250001","al":"On August 12, 2025, the State of Hawaii, Department of Commerce and Consumer Affairs issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated HRS § 485a­501(a)(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated HRS § 485a­412(d)(9), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":212},{"d":"2025-08-12","di":"2025-08-12","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Compensatory or rescissory damages; reasonable costs and expenses incurred in connection with the action, including","st":"Pending","al":"Plaintiffs have alleged that there were materially false and misleading statements and omissions in kindercare learning companies, inc.'s Form S-1 registration statement that was filed on September 6, 2024 with the United States Securities and Exchange Commission.","ab":"Partners Group (USA) Inc.","firms":[162791],"id":213},{"d":"2025-08-11","di":"2025-08-11","dr":"2025-08-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":275000.0,"dk":"NO. 2023078410201","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, at least from June 2019 through November 2024, Wells Fargo Clearing Services, LLC (\"the firm\") failed to establish and maintain a supervisory system, including written supervisory procedures (\"WSPS\"), reasonably designed to achieve compliance with section 15b(a)(1)(b) of the Securities Exchange Act of 1934, which prohibits unregistered municipal advisory activity, in violation of municipal securities rulemaking board rule G-27 and FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 11, 2025, the firm became subject to an AWC issued by FINRA regarding allegations that, at least from June 2019 through November 2024, Wells Fargo Clearing Services, LLC (\"the firm\") failed to establish and maintain a supervisory system, including written supervisory procedures (\"WSPS\"), reasonably designed to achieve compliance with section 15b(a)(1)(b) of the Securities Exchange Act of 1934, which prohibits unregistered municipal advisory activity, in violation of municipal securities rulemaking board rule G-27 and FINRA rules 3110(a) and (b) and 2010.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":214},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":250000.0,"dk":"2022073415001","al":"Goldman Sachs & Co. LLC (\"GSCO\") submitted a letter of acceptance, waiver and consent (\"AWC\") that was accepted by the Financial Industry Regulatory Authority (\"FINRA\") and became final on August 7, 2025. The AWC resolved alleged violations of FINRA rules 5121 and 2010 in July 2021, and alleged violations of FINRA rules 1210, 3110 and 2010 between May 2021 and March 2022. The AWC states that GSCO participated in an initial public offering in which it had a conflict of interest, but a qualified independent underwriter did not participate in the preparation of the registration statement and prospectus. Additionally, the AWC states that GSCO permitted four individuals to perform investment banking activities requiring registration during periods when they were not registered with FINRA in any capacity, and that GSCO's supervisory system, including its written procedures, was not reasonably designed to achieve compliance with FINRA registration requirements.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 7, 2025, without admitting or denying the allegations or findings in the AWC, gsco consented to a censure and a fine in the amount of $250,000. Gsco paid the fine by wire submission on August 28, 2025.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":215},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities Contact: Deputy Chief Counsel Seamus Dubbs (717)-214-6218","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist, restitution","st":"Final","fine":20000.0,"dk":"250022","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":216},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14000.0,"dk":"MC 25-65, MC 25-82","al":"Nylic paid a $2,000 fine for failing to pay claims and interest on claims in a timely manner, in violation of Connecticut statutory requirements. Nyliac paid a $12,000 fine for permitting eight (8) producers to act as agents in Connecticut without the required appointment. Both matters were resolved via stipulation and consent orders dated August 7, 2025, and no formal hearings were held.","res":"Consent","sm":"Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance company was found to have violated section 38A-816 of the Connecticut general statutes and New York Life Insurance and annuity corporation was found to have violated section 38A-702M of the Connecticut general statutes. No information Filed","ab":"New York Life Insurance","firms":[107717,169553],"id":217},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","st":"Final","fine":2000.0,"dk":"MC 25-65","al":"Nylic paid a $2,000 fine for failing to pay claims and interest on claims in a timely manner, in violation of Connecticut statutory requirements. Resolved via stipulation and consent order dated August 7, 2025, and no formal hearing was held.","res":"Stipulation and Consent","sm":"Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance company was found to have violated section 38A-816 of the Connecticut general statutes.","ab":"New York Life Insurance","firms":[173355],"id":218},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12000.0,"dk":"MC 25-82","al":"Nyliac paid a $12,000 fine for permitting eight (8) producers to act as agents in Connecticut without the required appointment. Resolved via stipulation and consent order dated August 7, 2025, and no formal hearing was held.","res":"Stipulation and Consent","sd":"Nyliac paid a $12,000 fine.","sm":"Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance and annuity corporation was found to have violated section 38A-702M of the Connecticut general statutes.","ab":"New York Life Insurance","firms":[173355],"id":219},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14000.0,"dk":"MC 25-65; MC 25-82","al":"New York Life Insurance company (\"NYLIC\") paid a $2,000 fine for failing to pay claims and interest on claims in a timely manner, in violation of Connecticut statutory requirements. New York Life Insurance and annuity corporation (\"NYLIAC\") paid a $12,000 fine for permitting eight (8) producers to act as agents in Connecticut without the required appointment. Both matters were resolved via stipulation and consent orders dated August 7, 2025, and no formal hearings were held.","res":"Stipulation and Consent","sd":"On 8/7/2025 nylic paid a $2,000 fine; nyliac paid a $12,000 fine.","sm":"Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance company was found to have violated section 38A-816 of the Connecticut general statutes and New York Life Insurance and annuity corporation was found to have violated section 38A-702M of the Connecticut general statutes.","ab":"New York Life Insurance","firms":[309234],"id":220},{"d":"2025-08-07","di":"2025-08-07","dr":"2025-08-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12000.0,"dk":"MC 25-65; MC 25-82","al":"Nylic paid a $2,000 fine for failing to pay claims and interest on claims in a timely manner, in violation of Connecticut statutory requirements. Nyliac paid a $12,000 fine for permitting eight (8) producers to act as agents in Connecticut without the required appointment. Both matters were resolved via stipulation and consent orders dated August 7, 2025, and no formal hearings were held.","res":"Stipulation and Consent","sm":"Pursuant to a market conduct examination by the State of Connecticut Insurance Department, stipulation and final order, dated 08/07/2025, New York Life Insurance company was found to have violated section 38A-816 of the Connecticut general statutes and New York Life Insurance and annuity corporation was found to have violated section 38A-702M of the Connecticut general statutes.","ab":"New York Life Insurance","firms":[340676],"id":221},{"d":"2025-08-06","di":"2025-08-06","dr":"2025-08-06","k":"Regulatory Action","rg":"Other","reg":"Commissioner of the District of Columbia Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO: SB-CO-01-25","al":"On August 6, 2025, the Commissioner of the District of Columbia Department of Insurance, Securities and Banking issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated D.C. Official code § 31­5606.05(a)(1)(b), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated D.C. Official code § 31­5602.07(a)(12), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":222},{"d":"2025-08-04","dr":"2025-08-04","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"MATTER NO. 20224600","al":"On August 4, 2025, the Securities Commissioner of South Carolina issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated S.C. Code ann. § 35­1­501(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated S.C. Code ann. § 35­1­412(d)(9) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":223},{"d":"2025-08-04","di":"2024-03-21","dr":"2025-08-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22502","al":"Settled order provides that adviser purchased securities in a single covered offering when it had sold short shares in the same securities within the rule 105 restricted period.","res":"Consent","sd":"In connection with the settled order, adviser paid a civil monetary penalty in the amount of $250,000 to the U.S. Securities and Exchange Commission on August 6, 2025.","sm":"Without admitting or denying the finding of the settled order, adviser consented to the entry of the order, was ordered to cease and desist from violating rule 105 of Regulation M under the Exchange Act, and agreed to pay a civil monetary penalty. No information Filed","ab":"Sourcerock Group LLC","self":true,"firms":[307575],"id":224},{"d":"2025-08-01","di":"2025-08-01","dr":"2025-08-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana, Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NO. 25-0006 CA","al":"On August 1, 2025, the State of Indiana, Office of the Secretary of State Securities Division issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated ind. Code § 23­19­5­1(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated ind. Code § 23­19­4­12 by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":225},{"d":"2025-08-01","di":"2025-08-01","dr":"2025-08-01","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"Voluntary corrective measures on employees.","st":"Final","fine":6254.0,"al":"Financial services commission (FSC) alleged that Samsung Life Insurance co. LTD. has violated: - applicable regulations concerning the processing of aggregated orders by failing to pre-establish asset allocation standards for each trust; and - allocating transaction results based on averaged execution prices rather than pre-determined allocation criteria.","res":"Decision & Order of Offer of Settlement","sd":"- Voluntary corrective measures on its employee","sm":"On August 1, 2025, the FSC issued a notice of its decision, finding that Samsung Life Insurance co., LTD. was liable for the allegations listed in our response to question 7. As a result, FSC imposed a fine of KRW 90 mil in aggregate and ordered voluntary corrective measures for its employees.","ab":"Samsung Life Insurance","firms":[158319],"id":226},{"d":"2025-07-23","di":"2025-06-30","dr":"2025-07-23","k":"Regulatory Action","rg":"Other","reg":"Austrian Financial Market Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Not applicable.","st":"Final","fine":120000.0,"dk":"FMA-UL0001.100/0002-LAW/2024","al":"Global Alpha Capital Management Ltd. failed to complete all the steps required for securities disclosure with the Austrian Financial Market Authority (FMA) in January 2023. The reporting was due on January 26, 2023. Global Alpha Capital Management Ltd. filed the securities disclosure position to the FMA on January 25, 2023, but only filed securities disclosure position to the issuer (schoeller bleckmann oilfield equipment) and the exchange on February 1, 2023. The delay was a result of a clerical error and has been resolved.","res":"Decision","sd":"By a decision made on July 23, 2025 the fma has decided that Global Alpha Capital Management Ltd. shall pay a penalty fee of eur 120,000. An invoice for the penalty fee has been received and paid.","sm":"On June 30, 2025, the fma offered the firm the option to pay a fine of eur 120,000 plus 10% costs related to the proceedings, along with reimbursement of cash expenses. Thus, in total eur 132,288.60. The fma has also provided the draft verdict it intends to issue should the firm decline the option to pay. The firm accepted the option to pay on July 11, 2025. The penalty decision is final. An invoice for the penalty fee has been received and paid. No information Filed","ab":"Global Alpha Capital Management Ltd.","self":true,"firms":[161512],"id":227},{"d":"2025-07-21","di":"2016-05-27","dr":"2025-07-21","k":"Civil Judicial Action","san":"Other","os":"The company's appeal filed in district court challenging the award was dismissed","st":"Final","al":"The client naveen kumar dahiya filed an arbitration claim against the company at national stock exchange of india limited, delhi claiming an amount of RS.12,39,000 ($14400) on account of unauthorized trade/ squaring off his open positions.","res":"Dismissed","sd":"The company's appeal filed in district court challenging the award was dismissed","ab":"JM Financial Services Limited","firms":[293667],"id":228},{"d":"2025-07-18","di":"2025-07-18","dr":"2025-07-18","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Other","os":"N/a","st":"Final","fine":150000.0,"dk":"2022073415201","al":"On July 8TH, Stifel settled an administrative proceeding with the NYSE finding that, in connection with manually routed options orders, Stifel failed to record order receipt or transmission times accurately and did not detect or remediate those repeated inaccuracies.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":229},{"d":"2025-07-17","di":"2025-07-17","dr":"2025-07-17","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet (Norway)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10027.25,"al":"In 2023, Finanstilsynet fined QVT Financial LP for a purported late regulatory filing made in 2022. QVT challenged this allegation directly with Finanstilsynet in 2023 and thereafter appealed the fine to the norwegian ministry of finance (det kongelige finansdepartement). In April 2025, the ministry of finance denied our appeal. Although it is QVT's view that it did not violate any regulation, that Finanstilsynet misapplied the relevant laws and that longstanding norwegian legal standards contradict Finanstilsynet's conclusions in this matter, QVT opted not to pursue the appeal further in litigation, as the costs thereof would far eclipse this small fine assessed. Accordingly, QVT paid the fine (in July 2025), which closed the matter.","res":"Other","sd":"Paid nok 100,822","sm":"The matter is closed now that the fine has been paid. No information Filed","ab":"QVT Financial LP","self":true,"firms":[156508],"id":230},{"d":"2025-07-14","di":"2025-04-28","dr":"2025-07-14","k":"Regulatory Action","rg":"State regulator","reg":"State of California Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Examination costs","st":"Final","fine":2500.0,"dk":"FILE NO. PLBS 11444-C","al":"The State of California Department of Insurance (\"department\") alleged that Wells Fargo Clearing Services, LLC (\"WFCS\") failed to timely disclose certain administrative actions to the department, in violation of California insurance code section 1729.2, and to timely respond to an inquiry from the department related to a change in WFCS' background information, in violation of California insurance code section 1736.5.","res":"Order","sm":"On July 14, 2024, the department entered into an order with WFCS to settle an administrative action which alleged that WFCS failed to timely disclose certain administrative actions to the department, in violation of California insurance code section 1729.2, and to timely respond to an inquiry from the department related to a change in WFCS' background information, in violation of California insurance code section 1736.5. Without admitting or denying the findings in the order, WFCS agreed to pay a $2,500 monetary penalty and examination costs of $1,478. The monetary penalty and examination costs will be paid in accordance with the terms of the order.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":231},{"d":"2025-07-11","di":"2025-07-11","dr":"2025-07-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, restitution; disgorgement","st":"Final","fine":350000.0,"dk":"2019061442101","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that, from January 2017 to at least December 2018, JPMS's supervisory system, including its written supervisory procedures, was not reasonably designed to assess whether its registered representatives recommended to retail customers short-term trades of syndicate preferred stocks that may have been unsuitable, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":232},{"d":"2025-07-07","di":"2025-07-07","dr":"2025-07-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan, Department of Licensing and Regulatory Affairs, Corporations, Securities and Commercial Licensing Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ENF-24-020076","al":"On July 7, 2025, the state of Michigan department of licensing and regulatory affairs, corporations, securities and commercial licensing bureau issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated MCL 451.2501(b) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated MCL 451.2412(4)(I) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":233},{"d":"2025-07-07","di":"2022-08-18","dr":"2025-07-07","k":"Civil Judicial Action","san":"Other","os":"The appeal filed by the company was dismissed by the district court","st":"Final","al":"The client nitin joshi filed an arbitration claim against the company at national stock exchange of india limited, delhi claiming an amount of RS.1,47,065/-. The issue related to auction settlement of 1300 shares of upl limited arising out of non-fulfilment of obligation under the option contract having strike price of 729/- of expiry dated 24.02.2022","res":"Dismissed","sd":"The appeal filed by the company was dismissed by the district court","ab":"JM Financial Services Limited","firms":[293667],"id":234},{"d":"2025-06-17","di":"2025-06-17","dr":"2025-06-17","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. SB-2025-006","al":"On June 17, 2025, the state of Idaho Department of Finance issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated I.C. § 30­14­501, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated I.C. § 30­14­412 and rule 105, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":235},{"d":"2025-06-17","di":"2025-06-17","dr":"2025-06-17","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Kentucky, Public Protection Cabinet, Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"2025-DFI-0074","al":"On June 17, 2025, the Kentucky department of financial institutions issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated KRS 292.320(1)(b), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated 808 kar 10:030, section 3, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":236},{"d":"2025-06-12","di":"2025-06-12","dr":"2025-06-12","k":"Regulatory Action","rg":"State regulator","reg":"State of West Virginia, West Virginia Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NO. 22-0035","al":"On June 12, 2025, the West Virginia securities commissioner issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated w. Va. Code § 32­1­101(2), by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated w. Va. Code § 32­2­204(a)(j), by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":237},{"d":"2025-06-12","di":"2025-06-12","dr":"2025-06-12","k":"Regulatory Action","rg":"State regulator","reg":"The Arkansas Securities Department and the Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"S-22-0038","al":"On June 12, 2025, the Arkansas securities commissioner issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated ark. Code. Ann. § 23­42­507(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated ark. Code ann. § 23­42­301(f) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":238},{"d":"2025-06-12","di":"2025-06-12","k":"Regulatory Action","san":"Suspension","st":"Pending","dk":"24-01291","al":"Due to an outstanding intra-industry arbitration award in favor of MR. Frankfort's former employer, FINRA initiated a proceeding on June 12, 2025 regarding the potential suspension of MR. Frankfort from associating with any FINRA member firms.","sm":"STILL PENDING No Information Filed","ab":"Frankfort, Samuel, D","firms":[319448],"id":239},{"d":"2025-06-10","di":"2025-06-10","dr":"2025-06-10","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Order to cease and desist from future violations of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO. CO-2025-OO21","al":"On June 10, 2025, the Alabama Securities Commission issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated section 8-6-17(a)(2), code of Alabama 1975, by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated section 8-6-3(j)(10), code of Alabama 1975, by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":240},{"d":"2025-06-06","di":"2025-06-06","dr":"2025-06-06","k":"Regulatory Action","rg":"Other","reg":"European Central Bank","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8183717.0,"al":"On 6 June 2025, the ecb has issued an administrative penalty of eur 6.94 million to Belfius Bank due to non-compliance with the requirements related to the implementation of internal models. (Please note that the ecb decision of July 2023 contains 26 different obligations on which Belfius Bank NV / Belfius banque SA has all - but for obligation 1 - been acting in line with the implementation calendar imposed by the ecb.) The European Central Bank, decided on 6 June 2025 to impose an administrative penalty on Belfius Bank in an amount of eur 6,940,000. This penalty is imposed in respect of a breach of an ecb decision on internal models, for the period from 27 January 2024 to 17 March 2025. More specifically Belfius Bank failed, by the deadline of 26 January 2024, to implement the new internal models for calculating capital requirements for credit risk and to submit an audit report testing and validating these models. Consequently, it continued using outdated internal models. This decision was made pursuant to article 18(7) of council regulation (EU) no 1024/2013. The ecb has taken into account as a mitigating circumstance the fact that Belfius Bank implemented since Q1 2024 an overall add-on to temporarily mitigate the impact of the use of non- compliant internal models.","res":"Other","sd":"On 6 June 2025 the ecb has issued an administrative penalty of eur 6.94 million.","ab":"Belfius Bank","firms":[173355,340676],"id":241},{"d":"2025-06-05","di":"2025-06-05","dr":"2025-06-05","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":25000.0,"dk":"E-2025-0189","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Massachusetts Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of mass. Gen. Laws c. 110a, section 204(a)(2) (j).","res":"Consent","sm":"On June 5, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of mass. Gen. Laws c. 110a, section 204(a)(2)(j). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Massachusetts uniform Securities Act and the regulations thereunder, to provide restitution to affected Massachusetts customers in an amount of no less than $47,422.32, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":242},{"d":"2025-06-04","di":"2025-06-04","dr":"2025-06-04","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; investigation costs; and undertakings","st":"Final","fine":100000.0,"dk":"DOCKET NO. 2025-0191","al":"In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (\"NASAA\"), the Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts (\"division\") alleged that, during the period of approximately May 1, 2020 to April 30, 2025 (\"time period\"), Edward D. Jones & Co., L.P. (\"edwardjones\") failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of mass. Gen. Laws c. 110a, section 204(a)(2)(j).","res":"Consent","sm":"On June 4, 2025, the division alleged that, during time period, Edward jones failed to ensure certain transactions were executed at a fair and reasonable price and did not reasonably supervise certain small principal equity transactions that included minimum commission charges to ensure Edward jones charged its customers a reasonable commission, in violation of mass. Gen. Laws c. 110a, section 204(a)(2)(j). Without admitting or denying the statement of facts or violations of law, Edward jones agreed to the imposition of a censure, to cease and desist from conduct in violation of the Massachusetts Securities Act and the regulations thereunder, to provide restitution to affected Massachusetts customers in an amount no less than $114,782, to pay an administrative fine in the amount of $100,000, to pay investigation costs in the amount of $25,000, and to comply with certain undertakings. The administrative fine and investigation costs were paid on June 17, 2025, and the restitution will be paid in accordance with the terms of the consent order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":243},{"d":"2025-06-04","di":"2025-06-04","dr":"2025-06-04","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Secretary of the Commonwealth of Massachusetts, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":30000.0,"dk":"E-2025-0192","al":"Without admitting or denying any statements of facts or violations of law, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the charging of reasonable commissions to customers on certain low principal amount equity transactions.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":244},{"d":"2025-06-04","di":"2025-06-04","dr":"2025-06-04","k":"Regulatory Action","rg":"State regulator","reg":"Office of Secretary of the Commonwealth of Massachusetts, Securities Division.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":25000.0,"dk":"E-2025-0190","al":"RBC Capital Markets, LLC charged unreasonable commissions on certain equity transactions and did not reasonably surveil these transactions to ensure that respondent charged customers a reasonable commission and fee.","res":"Consent","sm":"RBC Capital Markets, LLC neither admitted nor denied the statement of facts and violation of G.L.C. 110a, SEC. 204(a)(2)(j).","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":245},{"d":"2025-06-02","di":"2025-06-02","dr":"2025-06-02","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000.0,"dk":"MATTER NO. 2025-404B-006","al":"ICE Clear Credit LLC (\"ICE Clear Credit\") found that Deutsche bank AG (\"DBAG\") failed to comply with ICE Clear Credit rule 404(b) relating to the timely submission of two end-of-day prices.","res":"Order","sm":"On June 2, 2025, ICE Clear Credit issued a fine notice to dbag, finding that dbag failed to comply with ICE Clear Credit rule 404(b) relating to the timely submission of two end-of-day prices. ICE Clear Credit imposed a fine of usd $4,000, which was timely paid.","ab":"Deutsche Bank AG (\"DB AG\")","firms":[300838],"id":246},{"d":"2025-05-29","di":"2022-10-31","dr":"2025-05-29","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"See below","st":"On appeal","al":"The plaintiff who is a sub-distributor of Samsung a club yield plus GEN2 qualified investment-type private placement investment trust no. 1 filed a suit for request for redemption and damages.","res":"Other","sd":"See below","ab":"Samsung Hedge Asset","firms":[158319],"id":247},{"d":"2025-05-19","di":"2025-05-19","dr":"2025-05-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"NO. 2021073472601","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from January 2014 through March 2022, Wells Fargo Clearing Services, LLC (\"the firm\") failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain registered representatives departed the firm resulting in the former representatives having access to client information through insurance carrier portals, in violation of rule 30(a) of Regulation S-P under the Securities Exchange Act of 1934 (\"Exchange Act\"), FINRA rules 3110(a) and (b) and 2010, and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On May 19, 2025, the firm became subject to an AWC issued by FINRA regarding allegations that, from January 2014 through March 2022, the firm failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain registered representatives departed the firm resulting in the former representatives having access to client information through insurance carrier portals, in violation of rule 30(a) of Regulation S-P under the Exchange Act, FINRA rules 3110(a) and (b) and 2010, and NASD rule 3010. Without admitting or denying the findings in the AWC, the firm agreed to be censured and pay a $150,000 fine. The fine will be paid in accordance with the terms of the AWC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":248},{"d":"2025-05-16","di":"2025-05-16","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Monetary damages, equitable relief, and other relief as determined by the court","st":"Pending","al":"This is a derivative action alleging breaches of fiduciary duty, unjust enrichment, and related claims in connection with the management of a private investment fund.","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":249},{"d":"2025-05-15","di":"2025-05-15","dr":"2025-05-15","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"Warning - disciplinary actions against certain employees, including a three-month suspension, a three-month salary reduction,","st":"Final","al":"Financial services commission (FSC) alleged that Samsung Securities Co. Ltd has violated: - its obligation to comply with the principle of suitability. - Duty of care by misrepresentation and omission of material facts in the sale of financial investment products.","res":"Decision & Order of Offer of Settlement","sd":"\"- Warning - disciplinary actions against certain employees, including a three-month suspension, a three-month salary reduction, warning, and etc. - voluntary corrective measures on its employee\"","sm":"On May 15, 2025, the FSC issued a notice of its decision, finding that Samsung Securities Co. Ltd. was liable for the allegations listed in our response to question 7. As a result, FSC issued a warning and ordered disciplinary actions against employees, including a three-month suspension, a three-month pay reduction, warnings, etc. additionally, the FSC ordered voluntary corrective measures for its employees.","ab":"Samsung Securities Co. Ltd","firms":[158319],"id":250},{"d":"2025-05-14","di":"2025-05-14","k":"Civil Judicial Action","san":"Other","os":"Money damages (private/civil complaint); injunction.","st":"Pending","al":"The complaint principally relates to Fiera Capital Corporation's alleged failure to provide adequate information concerning the liquidity of the canadian pooled funds in which the plaintiffs are invested, Fiera Capital Corporation's alleged failure to process redemption requests in a timely manner and the suitability for the plaintiffs of the investment in such canadian pooled funds.","ab":"Fiera Capital Corporation","firms":[113638,137637],"id":251},{"d":"2025-05-13","di":"2025-05-13","dr":"2025-05-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1355000.0,"dk":"2022074103601","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\") settled parallel matters with the Financial Industry Regulatory Authority (FINRA) and investors exchange LLC (IEX). Without admitting or denying the findings, the firm consented to the sanctions and findings by FINRA that (1) gsco failed to accurately report data for 36.6 billion equity order events to the consolidated audit trail (CAT) central repository between June 2020 and June 2023, and had related supervisory failures, in violation of FINRA rules; and (2) due to a configuration error, from October 22, 2021 to November 16, 2021, gsco made over 90 million inaccurate order memoranda, inaccurately reported over 6.8 million trades and overreported over 98,000 trades to a trade reporting facility, and issued over 372,000 inaccurate trade confirmations, and had related supervisory failures, in violation of the Securities Exchange Act of 1934 and FINRA rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"For these violations, gsco was censured and fined $1,450,000, of which $1,355,000 is payable to FINRA and the remaining amount to iex. The firm has processed its payment to FINRA via wire.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":252},{"d":"2025-05-13","di":"2025-03-24","dr":"2025-05-13","k":"Regulatory Action","rg":"Other","reg":"Reserve Bank of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":58000.0,"dk":"NO. CO. ENFD. DECB. NO.S81 6/02-03-018T2024-2025","al":"On May 13, 2025, the Reserve Bank of India (\"RBI\") found that Deutsche Bank AG, india (\"DBAG\") violated an RBI directive by failing to register certain large accounts with the credit repository of information on large credit (\"CRILC\") platform.","res":"Order","sm":"On May 13, 2025, rbi found that dbag violated an rbi directive by failing to register certain large accounts with the crilc platform. Dbag was fined inr 5,000,000 (which is approximately $58,000 usd), which was timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":253},{"d":"2025-05-12","di":"2025-05-12","dr":"2025-05-12","k":"Regulatory Action","rg":"Other","reg":"Investors Exchange LLC (Iex)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":95000.0,"dk":"2022074103602","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\") settled parallel matters with the Financial Industry Regulatory Authority (FINRA) and Investors Exchange LLC (Iex). Without admitting or denying the findings, the firm consented to the sanctions and findings by IEX that due to a configuration error, from October 22, 2021 to November 16, 2021, gsco input over 16 million orders into IEX's system with inaccurate capacity, made and kept order memoranda for those orders that reflected inaccurate capacity, and had related supervisory failures, in violation of the Securities Exchange Act of 1934 and IEX rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"For these violations, gsco was censured and fined $1,450,000, of which $95,000 is payable to iex and the remaining amount to FINRA. The firm has processed its payment to iex via wire.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":254},{"d":"2025-05-09","di":"2025-05-07","dr":"2025-05-09","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange (\"NYMEX\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":26220.0,"dk":"NYMEX 24-1817-BC","al":"The registrant was alleged to have violated NYMEX rule 562 by exceeding position limits in the October 2024 crude oil futures as of the close of business on September 17, 2024.","res":"Settled","sd":"Under the terms of the settlement, a fine of $26,220 was paid by the registrant on May 9, 2025. No portion of the penalty was waived.","sm":"Pursuant to an offer of settlement in which Pacific Investment Management Company LLC (\"PIMCO\") neither admitted nor denied the rule violation or factual findings upon which the penalty was based, on May 7, 2025, a PANEL of the NYMEX business conduct committee (\"PANEL\") found that at the close of business on September 17, 2024, PIMCO held a short futures-equivalent position of 6,325 contracts in October 2024 crude oil futures, which was 325 contracts (5.42%) over the position limit. PIMCO liquidated its overage position the next trading day, which resulted in a $11,220.00 profit. The PANEL found that PIMCO violated rule 562 as a result of the foregoing. In accordance with the settlement offer, the PANEL ordered PIMCO to pay a $15,000 fine and disgorge $11,220.00 No information Filed","ab":"Pacific Investment Management Company LLC","self":true,"firms":[104559],"id":255},{"d":"2025-05-08","di":"2024-03-31","dr":"2025-05-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Delaware Insurance Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":133500.0,"dk":"DOCKET NO. 5635","al":"It was alleged that Massachusetts Mutual Life insurance company's practices and procedures did not comply with statutory and regulatory provisions: 18 del admin. C.§1203­4.0 life insurance solicitation definitions; 18 del. Admin c. §1204­5.2 duties of agents and brokers; 18 del. C. §1204.7.1 duties of insurers that use agents or brokers; 18 del. Admin. C. §1204­7.4 standards for basic illustrations.","res":"Stipulation and Consent","sd":"Massachusetts Mutual Life insurance company paid an administrative penalty of $133,500.00 on May 6, 2025. No portion of the administrative penalty was waived.","sm":"The department, through its examiners, conducted a target market conduct examination of Massachusetts Mutual Life insurance company's affairs and practices as of March 31, 2024. The department provided Massachusetts Mutual Life insurance company with a verified written report of the examination and Massachusetts Mutual Life insurance company reviewed and provided the department with comments on the examination report. The department through its examiners prepared a final report of the examination dated as of March 31, 2024 (the final examination report). The final examination report concluded that Massachusetts Mutual Life insurance company's practices and procedures did not comply with statutory and regulatory provisions. Massachusetts Mutual Life insurance company accepted the final examination report and waived any right to a hearing and agreed that the department may file the final examination report without any further modifications. Massachusetts Mutual Life insurance company paid an administrative penalty for the violations in the amount of $133,500.00 on May 6, 2025. The department will post a copy of the final examination report and the stipulation and consent on the department's public website. Within 1 year of the date of the final examination report, the department may re-examine the exceptions and recommendations in the final examination report and determine whether the corrective actions were appropriate, properly implemented and effective. No information Filed","ab":"Massachusetts Mutual Life","firms":[106006],"id":256},{"d":"2025-05-08","di":"2024-03-31","dr":"2025-05-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Delaware Insurance Commissioner","st":"Final","fine":133500.0,"dk":"5635","res":"Acceptance, Waiver & Consent(AWC)","sd":"Massachusetts Mutual Life insurance company accepted the final examination report and waived any right to a hearing and agreed that the department may file the final examination report without any further modifications. Massachusetts Mutual Life insurance company paid an administrative penalty for the violations in the amount of $133, 500.00 on May 6, 2025.","sm":"It was alleged that Massachusetts Mutual Life insurance company's practices and procedures did not comply with statutory and regulatory provisions: 18 del admin. C.§1203­4.0 life insurance solicitation definitions; 18 del. Admin c. §1204­5.2 duties of agents and brokers; 18 del. C. §1204.7.1 duties of insurers that use agents or brokers; 18 del. Admin. C. §1204­7.4 standards for basic illustrations. Respondent shall immediately implement corrective actions for any and all exceptions and recommendations included in the final examination report and shall report the completion of the corrective actions to the department within 30 days of the date of the consent order. The department, through its examiners, conducted a target market conduct examination of Massachusetts Mutual Life insurance company's affairs and practices as of March 31, 2024. The department provided Massachusetts Mutual Life insurance company with a verified written report of the examination and Massachusetts Mutual Life insurance company reviewed and provided the department with comments on the examination report. The department through its examiners prepared a final report of the examination dated as of March 31, 2024 (the final examination report). The final examination report concluded that Massachusetts Mutual Life insurance company's practices and procedures did not comply with statutory and regulatory provisions. Massachusetts Mutual Life insurance company accepted the final examination report and waived any right to a hearing and agreed that the department may file the final examination report without any further modifications. Massachusetts Mutual Life insurance company paid an administrative penalty for the violations in the amount of $133, 500.00 on May 6, 2025. The department will post a copy of the final examination report and the stipulation and consent on the department's public website. Within 1 year of the date of the final examination report, the department may re-examine the exceptions and recommendations in the final examination report and determine whether the corrective actions were appropriate, properly implemented and effective.","ab":"Massachusetts Mutual Life","firms":[162264],"id":257},{"d":"2025-05-07","di":"2025-05-07","dr":"2025-05-07","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15386.0,"dk":"REF. NO DSA-2024-06-0183B-DSA-L-BA-FBL","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for non-compliance with the mandatory credit allocation for agriculture, fisheries and rural development (AFRD) for the quarters ended 3-31-2023 through 6-30-2023.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP852,673.62(approximately USD15,386) on bana. The penalty amount was reduced to account for bana's penalty amount being over-assessed in connection with a prior letter. The payment will be made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":258},{"d":"2025-05-01","di":"2025-05-01","dr":"2025-05-01","k":"Regulatory Action","rg":"State regulator","reg":"Division of Securities, Utah Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. SD-25-0004; DOCKET NO. SD-25-0005","al":"On May 1, 2025, the Utah securities commission, Division of Securities, Utah Department of Commerce issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Utah code ann. Section 61-1-1(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Utah code ann. Section 61-1-6(2)(a)(II)(j) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor share class TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional share class TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":259},{"d":"2025-05-01","di":"2025-05-01","dr":"2025-05-01","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securities and Insurance, Office of the Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"SEC-2025-35","al":"On May 1, 2025, the Commissioner of Securities and Insurance, Office of the Montana State Auditor issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated M.C.A. § 30­10­301(1)(b) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated M.C.A. § 30­10­201(13)(k) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor share class TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional share class TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":260},{"d":"2025-04-29","di":"2025-04-29","dr":"2025-04-29","k":"Regulatory Action","rg":"Department of Labor","reg":"South Dakota Division of Insurance, Department of Labor and Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"1019070","al":"The South Dakota Division of Insurance, Department of Labor and Regulation (the \"division\") alleged that LPL Financial LLC (\"LPL\") violated: SDCL 47-31B-411 and FINRA rule 4511 in connection with an alleged failure by LPL and its agents to maintain accurate books and records; arsd 20:08:03:08 and FINRA rule 3110(a) and (b) in connection with its alleged failure to establish, maintain, and enforce an adequate supervisory system; and arsd 20:08:03:08 and FINRA rule 2010 in connection with its agents' alleged use of their own e-mail addresses in place of the clients' and signing client documents on the clients' behalf.","res":"Consent","sm":"On April 29, 2025, LPL entered into a consent order with the division regarding allegations that it violated SDCL 47-31B-411 and FINRA rule 4511 in connection with an alleged failure by LPL and its agents to maintain accurate books and records; arsd 20:08:03:08 and FINRA rule 3110(a) and (b) in connection with its alleged failure to establish, maintain, and enforce an adequate supervisory system; and arsd 20:08:03:08 and FINRA rule 2010 in connection with its agents' alleged use of their own e-mail addresses in place of the clients' and signing client documents on the clients' behalf. LPL agreed to a monetary penalty in the amount of $35,000. The monetary penalty will be paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":261},{"d":"2025-04-28","di":"2025-04-28","dr":"2025-04-28","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking and Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"NA","al":"On April 28, 2025, the Nebraska Department of Banking and Finance, bureau of securities, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated neb. Rev. Stat. § 8­1102(1)(b) (reissue 2002) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated neb. Rev. Stat. § 8­1103(9)(a)(XI) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor share class TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional share class TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":262},{"d":"2025-04-28","di":"2025-04-28","dr":"2025-04-28","k":"Regulatory Action","rg":"State regulator","reg":"Department of Financial Protection and Innovation of the State of California","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"NA","al":"On April 28, 2025, the Department of Financial Protection and Innovation of the State of California issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated California corporations code section 25401 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated California corporations code section 25218 and 10 C.C.R. 260.218.4 by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":263},{"d":"2025-04-28","di":"2025-04-28","dr":"2025-04-28","k":"Regulatory Action","rg":"State regulator","reg":"State of Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"NA","al":"On April 28, 2025, the Minnesota department of commerce issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated minn. Stat. § 80A.68 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated minn. Stat. § 80A.67 (d)(9) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor share class TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional share class TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":264},{"d":"2025-04-25","di":"2025-04-25","dr":"2025-04-25","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"LS-23-5929","al":"On April 25, 2025, the Office of the Mississippi Secretary of State, Securities Division, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Mississippi Securities Act § 75­71­501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Mississippi securities rule 5.19 by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":265},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC (American)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":102187.0,"dk":"2021069491204","al":"JPMS consented to sanctions and to entry of findings that (1) between April 2020 and January 2022, JPMS did not file or submitted untimely or inaccurate notifications to american in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934, in violation of american rule 5190(c) and (d), and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with american rule 5190(c) and (d), in violation of american rule 3110(a) and (b) (supervision).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":266},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150384.0,"dk":"2021069491201","al":"JPMS consented to sanctions and to entry of findings that (1) between April 2020 and March 2022, JPMS did not submit or submitted untimely or inaccurate notifications to FINRA in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934, in violation of FINRA rules 5190 and 2010 and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with FINRA rule 5190, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":267},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC (Nasdaq)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":27857.0,"dk":"2021069491202","al":"JPMS consented to sanctions and to entry of findings that (1) between December 2020 and June 2021, JPMS did not file one notice of intent and did not timely file two notices of intent in connection with three distributions in violation of rule 104(h)(2) of Regulation M under the Securities Exchange Act of 1934 and Nasdaq rule equity 2, section 15, and Nasdaq rule general 9, section 1(a), and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with Nasdaq rule equity 2, section 10(e) and Nasdaq rule 4619(e), in violation of Nasdaq rule general 9, section 20(a) and Nasdaq rule general 9, section 1(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":268},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE Chicago, Inc. N/K/A NYSE Texas, Inc. (Chicago)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":52908.0,"dk":"2021069491206","al":"JPMS consented to sanctions and to entry of findings that (1) between June 2020 and January 2022, JPMS did not submit or submitted untimely and inaccurate notifications to chicago in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934, in violation of chicago rule 11.5190(c) and (d) (notification requirements for offering participants), and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with chicago rule 11.5190(c) and (d), in violation of chicago article 6, rule 5(a) and (c) (supervision).","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":269},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE National, Inc. (National)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":87024.0,"dk":"2021069491207","al":"JPMS consented to sanctions and to entry of findings that (1) between June 2020 and January 2022, JPMS did not submit or submitted untimely or inaccurate notifications to national in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934, in violation of national rule 11.5190(c) and (d) (notification requirements for offering participants), and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with national rule 11.5190(c) and (d), in violation of national rules 11.5.1 (written procedures) and 11.3.2 (violations prohibited).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":270},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc. (ARCA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":106519.0,"dk":"2021069491205","al":"JPMS consented to sanctions and to entry of findings that (1) between April 2020 and January 2022, JPMS did not submit or submitted untimely or inaccurate notifications to ARCA in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934, in violation of ARCA rule 9.5190-e(c) and (d), and (2) between August 2020 and January 2024, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with ARCA rule 9.5190-e(c) and (d), in violation of ARCA rule 11.18(b) and (c) (supervision).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":271},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC (NYSE)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":123121.0,"dk":"2021069491203","al":"JPMS consented to sanctions and to entry of findings that (1) between April 2020 and January 2022, JPMS did not submit or submitted untimely or inaccurate notifications to NYSE in connection with its participation in certain distributions of securities subject to Regulation M under the Securities Exchange Act of 1934 (\"Regulation M\"), in violation of NYSE rule 5190(c) and (d), (2) between June 2020 and March 2021, JPMS did not file or submitted untimely notices of intent in connection with its participation in four distributions involving securities listed on NYSE, in violation of rule 104(h) of Regulation M and NYSE rule 5190(e) and (3) between August 2020 and January 2024, JPMS did not establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with NYSE rule 5190(c) and (d), in violation of NYSE rule 3110(a) and (b) (supervision).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":272},{"d":"2025-04-21","di":"2025-04-21","dr":"2025-04-21","k":"Regulatory Action","rg":"State regulator","reg":"The Investor Protection Director of the State of Delaware","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"INVESTOR PROTECTION CASE NO. 22-0111","al":"On April 21, 2025, The Investor Protection Director of the State of Delaware issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Delaware Securities Act § 73­201(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Delaware Securities Act § 73­304(a)(10) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":273},{"d":"2025-04-14","di":"2025-04-14","dr":"2025-04-14","k":"Regulatory Action","rg":"State regulator","reg":"State of Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO. 23-25-S","al":"On April 14, 2025, the state of Alaska department of commerce, community, and economic development division of banking and securities issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Alaska stat. 45.56.500(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Alaska stat. 45.56.440(d)(9) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":274},{"d":"2025-04-11","di":"2025-04-11","dr":"2025-04-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine, Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"NO. 2025-03","al":"On April 11, 2025, the state of Maine office of securities issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated 32 Maine rev. Stat. § 16501(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Maine office of securities rules, chapter 504 § 7(1) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":275},{"d":"2025-04-10","di":"2025-04-10","dr":"2025-04-10","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securities, State of Georgia","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO. ENSC-241177","al":"On April 10, 2025, the Commissioner of securities state of Georgia issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated official code of Georgia § 10­5­50 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated official code of Georgia § 10­5­41(d)(9) and Georgia rule 590­4­5­12(1) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":276},{"d":"2025-04-10","di":"2025-04-10","dr":"2025-04-10","k":"Regulatory Action","rg":"State regulator","reg":"State of Rhode Island, Department of Business Regulation, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"2025-SC-001","al":"On April 10, 2025, the state of Rhode Island department of business regulation securities division issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated R.I. Gen. Laws § 7­11­501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated R.I. Gen. Laws § 7­11­212(b)(11) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":277},{"d":"2025-04-10","di":"2025-04-10","dr":"2025-04-10","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada, Office of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"FILE NO. INV25-005","al":"On April 10, 2025, the state of Nevada office of the secretary of state securities division issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated nev. Rev. Stat. 90.570 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated nev. Rev. Stat. 90.420(1)(l) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":278},{"d":"2025-04-09","di":"2025-04-09","dr":"2025-04-09","k":"Regulatory Action","rg":"Other","reg":"Arizona Department of Insurance and Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":500.0,"dk":"25A-006-INS","al":"The Arizona Department of Insurance and Financial Institutions alleged that Edward jones violated an insurance law and was liable for a civil penalty under Arizona revised statutes section 20-295(a)(2) in connection with its failure to forward beneficiary change forms to a client's insurance companies.","res":"Consent","sm":"On April 9, 2025, Edward jones entered into consent order with the Arizona Department of Insurance and Financial Institutions (the \"department\") to resolve this matter. Edward jones did not contest that it failed to forward two annuity beneficiary change forms to its client's insurance companies. The department found that failure to \"demonstrate[] incompetence in the conduct of business\" under Arizona revised statutes section 20-295(a)(8). Therefore, pursuant to section (a)(2), the department imposed a civil penalty of $250.00 for each form, for a total of $500.00, which Edward jones paid on April 2, 2025.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":279},{"d":"2025-04-03","di":"2025-04-03","dr":"2025-04-03","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Department of Commerce, Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DIVISION ORDER NO. 25-005","al":"On April 3, 2025, the Ohio Department of Commerce, Division of Securities, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Ohio rev. Code 1707.19(a)(1)(I) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Ohio admin. Code 1301:6-3-19(b)(9) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":280},{"d":"2025-04-02","di":"2025-04-02","dr":"2025-04-02","k":"Regulatory Action","rg":"Other","reg":"Iowa Insurance Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DIV. CASE NO. 125581","al":"On April 2,2025, the Iowa Insurance Commissioner issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Iowa code § 502.501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Iowa code § 502.412(4)(I) and Iowa admin. Code rule 191­50.17(3) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as a result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":281},{"d":"2025-04-01","di":"2025-04-01","dr":"2025-04-01","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"2025-CDS-006","al":"On April 1, 2025, the state of Colorado Securities Commissioner issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Colorado revised statutes § 11­51­501(1)(b) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated 3 code of Colorado regulations 704-1, rule 51-4.7(h) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":282},{"d":"2025-04-01","di":"2025-03-17","dr":"2025-04-01","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Public Prosecutor","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27500000.0,"dk":"7500 JS-OWI 207940/25","al":"On April 1, 2025, DWS group GMBH & co. kgaa and DWS Investment GMBH (together, \"DWS\") received an administrative fine notice from the Frankfurt Public Prosecutor finding that DWS committed an administrative offense by negligently breaching a requirement regarding proper business operations in the german capital investment code (\"KAGB\") requiring capital management companies to have at their disposal the means and procedures necessary for the proper operation of business and to use them effectively (SEC. 26 para. 2 no. 4 KAGB) based on allegations that the actual state of implementation of environmental and social governance (\"ESG\")-related policies and procedures at DWS did not live up to DWS's external communication regarding ESG.","res":"Order","sm":"On April 1, 2025, DWS received an administrative fine notice from the Frankfurt Public Prosecutor finding that DWS committed an administrative offense by negligently breaching a requirement regarding proper business operations in the kagb requiring capital management companies to have at their disposal the means and procedures necessary for the proper operation of business and to use them effectively (SEC. 26 para. 2 no. 4 kagb) based on allegations that the actual state of implementation of ESG-related policies and procedures at DWS did not live up to DWS's external communication regarding ESG. The administrative fine notice imposed an aggregate fine of 25,000,000 euro on DWS group GMBH & co and DWS Investment GMBH, which was timely paid","ab":"DWS Investment GMBH","firms":[300838],"id":283},{"d":"2025-03-25","di":"2025-03-25","dr":"2025-03-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut, Department of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"MATTER NO. 25-202513-S","al":"On March 25, 2025, the state of Connecticut department of banking issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Connecticut gen. Stat § 36b­5(a)(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated regulations of Connecticut state agencies § 36b­31­6(f) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":284},{"d":"2025-03-25","di":"2024-05-28","dr":"2025-03-25","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet - the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":47554.0,"dk":"23/9729","al":"On May 28, 2024, Finanstilsynet alleged that certain net short position notification filings were not made timely by Pentwater Capital Management europe LLP (\"Pentwater europe\") in accordance with article 5, CF. Article 6 and article 9 of regulation (EU) no 236/2012 (\"SSR\") CF. Section 3-14 (as it was phrased before 1 March 2021) of the norwegian securities trading act (\"NSTA\").","res":"Decision","sd":"Finanstilsynet imposed a violation penalty of nok 500,000 (approximately usd 47,554 on May 28, 2024).","sm":"On May 28, 2024, Finanstilsynet imposed a violation penalty of nok 500,000 on Pentwater europe. On June 25, 2024, Pentwater europe filed a complaint appealing Finanstilsynet's decision to impose a violation penalty. On March 25, 2025, the norwegian ministry of finance confirmed Finanstilsynet's decision that Pentwater europe be subject to the violation penalty to nok 500,000. No information Filed","ab":"Pentwater Capital Management LP","self":true,"firms":[156873],"id":285},{"d":"2025-03-21","di":"2025-03-21","dr":"2025-03-21","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. 250010","al":"On March 21, 2025, the pa department of banking and securities issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated 70 penn. Stat. § 1­401 (b) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated 70 penn. Stat. § 1­305 (a)(VII) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":286},{"d":"2025-03-21","di":"2025-03-21","dr":"2025-03-21","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico, Regulation and Licensing Department, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"MS 24-12-19","al":"On March 21, 2025, the state of New Mexico regulation and licensing department securities division, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated New Mexico statutes annotated 1978, § 58­13c­501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated New Mexico statutes annotated 1978, § 58­13c­412(c)(9) and New Mexico admin. Code. 12.11.4.10 failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":287},{"d":"2025-03-21","di":"2025-03-21","dr":"2025-03-21","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire, Department of State, Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"INV2022-00041","al":"On March 21, 2025, the state of New Hampshire department of state bureau of securities regulation, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated N.H. Rev. Stat. Ann. 421-b:5-501(a)(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated N.H. Rev. Stat. Ann. 421-b:4-412(d)(9) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":288},{"d":"2025-03-21","di":"2025-03-21","dr":"2025-03-21","k":"Regulatory Action","rg":"State regulator","reg":"State of New Jersey, Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"al":"On March 21, 2025, the state of New Jersey bureau of securities, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated New Jersey statutes annotated 49:3-52(b) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated New Jersey statutes annotated 49:3-58(a)(2)(XI) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":289},{"d":"2025-03-21","di":"2025-03-21","k":"Civil Judicial Action","san":"Other","os":"Money damages; injunction (provision of information about the plaintiffs' position in the redemption queues and statement","st":"Pending","al":"The complaint principally relates to Fiera Capital Corporation's alleged failure to provide adequate information concerning the liquidity of the canadian pooled funds in which the plaintiffs are invested, the performance of such pooled funds, and Fiera Capital Corporation's alleged failure to process redemption requests in a timely manner.","ab":"Fiera Capital Corporation","firms":[113638,137637],"id":290},{"d":"2025-03-20","di":"2025-03-20","dr":"2025-03-20","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire, Department of State, Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, undertaking, investigation costs","st":"Final","fine":325000.0,"dk":"C2024-00025","al":"The State of New Hampshire, Department of State, Bureau of Securities Regulation (the \"bureau\") alleged that LPL Financial LLC (\"LPL\") violated N.H. Rsa 421-b:4-406(k) in connection with allegations that from December 2018 to August 2021, a registered representative at LPL used an unapproved messaging platform to communicate with clients and prospective clients relating to his securities business.","res":"Order","sm":"On March 20, 2025, LPL entered into a consent order with the bureau regarding allegations that it violated N.H. Rsa 421-b:4-406(k) in connection with allegations that from December 2018 to August 2021, a registered representative at LPL used an unapproved messaging platform to communicate with clients and prospective clients relating to his securities business. Without admitting or denying the facts or allegations, LPL agreed to (1) cease and desist from violating the rules and laws regarding preservation of records of customer communications as required by FINRA rule 4511 and SEC rule 240.17A-4, pursuant to N.H. Rsa 421-b:4-406(k), (2) comply with certain undertakings, and (3) payment of an administrative fine in the amount of $325,000 plus investigation costs in the amount of $25,000. The administrative fine and investigation costs were paid in accordance with the terms of the consent order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":291},{"d":"2025-03-19","di":"2025-03-19","dr":"2025-03-19","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S. (\"ICE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"dk":"ICE FUTURES CASE NO. 2024-005","al":"On March 19, 2025, a subcommittee of the exchange's business conduct committee (\"BCC\") determined that PIMCO may have violated exchange rule 4.02(c) in September 2023, when employees placed orders, including through different and independent executing brokers, for two accounts with common beneficial ownership in the California carbon allowance vintage 2023 contract (\"CB1\"), a portion of which ultimately matched opposite one another. Based on information obtained, it appeared that the employees did not intend for the orders to match, however, they should have known that the orders would trade opposite one another.","res":"Settled","sd":"Under the terms of the settlement, a fine of $100,000 was paid by the registrant on March 27, 2025. No portion of the penalty was waived.","sm":"On March 21, 2025, ICE announced an agreement with PIMCO to settle the allegations relating to PIMCO's trading in the CB1. The monetary penalty was paid on March 27, 2025.","ab":"Pacific Investment Management Company LLC","self":true,"firms":[104559],"id":292},{"d":"2025-03-18","di":"2025-03-18","dr":"2025-03-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington Department of Financial Institutions, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ORDER NO. S-22-3439-25-CO01","al":"On March 18, 2025, the state of Washington department of financial institutions securities division, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated rev. Wash. Code 21.20.010 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Washington admin. Code 460-20C-150 by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":293},{"d":"2025-03-13","di":"2024-07-05","dr":"2025-03-13","k":"Regulatory Action","rg":"Other","reg":"Reserve Bank of India (\"Rbi\")","san":"Other","os":"Show cause notice","st":"Final","fine":3565.0,"dk":"NOT APPLICABLE","al":"Rbi vide its letter dated July 05, 2024, issued a show cause notice in relation to an inadvertent miss of disclosure of a related party transaction in annual report pursuant to paragraph 4.3(a) of annex xvi of master direction ­ non​ banking financial company ­ systemically important non-deposit taking company and deposit taking company (Reserve bank) directions, 2016.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Not applicable","sm":"Within the space provided). Purusuant to paragraph 4.3(a) of annex xvi of master direction ­ non​ banking financial company ­ systemically important non­deposit taking company and deposit taking company (Reserve bank) directions, 2016, rbi vide its letter dated July 05, 2024, issued a show cause notice in relation to an inadvertent miss of disclosure of a related party transaction in annual report. JMFPL replied to the show cause notice stating that the said transaction has disclosed in its audited financial statements under the related party transactions and that the missed disclosure of related party transaction was purely on the ground of interpretation, rbi vide its order dated March 13, 2025 levied a penalty of RS. 3.10 lakh on JMFPL (matter closed).","ab":"JM Financial Products Limited","firms":[293667],"id":294},{"d":"2025-03-12","di":"2025-03-12","dr":"2025-03-12","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance & Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"al":"On March 12, 2025, the South Dakota Department of Labor and regulation, division of insurance, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated s. Dakota codified laws 47-31B-501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated s. Dakota codified laws 47-31B-412 by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":295},{"d":"2025-03-11","di":"2025-03-11","dr":"2025-03-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont, Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DOCKET NO. 25-003-S","al":"On March 11, 2025, the Vermont department of financial regulation issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated 9 Vermont stat. Ann. § 5501 by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Vermont secs. Reg. § 2­2(b)(2) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":296},{"d":"2025-03-11","di":"2024-09-09","dr":"2025-03-11","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Department of Commerce and Insurance | Tennessee Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":20000.0,"dk":"MATTER NO.: 22-00398","al":"Consent order finds that Masterworks made sales of securities in the state of Tennessee without submitting required notice filings between May 2019 and January 2022 in violation of the Tennessee notice filing requirements. Masterworks self-reported and corrected the lapse in January of 2022 and has since made all required notice filings in the state. No investor harm was alleged.","res":"Order","sd":"Administrative fine of $20,000 levied against the advisory affiliate. Funds were paid on 03/14/2025 with no portion waived.","sm":"Consent order was signed, entered, and executed on March 11, 2025 (03/11/2025).","ab":"Masterworks.Io, LLC,","firms":[324239],"id":297},{"d":"2025-03-10","di":"2025-03-10","dr":"2025-03-10","k":"Regulatory Action","rg":"State regulator","reg":"Division of Securities, Wisconsin Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"DFI CASE NO. S-245138 (LX)","al":"On March 10, 2025, the Wisconsin department of financial institutions, Division of securities, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated wis. Stat. § 551.501(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated wis. Admin code § dfi­SEC 4.05(2) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action.the foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":298},{"d":"2025-03-10","di":"2025-03-10","dr":"2025-03-10","k":"Regulatory Action","rg":"Other","reg":"Oregon Department of Consumer and Business Services, Division of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"CASE NO. S-25-0017","al":"On March 10, 2025, the Oregon Department of Consumer and Business Services, Division of Financial Regulation, issued a settled consent order in which it found that (I) The Vanguard Group (\"VGI\") violated Oregon rev. Stat. 59.135(2) by failing to disclose the potential for higher capital gains distributions from lowering the investment minimum of the institutional target retirement funds (\"TRFS\"); and (II) the vanguard marketing corporation (\"VMC\") violated Oregon rev. Stat 59.205(13) and Oregon admin. Rule 441-205-0210(3) by failing to adequately supervise its agents to ensure that they took adequate steps to disclose the risk that investors that held investor TRFS in taxable accounts could potentially experience tax consequences as result of lowering the investment minimum for the institutional TRFS.","res":"Settled","sd":"N/a","sm":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3-22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to certain offsets; (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. Penalties and remediation deemed satisfied by payment to SEC fair fund in related action. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":299},{"d":"2025-03-06","di":"2025-03-06","dr":"2025-03-06","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania, Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":55000.0,"dk":"250007","al":"The Pennsylvania department of banking and securities (the \"department\") alleged that LPL Financial LLC (\"LPL\") violated section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972 in connection with allegations that from June 2023 to September 2024, LPL did not register one of its representatives as an investment adviser representative in Pennsylvania.","res":"Order","sm":"On March 6, 2025, LPL entered into a consent agreement and order with the department regarding allegations that LPL violated section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972 in connection with allegations that from June 2023 to September 2024, LPL did not register one of its representatives as an investment adviser representative in Pennsylvania. Without admitting or denying the allegations, LPL agreed to (1) comply with the Pennsylvania Securities Act of 1972, including section 301(C.1)(1)(II), and (2) pay an administrative assessment in the amount of $55,000.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":300},{"d":"2025-03-06","di":"2025-03-06","dr":"2025-03-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":100000.0,"dk":"2022075391301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, as successor-in-interest to hefren-tillotson, violated reg bi's compliance obligation. The findings stated that hefren-tillotson's registered representatives recommended that customers open portfolio review program accounts, which enrolled the customers in an advisory service, even though the customers were already receiving those services through their existing or simultaneously opened portfolio review or investment advisory accounts. These customers did not receive any additional services by opening these accounts. As a result, these customers paid $557,830.64 in unnecessary account fees. Subsequently, baird voluntarily discontinued charging portfolio review fees and recommending portfolio review accounts after its acquisition of hefren-tillotson's brokerage business. The findings also stated that hefren-tillotson's written procedures, and supervisory system, were not reasonably designed to achieve compliance with reg bi's requirement that account-type recommendations are in the customer's best interest. The firm's WSPS did not provide any procedures or guidance regarding the factors to consider when recommending portfolio review program accounts. Moreover, the firm's WSPS did not require representatives to consider whether customers would benefit from a recommendation to open a new portfolio review account when the customer was already receiving the services provided in connection with that account type. The firm's WSPS also failed to detail any steps that principals should take to determine whether an account-type recommendation was in the customer's best interest in light of the customer's investment profile, the costs of such an account, and the services provided in connection with that account.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $100,000, and ordered to pay $557,830.64, plus interest, in restitution to customers.","sm":"As set forth in the letter of acceptance, waiver and consent (\"AWC\"), all of the activities/violations/matters described in the AWC occurred prior to the time hefren-tillotson merged into baird. Baird, as successor-in-interest to hefren-tillotson, voluntarily discontinued the portfolio review program prior to the time these accounts were at baird. FINRA also recognized that baird provided substantial assistance in calculating appropriate restitution.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":301},{"d":"2025-03-03","di":"2025-03-03","k":"Regulatory Action","rg":"Other","reg":"National Stock Exchange of India Limited","san":"Other","os":"Monetary fine","st":"Pending","dk":"NOT APPLICABLE","al":"Nse MCSGFC, committee vide order dated March 03, 2025, has levied penalty of RS. 5,60,000/- ($6,384) for violation observed during onsite inspection of authorized person. We have submitted a request for reversal of the penalty levied.","ab":"JM Financial Services Limited","firms":[293667],"id":302},{"d":"2025-02-21","di":"2023-05-24","dr":"2025-02-21","k":"Regulatory Action","rg":"Other","reg":"UK Competition and Markets Authority (Cma)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000000.0,"al":"In May 2023 the competition and markets authority issued a statement of objections to five banks (Deutsche bank, Morgan stanley, royal bank of Canada, Citi, and HSBC). In February 2025, the competition and markets authority announced that it had reached a settlement with HSBC. HSBC accepted that a single HSBC trader had shared competitively sensitive information on 12 separate occasions with a Deutsche bank trader in a one-to-one chatroom from October 2009 to July 2010. The information concerned the issuing and trading of gilts.","res":"Settled","sd":"N/a","sm":"N February 2025, HSBC Holdings (as parent) and HSBC bank PLC accepted that a single HSBC bank PLC trader had shared competitvely-sensitive information with Deutsche bank on 12 occassions over 2009-2010. HSBC has agreed to pay a fine of GBP £23.4m (approx usd $30m). No information Filed","ab":"HSBC Holdings PLC","firms":[154700,172522,324468],"id":303},{"d":"2025-02-20","di":"2025-02-20","dr":"2025-02-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":275000.0,"dk":"2021070593301","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Merrill Lynch, Pierce, Fenner & Smith (MLPF&s) (1) accepted market orders for the purchase of shares of equity new issues in the secondary market prior to the commencement of trading of such shares in the secondary market in violation of FINRA rules 5131(d)(4) and 2010; and (2) failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with FINRA rule 5131(d)(4).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPF&s agreed to the imposition of a censure, a fine in the amount of $275,000, and certain undertakings. The fine will be paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":304},{"d":"2025-02-19","di":"2023-08-03","dr":"2025-02-19","k":"Regulatory Action","rg":"Other","reg":"The Arizona Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"S-21347A-25-0005","al":"Pursuant to A.R.S. §§ 44­1961(a)(12) and (b)(1) and 44­2036, the state of Arizona's corporation commission alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Arizona Corporation Commission found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of A.R.S. §§ 44­1961(a)(12) and (b)(1) and 44­2036. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the state of Arizona.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":305},{"d":"2025-02-18","di":"2023-08-03","dr":"2025-02-18","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CASE NO. SEC-2024-00016","al":"Pursuant to 21 VAC-5-20-260 of the Virginia Securities Act (the \"act\"), the Virginia state corporation commission (the \"commission\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018 (the \"investigation period\"), Edward jones procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commission found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of 21 VAC-5-20-260 of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the treasurer of Virginia.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":306},{"d":"2025-02-17","di":"2023-12-18","dr":"2025-02-17","k":"Civil Judicial Action","san":"Other","os":"Please see section 14 for details relating to the settlement agreement.","st":"Final","al":"On December 18, 2023, the Tennessee attorney general (\"AG\") sued BlackRock, inc. in Tennessee state court for alleged violations of Tennessee's consumer protection statute in connection with our ESG practices. The complaint generally alleges that BlackRock has made misleading statements in fund prospectuses, fact sheets, various public statements, and on its website regarding its ESG practices and its approach to proxy voting.","res":"Settled","sd":"Not applicable.","ab":"BlackRock Inc","firms":[290336],"id":307},{"d":"2025-02-17","di":"2024-03-18","dr":"2025-02-17","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 12-2024","al":"The Frankfurt stock exchange (\"FSE\") found that, in November 2024, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 31 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On February 17, 2025, DB AG received a decision from fse issued on January 9, 2025 finding that, in November 2024, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 31 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":308},{"d":"2025-02-05","di":"2023-03-13","dr":"2025-02-05","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":24000000.0,"dk":"ZR 7-WP 3127/00013#00007","al":"BAFIN found that Deutsche Bank AG (\"DBAG\") (a) failed to timely investigate and address breaches of law regarding transactions in FX derivatives, (b) in certain periods during the covid pandemic, failed to ensure that investment advice given by telephone was recorded, and (c) failed to timely provide the receiving payment service provider with the information required to switch accounts or committed failures in the process of transferring or closing certain client accounts.","res":"Order","ab":"Deutsche Bank AG","firms":[300838],"id":309},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, monetary fine, undertaking","st":"Final","fine":18000000.0,"dk":"3-22422","al":"On January 17, 2025, the U.S. Securities and Exchange Commission (\"SEC\") issued a settled administrative order in which it found that LPL Financial LLC (\"LPL\") willfully violated section 17(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rule 17A-8 thereunder. Specifically, the order found that from at least May 2019 to December 2023 (the \"relevant period\"), LPL did not follow its anti-money laundering (\"AML\") policies and procedures regarding its customer identification program (\"CIP\") and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its CIP screening measures; and not closing or restricting certain accounts that were prohibited under LPL's AML policies. In determining to accept LPL's offer of settlement, the SEC considered remedial acts promptly undertaken by LPL, including LPL's engagement of a compliance consultant and proactive implementation of the consultant's recommendations.","res":"Decision & Order of Offer of Settlement","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12. Paid fine on January 23, 2025.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":310},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":25000000.0,"dk":"FILE NO. 3-22433","al":"The Securities and Exchange Commission (SEC) alleged that Merrill Lynch, Pierce, Fenner & Smith (MLPF&s), willfully violated section 206(4) of the Investment Advisers Act of 1940 (Advisers Act) and rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&s failed to adopt and implement reasonably designed written policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill lynch bank deposit program and (II) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&s took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period.","res":"Order","sm":"MLPF&s, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. The fine was paid in accordance with the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":311},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":7000000.0,"dk":"FILE NO. 3-22430","al":"The Securities and Exchange Commission (\"SEC\") entered into a settlement order with Wells Fargo Clearing services, LLC (\"WFCS\") and Wells Fargo Advisors Financial Network, LLC (\"WFAFN\") (collectively, the \"firms\") to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act of 1940 (\"Advisers Act\") and the rules thereunder relating to its cash sweep program, specifically, its use of a bank deposit sweep program (\"BDSP\"). The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","res":"Order","sm":"On January 17, 2025, the SEC entered into a settlement order with the firms to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to its cash sweep program, specifically, its use of a BDSP. The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. Wfafn, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $7 million. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Clearing","firms":[11025],"id":312},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":28000000.0,"dk":"FILE NO. 3-22430","al":"The Securities and Exchange Commission (\"SEC\") entered into a settlement order with Wells Fargo Clearing Services, LLC (\"WFCS\") and Wells Fargo Advisors financial network, LLC (\"WFAFN\") (collectively, the \"firms\") to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act of 1940 (\"Advisers Act\") and the rules thereunder relating to its cash sweep program, specifically, its use of a bank deposit sweep program (\"BDSP\"). The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","res":"Order","sm":"On January 17, 2025, the SEC entered into a settlement order with the firms to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to its cash sweep program, specifically, its use of a BDSP. The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. WFCS, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Advisors","firms":[19616],"id":313},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"State regulator","reg":"Attorney General of the State of New York","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws.","st":"Final","fine":166700000.0,"dk":"ASSURANCE NO. 25-003","al":"On January 17, 2025, the New York Attorney general issued a settled assurance of discontinuance in which it found that vgi violated the martin act (N.Y. General business law § 352 et seq.) And N.Y. Executive law § 63(12) by failing to disclose to investors in investor TRFS of the impact on capital gains distributions and resulting capital gains tax liability that would result from lowering the minimum investment for the institutional TRFS.","res":"Settled","sd":"Without admitting or denying the findings, VMC and vgi agreed not to engage, or attempt to engage, in conduct in violation of any applicable laws. VMC and vgi were also ordered to satisfy the monetary conditions of the related SEC [file no. 3- 22435] and nyag [aod 25-003] actions, which, together, required vgi and VMC to pay (I) $135 million in remediation, subject to $42.094 million in offsets ($92.91 million net of offsets); (II) a penalty of $13.5 million; and (III) $14.7 million in disgorgement and $3.5 million in prejudgment interest. The required monetary relief was deemed satisfied by payment to SEC fair fund in related action. On January 24, 2025, vgi paid $106,410,000 into the SEC fair fund, comprising the $13.5 million civil penalty and $92.9 million in restitution. The foregoing amounts represent the total amounts paid by vgi and VMC in full satisfaction of all state settlement orders relating to this matter.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":314},{"d":"2025-01-17","di":"2025-01-17","dr":"2025-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure monetary fine","st":"Final","fine":31700000.0,"dk":"FILE NO. 3-22435","al":"On January 17, 2025, U.S. Securities and Exchange Commission (\"SEC\") issued a settled administrative order in which it found that The Vanguard Group (\"VGI\") willfully violated section 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\"), and rules 206(4)-7 and 206(4)-8 thereunder by (I) failing to disclose to investors in the investor target retirement funds (\"TRFS\") of the impact on capital gains distributions and resulting capital gains tax liability as a result of lowering the minimum investment for the institutional TRFS and (II) not having in place, adopted, or implemented written policies and procedures during 2020 and 2021 to address the accuracy of disclosures with respect to certain mutual funds. The SEC also found that VGI caused certain mutual funds to violate section 17(a)(2) of the Securities Act of 1933 (\"Securities Act\") and section 34(b) of the Investment Company Act of 1940 (\"Investment Company Act\"). Without admitting or denying the findings, VGI was (I) censured; (II) ordered to cease and desist from committing or causing any violations and any future violations of section 17(a)(2) of the Securities Act, section 206(4) of the Advisers Act and rules 206(4)-7 and 206(4)-8 thereunder, and section 34(b) of the Investment Company Act.","res":"Decision & Order of Offer of Settlement","sd":"Without admitting or denying the findings, vgi was (I) censured; (II) ordered to cease and desist from committing or causing any violations and any future violations of section 17(a)(2) of the Securities Act, section 206(4) of the Advisers Act and rules 206(4)-7 and 206(4)-8 thereunder, and section 34(b) of the Investment Company Act; (III) ordered to pay $14.7 million in disgorgement and $3.5 million in prejudgment interest; and (IV) ordered to pay a $13.5 million civil money penalty. Disgorgement and interest amounts deemed satisfied by payment of $92.9 million to fair fund in connection with related state actions. On January 24, 2025, vgi paid $106,410,000 into the SEC fair fund, comprising the $13.5 million civil penalty and $92.9 million in restitution.","sm":"The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":315},{"d":"2025-01-17","di":"2023-12-18","dr":"2025-01-17","k":"Civil Judicial Action","san":"Other","os":"Please see section 14 for details relating to the settlement agreement.","st":"Final","al":"On December 18, 2023, the Tennessee attorney general (\"AG\") sued BlackRock, Inc. in Tennessee state court for alleged violations of Tennessee's consumer protection statute in connection with our ESG practices. The complaint generally alleges that BlackRock has made misleading statements in fund prospectuses, fact sheets, various public statements, and on its website regarding its ESG practices and its approach to proxy voting.","res":"Settled","sd":"Not applicable.","ab":"BlackRock Inc; BlackRock, Inc.","firms":[106614,107105,282125],"id":316},{"d":"2025-01-16","di":"2023-08-03","dr":"2025-01-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Utah Department of Commerce Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DOCKET NO.: SD-23-0031","al":"Pursuant to § 61­1­6(2)(a)(II)(j) of the Utah uniform Securities Act (\"act\"), the Utah division of securities (\"division\") alleged that, during the period ofapproximately July 1, 2016 to June 3, 2018, (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to the sale ofcertain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones toserve as their investment adviser and manage those assets.","res":"Consent","sm":"The division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of § 61­ 1-6(2)(a)(II)(j) of the act. Without admitting or denying thefindings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to thedivision.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":317},{"d":"2025-01-16","di":"2025-01-16","dr":"2025-01-16","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1250.0,"dk":"N/A","al":"Bloomberg SEF LLC (\"Bloomberg SEF\") alleged that Wells Fargo Bank, national association (\"the firm\") failed to timely notify Bloomberg SEF after an erroneous trade was discovered, in violation of Bloomberg SEF rule 516.","res":"Other","sm":"Bloomberg SEF issued a summary fine in the amount of $1,250 to the firm. The payment was made in accordance with the terms of the notice of fine.","ab":"Wells Fargo Bank,","firms":[11025,19616],"id":318},{"d":"2025-01-16","di":"2025-01-16","dr":"2025-01-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":45000000.0,"dk":"RELEASE NO. 2025-15","al":"The SEC order alleged that Two Sigma Investments, LP (\"two sigma\") failed to exercise reasonable care in addressing known material vulnerabilities to a subset of its computer-based algorithmic investment models in breach of its fiduciary duty of care, had deficiencies in its written compliance policies and procedures, and failed to reasonably supervise one of its modelers who intentionally violated two sigma's policies. Separately, the order alleged that two sigma violated the SEC's whistleblower protection rule.","res":"Order","sd":"Monetary penalty ordered of $45,000,000.","sm":"On January 16, 2025, The Securities and Exchange Commission (\"SEC\") entered an order instituting administrative and cease-and- desist proceedings (the \"SEC order\") against Two Sigma Investments, LP and two sigma advisers, LP (collectively, \"two sigma\") pursuant to section 21c of the Securities Exchange Act of 1934 (the \"Exchange Act\") and sections 203(e) and 203(k) of the Investment Advisers Act of 1940 (the \"Advisers Act\"). Two sigma consented to the SEC order without admitting or denying the findings therein. The SEC order alleges that two sigma failed to exercise reasonable care in addressing known material vulnerabilities to a subset of its computer-based algorithmic investment models in breach of its fiduciary duty of care, had deficiencies in its written compliance policies and procedures, and failed to reasonably supervise one of its modelers who intentionally violated two sigma's policies. Separately, the order alleged that two sigma violated the SEC's whistleblower protection rule. The SEC ordered that two sigma cease and desist from committing or causing any violations and any future violations of rule 21F-17(a) under the Exchange Act and sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-7 promulgated thereunder. Additionally, the SEC ordered that two sigma be censured and each of Two Sigma Investments, LP and two sigma advisers, LP pay a civil money penalty of $45,000,000 to the SEC within 10 days of the entry of the order. No information Filed","ab":"Two Sigma Investments, LP","self":true,"firms":[137137],"id":319},{"d":"2025-01-14","di":"2025-01-14","dr":"2025-01-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censured and civil money penalty of $150,000.","st":"Final","fine":150000.0,"dk":"FILE NO. 3-22414","al":"Navy capital allegedly failed to act in a manner consistent with its statements to prospective and existing investors in private funds about Navy capital's enhanced anti-money laundering (AML) due diligence practices on certain occasions between October 2018 and January 2022.","res":"Decision & Order of Offer of Settlement","sm":"This is a settled cease & desist order (\"order\") with the SEC, pursuant to which Navy capital neither admitted nor denied the allegations in the order. The order was filed and resolved pursuant to a settlement. No information Filed","ab":"Navy Capital Green Management, LLC","self":true,"firms":[299809],"id":320},{"d":"2025-01-13","di":"2025-01-13","dr":"2025-01-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":5600000.0,"dk":"INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 6816; ADMINISTRATIVE PROCEEDING FILE NO. 3-22403","al":"In January 2025, Carlyle Investment Management L.L.C., Carlyle global credit investment management L.L.C., and alpinvest partners B.V. (together, the \"Carlyle advisers\") entered into a settlement with the SEC and consented to the entry of an order (the \"order\") finding that the Carlyle advisers did not adhere to applicable recordkeeping provisions of the federal securities laws by failing to maintain and preserve certain communications on unapproved written communications platforms (\"off-channel communications\"), and that its failure to implement its procedures reasonably expected to prohibit these off-channel communications led to a failure to reasonably supervise its personnel. The violations fell under section 203(e)(6) of the Advisers Act, section 204 of the Advisers Act, and rule 204-2(a)(7) thereunder. The order required the Carlyle advisers to cease and desist from committing or causing future violations of section 204 of the Advisers Act and rule 204-2 thereunder, censured the Carlyle advisers, and required the Carlyle advisers to pay a civil monetary penalty, no portion of which was borne by the Carlyle advisers' clients. The Carlyle advisers also agreed to certain undertakings.","res":"Order","sd":"Carlyle Investment Management L.L.C. Paid a civil monetary penalty in the amount of $5,600,000 on January 16, 2025.","sm":"On January 13, 2025, the SEC announced the settled administrative order entered into by the Carlyle advisers, which is similar in form and content to those previously entered into by numerous other broker-dealers and investment advisers as part of the SEC's sweep of firms' use of off-channel communications. The order required the Carlyle advisers to cease and desist from committing or causing future violations of section 204 of the Advisers Act and rule 204-2 thereunder, censured the Carlyle advisers, and required the Carlyle advisers to pay a civil monetary penalty. The Carlyle advisers also agreed to certain undertakings. In the order, the SEC recognized the Carlyle advisers' cooperation with the SEC staff and the remedial efforts taken prior to and after being approached by SEC staff, including beginning to roll out to employees on-channel messaging platforms for external communications. No information Filed","ab":"Carlyle Investment Management L.L.C.","self":true,"firms":[111128],"id":321},{"d":"2025-01-13","di":"2025-01-13","dr":"2025-01-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty and censure","st":"Final","fine":11000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22401","al":"The SEC alleged that from December 2019, personnel at KKR sent and received off-channel communications that related to its advisory business. KKR did not maintain or preserve these off-channel communications, resulting in a violation of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder. KKR also failed to implement procedures reasonably expected to prevent off- channel communications and failed to reasonably supervise its personnel within the meaning of section 203(e)(6) of the Advisers Act.","res":"Settled","sd":"The order imposes a civil penalty of $11 million. The portion levied against KKR is 100%. Pursuant to the order, the penalty was paid on January 15, 2025.","sm":"The SEC administrative order is final. The civil penalty was paid on January 15, 2025. No information Filed","ab":"Kohlberg Kravis Roberts & Co. L.P.","self":true,"firms":[144533],"id":322},{"d":"2025-01-13","di":"2025-01-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":1200000.0,"dk":"INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 6816; ADMINISTRATIVE PROCEEDING FILE NO. 3-22403","al":"In January 2025, carlyle investment management L.L.C., carlyle global credit investment management L.L.C., and Alpinvest Partners B.V. (together, the \"carlyle advisers\") entered into a settlement with the SEC and consented to the entry of an order (the \"order\") finding that the carlyle advisers did not adhere to applicable recordkeeping provisions of the federal securities laws by failing to maintain and preserve certain communications on unapproved written communications platforms (\"off-channel communications\"), and that its failure to implement its procedures reasonably expected to prohibit these off-channel communications led to a failure to reasonably supervise its personnel. The violations fell under section 203(e)(6) of the Advisers Act, section 204 of the Advisers Act, and rule 204-2(a)(7) thereunder. The order required the carlyle advisers to cease and desist from committing or causing future violations of section 204 of the Advisers Act and rule 204-2 thereunder, censured the carlyle advisers, and required the carlyle advisers to pay a civil monetary penalty, no portion of which was borne by the carlyle advisers' clients. The carlyle advisers also agreed to certain undertakings.","res":"Order","sd":"Alpinvest partners BV paid a civil monetary penalty in the amount of $1,200,000 on January 16, 2025.","sm":"On January 13, 2025, the SEC announced the settled administrative order entered into by the carlyle advisers, which is similar in form and content to those previously entered into by numerous other broker-dealers and investment advisers as part of the SEC's sweep of firms' use of off-channel communications. The order required the carlyle advisers to cease and desist from committing or causing future violations of section 204 of the Advisers Act and rule 204-2 thereunder, censured the carlyle advisers, and required the carlyle advisers to pay a civil monetary penalty. The carlyle advisers also agreed to certain undertakings. In the order, the SEC recognized the carlyle advisers' cooperation with the SEC staff and the remedial efforts taken prior to and after being approached by SEC staff, including beginning to roll out to employees on-channel messaging platforms for external communications. No information Filed","ab":"Alpinvest Partners B.V.","self":true,"firms":[159215],"id":323},{"d":"2025-01-09","di":"2025-01-09","dr":"2025-01-09","k":"Regulatory Action","rg":"Other","reg":"ComisiÓN Nacional Bancaria Y de Valores (\"CNBV\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":123000.0,"dk":"CNBV.2S.2.211(4433)\"2023\"/1025/5 PTS","al":"On January 9, 2025, the ComisiÓN Nacional Bancaria Y de Valores (\"CNBV\") imposed a fine of approximately $123,000 usd (MNX $2,501,720) regarding the anti­money laundering and counter-terrorist financing program at BlackRock's mexico city office. Specifically, the CNBV found that BlackRock Mexico did not have sufficient procedures to assess whether potential transactions involving politically exposed persons were appropriate and to collect certain information about higher risk clients. Further, the CNBV identified instances where BlackRock Mexico did not maintain complete client files.","res":"Settled","sd":"Not applicable","sm":"See summary provided in section 7. The findings observed by the CNBV have already been corrected, and these actions have been communicated to the CNBV. The fine imposed by the CNBV is the minimum fine permissible under the applicable law for each finding.","ab":"BlackRock Mexico; BlackRock Mexico Operadora, S.A. de","firms":[106614,107105,290336],"id":324},{"d":"2025-01-08","di":"2018-05-01","dr":"2025-01-08","k":"Regulatory Action","rg":"State regulator","reg":"State of New Jersey Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.75,"dk":"CRD #250","al":"Pursuant to N.J.S.A. 49:3-58(a)(2)(XI), the State of New Jersey Bureau of Securities (the \"bureau\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The bureau found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of N.J.S.A. 49:3-58(a)(2)(XI) of the New Jersey securities law. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 and $15,000 in investigatory costs to the general Treasury of New Jersey.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":325},{"d":"2025-01-08","di":"2018-05-01","dr":"2025-01-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Department of Commerce Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DIVISION ORDER NO.: 25-001","al":"Pursuant to O.A.C. §1301:6­3­19(b)(9), the Ohio division of securities alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Ohio division of securities found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of O.A.C. §1301:6­3­19(b)(9) of the Ohio administrative code. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the Ohio investor education and enforcement expense fund.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":326},{"d":"2025-01-08","di":"2003-12-01","dr":"2025-01-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Payment as compensation for damages in a total amount of approximately euro 30,5 million plus legal expenses.","st":"Final","al":"On December 18, 2002, the italian stock market regulator (\"CONSOB\"), ruled that Mediobanca acted in concert with other companies during their combined purchase of more than 30% of the share capital of la fondiaria assicurazioni S.P.A. (\"Fondiaria\", now UNIPOLSAI assicurazioni S.P.A. (\"UNIPOLSAI\") in violation of articles 106, 109 and 122 of law decree no. 58 of 24 February 1998 (the italian consolidated financial act - \"tuf\") by omitting to launch a public tender offer, in breach of such mandatory provisions. Similar rulings have been issued by the administrative court of lazio (tar lazio), the italian antitrust authority (AGCM) and also by the court of appeal of milano and torino. Following such rulings, 16 civil proceedings were brought by fondiaria's minority shareholders against UNIPOLSAI and Mediobanca. With respect to the status of such proceedings, these have been all terminated. The proceeding brought by MR. roberto gavazzi, indicated as pending as of the date of the last civil judicial action disclosure reporting page, has been settled on January 9, 2025 with the payment by Mediobanca of an amount of 58,091.26 euro. The proceeding has been declared finally terminated by court order of January 29, 2025. With respect to the claims brought by the plaintiffs in all the proceedings, please note that an important principle has been stated, in one of the proceedings that was later settled, by the italian high court (court of cassation), in decision no. 14400 dated August 10, 2012. The court stated that each minority shareholder that has been unlawfully deprived of the chance to participate in a public tender offer on the shares has the right to receive compensation for damages subject to proof that the loss of the chance to gain profits depends on the lack of the launch of a public tender offer, in violation of the provisions of tuf. As a result, the proceedings relate to the same underlying violation of italian law and can thus be considered part of the same event or proceeding.","res":"Judgment Rendered","sd":"All payments have been made in accordance with the relevant settlement agreements and/or judgments.","ab":"Mediobanca - Banca Di","firms":[139138],"id":327},{"d":"2025-01-07","di":"2018-05-01","dr":"2025-01-07","k":"Regulatory Action","rg":"Other","reg":"The Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"116856-S","al":"Pursuant to sections 20.121(3)(a)(2) of the Florida administrative code, The Florida Office of Financial Regulation (\"office\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Florida office found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of sections 20.121(3)(a)(2) of the Florida administrative code. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state of Florida.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":328},{"d":"2025-01-02","di":"2023-08-03","dr":"2025-01-02","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina Department of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.0,"dk":"FILE NO. 22SEC113","al":"Pursuant to N.C. Gen. Stat. §78a­39(A1), the North Carolina secretary of state as administrator of the North Carolina Securities Act (the \"administrator\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The administrator found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of N.C. Gen. Stat. §78a­39(A1). Without admitting or denying the findings of facts or conclusions of law set forth in the final order, Edward jones agreed to pay an administrative monetary fine of $320,754.00 to the North Carolina secretary of state.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":329},{"d":"2024-12-31","di":"2024-12-31","dr":"2024-12-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"NO. 2023080783201","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from April 2015 through June 2023, Citigroup Global Markets Inc. (\"the firm\") permitted certain associated persons to engage in activities requiring qualification as a municipal securities representative when they were not qualified to act in that capacity, in violation of MSRB rules G-2 and G-3.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings in the AWC, the firm agreed to be censured and pay a $100,000 fine. The fine was paid in accordance with the terms of the AWC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":330},{"d":"2024-12-30","di":"2023-08-03","dr":"2024-12-30","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ORDER NO: SB-CO-04-23","al":"Pursuant to D.C. Official code § 31­5602.07 (a)(12) of the District of Columbia Securities Act of 2000 (\"the D.C. Securities Act\"), the commissioner of the D.C. Department of insurance, securities and banking (\"the department\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The department found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of D.C. Official code § 31­5602.07 (a)(12) of the D.C. Securities Act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the D.C. Treasurer.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":331},{"d":"2024-12-30","di":"2018-05-01","dr":"2024-12-30","k":"Regulatory Action","rg":"State regulator","reg":"Wisconsin Department of Financial Institutions, Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DFI CASE NO. S-248377 (LX)","al":"Pursuant to wis. Admin. Code § dfi­SEC. 4.05(2) of the Wisconsin uniform securities law, chapter 551 (\"the act\"), the Wisconsin Department of Financial Institutions, Division of Securities (the \"division\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of wis. Admin. Code § dfi­SEC. 4.05(2) of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 and $15,000.00 in investigatory costs to the state of Wisconsin.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":332},{"d":"2024-12-27","di":"2023-08-03","dr":"2024-12-27","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"2023-AH-0022","al":"Pursuant to chapter 808 kar 10:030, section 4(1) of the Kentucky revised statutes, the Kentucky Department of Financial Institutions alleged that, during theperiod of approximately July 1, 2016 to June 3, 2018, (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to thesale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged edwardjones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Kentucky Department of Financial Institutions found that Edward jones did not have reasonably designed procedures with respect to its activities as abroker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 808 kar 10:030, §4(1) of thekentucky revised statutes. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed topay an administrative monetary fine of $320,754.72 payable to the Kentucky state treasurer.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":333},{"d":"2024-12-27","di":"2023-08-03","dr":"2024-12-27","k":"Regulatory Action","rg":"State regulator","reg":"State of Tennessee Commissioner of Commerce and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"MATTER NO.: 23-01039","al":"Pursuant to tenn. Code ann. § 48­1­112(a)(2)(j), the commissioner of commerce and insurance for the state of Tennessee (\"commissioner\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of tenn. Code ann. § 48­1­112(a)(2)(j). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the Tennessee department of commerce and insurance.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":334},{"d":"2024-12-27","di":"2023-08-03","dr":"2024-12-27","k":"Regulatory Action","rg":"State regulator","reg":"The State of Minnesota, the Commissioner of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"82356","al":"Pursuant to minn. Stat. § 80A.67(d)(9) of the Minnesota Securities Act and minn. Stat. § 45.027 subd. 6 and 7, the state of Minnesota, commissioner of commerce alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The state of Minnesota, department of commerce found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of minn. Stat. § 80A.67(d)(9) of the Minnesota Securities Act and minn. Stat. § 45.027 subd. 6 and 7. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state of Minnesota.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":335},{"d":"2024-12-27","di":"2024-12-27","dr":"2024-12-27","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","san":"Censure","os":"Joint and several fine","st":"Final","fine":650000.0,"dk":"FILE NO. URE-259-01","al":"Prior to douglas Schadewald's employment with registrant, and during the time that he was affiliated with jane street options, LLC (\"JSOP\"), Schadewald and JSOP were alleged to have violated CBOE rule 8.1 and 8.16 in May 2021. Neither JSOP nor Schadewald admit or deny that violations of exchange rules have been committed.","res":"Consent","sd":"CBOE imposed a joint and several fine in the amount of $650,000 that was paid in full by jane street options, LLC. CBOE did not impose any suspension, bar, re-qualification condition, examination or retraining requirement.","sm":"Letter of consent, effective December 27, 2024, includes a waiver of the right to appeal. No information Filed","ab":"Schadewald, Douglas, Lee","firms":[158117],"id":336},{"d":"2024-12-27","di":"2024-12-27","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"The private investors of Samsung a club yield plus GEN2 qualified investment-type private placement investment NO.1 alledgedalleged that the firm violated its fiduciary duty by neglecting to inform the investor of the associated risks.","ab":"Samsung Securities Co. Ltd","firms":[158319],"id":337},{"d":"2024-12-26","di":"2023-08-03","dr":"2024-12-26","k":"Regulatory Action","rg":"State regulator","reg":"State of Oregon Department of Consumer and Business Services Division of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CASE NO. S-23-0046","al":"Pursuant to Oregon administrative rule (\"OAR\") 660:11-5-42(b)(22)(a), the DIRECTOR of the department of consumer and business services (\"DIRECTOR\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The director found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of oar 660:11-5-42(b)(22)(a). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the Oregon department of consumer & business services.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":338},{"d":"2024-12-24","di":"2018-05-01","dr":"2024-12-24","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Massachusetts, Office of the Secretary of the Commonwealth Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"E-2018-0048","al":"Pursuant to mass. Gen. Laws c. 110a, § 204(a)(2)(j), the Commonwealth of Massachusetts, Office of the Secretary of the Commonwealth Securities Division alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker- dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Commonwealth of Massachusetts, Office of the Secretary of the Commonwealth Securities Division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of mass. Gen. Laws c. 110a, § 204(a)(2)(j). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Commonwealth of Massachusetts secretary of state.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":339},{"d":"2024-12-24","di":"2023-08-03","dr":"2024-12-24","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"I-2023-000027","al":"Pursuant to NH rsa 421-b:4-401(f)(3)(b), the State of New Hampshire Bureau of Securities Regulation (the \"bureau\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The bureau found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of NH rsa 421-b:4-401(f)(3)(b) of the New Hampshire uniform Securities Act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the state of New Hampshire.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":340},{"d":"2024-12-23","di":"2024-12-23","dr":"2024-12-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3000000.0,"dk":"2020065501201","al":"Without admitting or denying the findings, J.P. Morgan Securities LLC (\"JPMS\") consented to sanctions and to entry of findings that (1) from June 2008 through August 2024, JPMS inaccurately reported approximately 820,000 short interest positions to FINRA, in violation of FINRA rules 4560 and 2010 and NASD rules 3360 and 2110; and (2) during the same period, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with its short interest reporting obligations, in violation of FINRA rules 3110(a) and (b) and 2010 and NASD rules 3010 and 2110.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":341},{"d":"2024-12-23","di":"2018-05-01","dr":"2024-12-23","k":"Regulatory Action","rg":"State regulator","reg":"The Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CASE NO. S-23-0013/ ORDER NO. S-23-0013-23-OR01","al":"Pursuant to ark. Code ann. § 23­42­301(f) and rule 301.01(c)(2), The Arkansas Securities Commissioner alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Arkansas Securities Commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of ark. Code ann. § 23­42­301(f) and rule 301.01(c)(2). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Arkansas securities department. Edward jones will additionally pay $15,000.00 for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":342},{"d":"2024-12-23","di":"2023-08-03","dr":"2024-12-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Wyoming, Compliance Division of the Wyoming Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"MATTER NO. 2023-02","al":"Pursuant to W.S. 17-4-412(d)(IX) of the Wyoming uniform Securities Act (\"the act\"), the Wyoming secretary of state alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Wyoming secretary of state found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of W.S. 17-4-412(d)(IX) of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the Wyoming secretary of state.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":343},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"Michigan Department of Licensing and Regulatory Affairs, Corporations, Securities, and Commercial Licensing Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ENF-23-020101","al":"Pursuant to MCL 451.2412(4)(I) of the Michigan uniform Securities Act, the director of the corporations, securities, and commercial licensing BUREAU (\"BUREAU\") within the state of Michigan, department of licensing and regulatory affairs alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The bureau found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of MCL 451.2412(4)(I) of the Michigan uniform Securities Act. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state treasurer, state of Michigan. Furthermore, as Michigan served as a lead state in this matter, Edward jones will pay $15,000.00 for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":344},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"INV23-171","al":"Pursuant to NRS 90.420(1)(l), the State of Nevada Office of the Secretary of State Securities Division alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"State of Nevada Office of the Secretary of State Securities Division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of NRS 90.420(1)(l). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Nevada secretary of state. Edward jones will additionally pay $15,000.00 for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":345},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ADMINISTRATIVE ORDER NO. CA-2024-0032","al":"Pursuant to section 8-6-3(j)(10) of title 8, chapter 6, code of Alabama, The Alabama Securities Commission alleged that, during the period of approximately July 1,2016 to June 3, 2018, (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to the sale of certain class a sharemutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as theirinvestment adviser and manage those assets.","res":"Consent","sm":"The Alabama Securities Commission found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealerduring the investigation period that would have detected the conduct alleged, which constituted a violation of section 8-6-3(j)(10) of title 8, chapter 6, codeof Alabama. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay anadministrative monetary fine of $320,754.72 payable to The Alabama Securities Commission.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":346},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of California - Department of Financial Protection and Innovation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CRD NO. 250","al":"Pursuant to corporations code section 25218 and code of regulations, title 10, section 260.218.4, the state of California's commissioner of the department of financial protection and innovation alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner of the department of financial protection and innovation found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of corporations code section 25218 and code of regulations, title 10, section 260.218.4. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72, payable to the California department of financial protection and innovation.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":347},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Colorado Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"2023-CDS-019","al":"Pursuant to §§ 11­51­410(1)(I), 11­51­606(2)(a) and (b)(II), C.R.S. Of the Colorado Securities Act, the securities commissioner ­ state of Colorado alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The state of Colorado's securities commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of §§ 11­51­606(2)(a) and (b)(II), C.R.S. Of the Colorado Securities Act. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the state of Colorado.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":348},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Commissioner of Securities and Insurance, Office of the Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"SEC-2023-00223","al":"Pursuant to mont. Code ann. § 30­10­201(13)(k), The Commissioner of Securities and Insurance, Office of the Montana State Auditor, alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Commissioner of Securities and Insurance, Office of the Montana State Auditor found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of mont. Code ann. § 30­10­201(13)(k). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state of Montana. Edward jones will additionally pay $15,000.00 for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":349},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"OFI-2023-03","al":"Pursuant to 51:704(a)(9) of the Louisiana securities law (LSL), the Louisiana Office of Financial Institutions alleged that, during the period of approximatelyjuly 1, 2016 to June 3, 2018, (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to the sale of certain class ashare mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as theirinvestment adviser and manage those assets.","res":"Consent","sm":"The Louisiana Office of Financial Institutions found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 51:704(a)(9) of the Louisiana securitieslaw. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrativemonetary fine of $320,754.72 payable to the state of Louisiana Office of Financial Institutions.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":350},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico Regulation and Licensing Department Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CASE NO. MS-23-7-10","al":"Pursuant to 12.11.4.10 nmac, the securities division of the New Mexico regulation and licensing department (the \"division\") alleged that, during the period ofapproximately July 1, 2016 to June 3, 2018, (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to the sale ofcertain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones toserve as their investment adviser and manage those assets.","res":"Consent","sm":"The division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigationperiod that would have detected the conduct alleged, which constituted as a violation of 12.11.4.10 nmac of the New Mexico securities law. Without admittingor denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of$320,754.72 to the division.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":351},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Nebraska Department of Banking and Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CRD #250","al":"Pursuant to Securities Act of Nebraska, neb. Rev. Stat section 8-1103(9)(a)(XI) of the act, The Nebraska Department of Banking and Finance alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Nebraska Department of Banking and Finance found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of the Securities Act of Nebraska, neb. Rev. Stat section 8-1103(9)(a)(XI). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to The Nebraska Department of Banking and Finance.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":352},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"The Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"NO. 2023-29","al":"Pursuant to The Maine Office of Securities rule chapter 504 § 7(1), the Maine securities administrator alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Maine securities administrator found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 504 § 7(1) of The Maine Office of Securities rule. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the treasurer, state of Maine.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":353},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of Maryland","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"SECURITIES DOCKET NO. 2023-0261","al":"Pursuant to section 11-412(a)(10) of the Maryland Securities Act, the Securities Commissioner of Maryland alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Securities Commissioner of Maryland found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of section 412(a)(10)of the Maryland Securities Act. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state of Maryland, Maryland office of the attorney general.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":354},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Washington State Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ORDER NO. S-19-2768-23-CO01","al":"Pursuant to RCW 21.20.110(1)(j) of the Securities Act of Washington (the \"act\"), the Securities Division of the Washington State Department of Financial Institutions (the \"securities division\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The securities division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of RCW 21.20.110(1)(j) of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the securities division, plus an additional $15,000 to cover investigatory costs incurred by the securities division while serving as a lead state in this matter spanning multiple states.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":355},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DOCKET NO. 24 E 016 / KSC NO. 2024-6907","al":"Pursuant to Kansas uniform Securities Act section 17-12A412(c), the securities commissioner of the state of Kansas alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The securities commissioner of the state of Kansas found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of Kansas uniform Securities Act section 17-12A412(c). Without admitting or denying the findings ( ) of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Kansas insurance department.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":356},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Attorney General of the State of New York Investor Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"NO. 24-097","al":"Pursuant to executive law section 63(15), the Attorney General of the State of New York Investor Protection Bureau (\"BUREAU\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The bureau found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of executive law section 63(15). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the bureau.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":357},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of North Dakota Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CRD #250","al":"Pursuant to N.D.C.C. § 10­04­11(1)(m), the North Dakota securities commissioner, as administrator of the Securities Act (the \"securities commissioner\"), alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The securities commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of N.D.C.C. § 10­04­11(1)(m) of the North Dakota Securities Act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the North Dakota securities department.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":358},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ORDER NO. IC-25-CAF-01","al":"Pursuant to § 115.10(a)(1) of 7 tex. Admin. Code §§101.1­139.27 (2022) (tex. State SEC. BD.) (The \"board rules\"), the Texas securities commissioner (the \"commissioner\") as administrator of the Texas Securities Act alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of § 115.10(a)(1) of the board rules. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72, plus an additional $15,000 for Texas serving as the lead state in this matter that has spanned multiple states, to the state of Texas.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":359},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"U.S. Virgin Islands Division of Banking, Insurance, and Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DOCKET NO.: 2023-003","al":"Pursuant to title 9 CH. 23 § 642(d)(9) of the virgin islands code (\"VIC\"), the securities administrator (the \"administrator\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The administrator found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of title 9 CH. 23 § 642(d)(9) of the vic. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the government of the U.S. virgin islands.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":360},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ODS FILE 24-001","al":"Pursuant to rule 660:11-5-42(b)(22)(a)of the Oklahoma uniform Securities Act of 2004 (the \"act\"), the administrator of the Oklahoma department of securities (the \"administrator\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The administrator found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of rule 660:11-5-42(b)(22)(a) of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the Oklahoma state treasurer.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":361},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"LS-23-6227","al":"Pursuant to 1 Mississippi admin code PT. 14, r. 5.19 of the Mississippi Securities Act, the office of the Mississippi secretary of state, securities division, alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The office of the Mississippi secretary of state, securities division, found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 1 Mississippi admin code PT. 14, r. 5.19. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Mississippi secretary of state's office.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":362},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DOCKET NO. 240047 (SEC-CAO)","al":"Pursuant to 10 pa. Code § 305.011 (a), the department of banking and securities (\"department\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The department found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of 10 pa. Code § 305.011 (a). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the department of banking and securities.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":363},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Puerto Rico Office of the Commissioner of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CRD #250","al":"Pursuant to article 204(a)(2)(j) of Puerto Rico uniform Securities Act (\"PRUSA\") and article 28 of regulation no. 6078 of January 19, 2000, as amended, known as \"regulation under the uniform Securities Act\" (\"regulation 6078\"), the office of the commissioner of financial institutions act (the \"commissioner\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of article 204(a)(2)(j) of prusa and regulation 6078. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the department of Treasury of the Commonwealth of Puerto Rico.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":364},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Rhode Island Department of Business Regulation Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DBR NO. 2023-SC-003","al":"Pursuant to R.I. Gen. Laws § 7­11­212(b)(11), the DIRECTOR of the department of business regulation (\"DIRECTOR\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The director found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of R.I. Gen. Laws § 7­11­212(b)(11). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the general fund of the state of Rhode Island.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":365},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Indiana Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"23-0017 CA","al":"Pursuant to 710 I.A.C. Section 4-7-6(d)(1) of the Indiana uniform Securities Act, the Indiana securities division as administrator of the Indiana Securities Act alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Indiana securities division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 710 I.A.C. Section 4-7-6(d)(1) of the Indiana uniform Securities Act. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to state of Indiana secretary of state notary. Furthermore, as Indiana served as a lead state in this matter, Edward jones will also pay an additional $15,000.00 payable for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":366},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"MATTER NO. 20233326","al":"Pursuant to S.C. Code ann. § 35­1­412(d)(9), the Securities Commissioner of South Carolina (the \"securities commissioner\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The securities commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of S.C. Code ann. § 35­1­412(d)(9). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the office of the attorney general of the state of South Carolina.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":367},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Department of Labor","reg":"State of South Dakota Department of Labor and Regulation, Division of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CRD #250","al":"Pursuant to arsd 20:08:03:01(2)(b), the director of the division of insurance (the \"director\") as administrator of the South Dakota Securities Act alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The director found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of arsd 20:08:03:01(2)(b). Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the state of South Dakota.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":368},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution","st":"Final","dk":"2021069467101","al":"FINRA alleged that, between January 2015 and June 2020, Edward jones violated FINRA rules 3110(a) and 2010 by failing to establish and maintain a system reasonably designed to supervise the application of sales charge waivers and fee rebates to which customers were entitled through rights of reinstatement offered by mutual fund companies. FINRA further alleged that, as a result, customers paid $4,440,979 in excess sales charges and fees between January 2015 and June 2020.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 20, 2024, Edward jones entered into an AWC with FINRA without admitting or denying the findings. Edward jones agreed to a censure and to pay restitution in the amount of $4,440,979 plus interest.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":369},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"The Alaska Department of Commerce, Community, an Economic Development Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"23-106-S","al":"Pursuant to Alaska statute 3 aac 08.030(a)(2) the state of Alaska department of commerce, community, and economic development division of banking and securities alleged that, during the period of approximately July 1, 2016 to June 3, 2018 (the \"investigation period\"), Edward jones' procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The state of Alaska department of commerce, community, and economic development division of banking and securities commission found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker- dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 3 aac 08.030(a)(2). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the state of Alaska.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":370},{"d":"2024-12-20","di":"2018-05-01","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut's Department of Banking Securities and Business Investments Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CO-23-11056-S","al":"Pursuant to section 36B-31-6F(b) of the regulations of Connecticut state agencies, the State of Connecticut's Department of Banking Securities and Business Investments Division alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"State of Connecticut's Department of Banking Securities and Business Investments Division found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation 36B-31-6F(b) of the regulations of Connecticut state agencies. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the treasurer, state of Connecticut. Edward jones will additionally pay $15,000.00 for investigatory costs.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":371},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"SEB20230062","al":"Pursuant to Hawaii revised statutes § 485a­412(d)(9) the Hawaii department of commerce and consumer affairs alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Hawaii department of commerce and consumer affairs found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of Hawaii revised statutes § 485a­412(d)(9). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the general fund of the state of Hawaii.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":372},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Department of Finance of the State of Idaho","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"2023-7-06","al":"Pursuant to Idaho administrative procedures act rule 12.01.08.105.03 the Idaho department of finance alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Idaho department of finance found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of Idaho administrative procedures act rule 12.01.08.105.03. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the general fund of the finance department of Idaho.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":373},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"The Illinois Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"FILE NO. 2300475","al":"Pursuant to section 8.e(1)(e)(IV) of the Illinois securities law of 1953, the Illinois securities division as administrator of the Illinois securities law, alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Illinois Securities Department found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of section 8.e(1)(e)(IV) of the Illinois securities law of 1953. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to The Illinois Securities Department.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":374},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of West Virginia, West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"MATTER NO. 23-0071","al":"Pursuant to § 32­2­204(a)(2)(j) of the West Virginia uniform Securities Act (the \"Securities Act\"), the West Virginia securities commission (the \"securities commission\") alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker- dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The securities commission found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of § 32­2­204(a)(2)(j) of the Securities Act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 to the state of West Virginia.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":375},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"The Georgia Commissioner of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"ENSC-241123","al":"Pursuant, to rule 590-4-5-.12 of the Georgia uniform Securities Act, the commissioner of securities of the state of Georgia alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner of securities of the state of Georgia found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of O.C.G.A. Rule 590-4-5-.12. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Georgia secretary of state revenue.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":376},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"The Delaware Investor Protection Unit","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"23-0136","al":"Pursuant, to rule 609(b)(4)(a) of the rules pursuant to the Delaware Securities Act, the investor protection director of the state of Delaware alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The investor protection director of the state of Delaware found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of rule 609(b)(4)(a) of the Delaware Securities Act. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the investor protection fund of the state of Delaware.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":377},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"DOCKET NO. 23-016-S","al":"Pursuant to V.S.R. § 2­2 of the Vermont uniform Securities Act (\"act\"), the commissioner of financial regulation (the \"commissioner\") for the state of Vermont alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker- dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted as a violation of V.S.R. § 2­2 of the act. Without admitting or denying the findings of facts or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $272,641.52 to the department of financial regulation, as well as providing a contribution of $48,113.20 to the Vermont financial services education and victim restitution special fund.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":378},{"d":"2024-12-20","di":"2023-08-03","dr":"2024-12-20","k":"Regulatory Action","rg":"Other","reg":"The Iowa Insurance Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"CASE NO. 119293","al":"Pursuant to Iowa code § 502.412(4)(I), The Iowa Insurance Division alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Iowa insurance commissioner found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of Iowa code § 502.412(4)(I). Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to The Iowa Insurance Division's enforcement fund.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":379},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist and censure","st":"Final","fine":900000.0,"dk":"3-22374","al":"The Securities and Exchange Commission alleged that LPL (1) willfully violated section 17(a)(1) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rule 17A-4(j) by failing to furnish promptly true and complete electronic blue sheet (\"EBS\") information as requested by the SEC staff from at least July 2018 through May 2021, and (2) willfully violated Exchange Act rule 17A-25 by failing to submit electronically certain securities transaction information to the SEC through the EBS systems in response to requests made by the SEC.","res":"Order","sm":"On December 20, 2024, LPL entered into a settlement order with the SEC settling an administrative action which found that LPL (1) willfully violated section 17(a)(1) of the Exchange Act and rule 17A-4(j) by failing to furnish promptly true and complete electronic blue sheet (\"EBS\") information as requested by the SEC staff from at least July 2018 through May 2021, and (2) willfully violated Exchange Act rule 17A-25 by failing to submit electronically certain securities transaction information to the SEC through the EBS systems in response to requests made by the SEC. LPL engaged in voluntary remedial efforts concerning its EBS systems and control environment. In determining to accept LPL's offer of settlement, the SEC considered remedial acts promptly undertaken by LPL and cooperation afforded the SEC staff. LPL admitted to the facts set forth in the order, acknowledged that its conduct violated the federal securities laws and agreed to the imposition of a censure, a cease and desist from committing or causing any violations and future violations of these rules and to pay a civil monetary penalty in the amount of $900,000. The civil monetary penalty was paid in accordance with the terms of the settlement order.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":380},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":900000.0,"dk":"2020067449801","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that LPL submitted certain blue sheets to FINRA that inaccurately reported one or more of 12 types of transaction information in violation of FINRA rules 8211, 8213 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 20, 2024, LPL entered into an AWC with FINRA which alleged that LPL submitted certain blue sheets to FINRA that inaccurately reported one or more of 12 types of transaction information in violation of FINRA rules 8211, 8213 and 2010. Without admitting or denying the findings, LPL agreed to the imposition of a censure and to pay a fine in the amount of $900,000. The fine was paid in accordance with the terms of the AWC.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":381},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":900000.0,"dk":"NO. 2019062573101","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from at least 2011 through February 2023, Wells Fargo Clearing Services, LLC (\"the firm\") submitted approximately 22,000 blue sheets to FINRA that contained inaccurate information, in violation of FINRA rules 8211, 8213, and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 20, 2024, the firm became subject to a letter of acceptance, waiver and consent issued by FINRA regarding allegations that, from at least 2011 through February 2023, the firm submitted approximately 22,000 blue sheets to FINRA that contained inaccurate information, in violation of FINRA rules 8211, 8213, and 2010. Without admitting or denying the findings in the AWC, the firm agreed to be censured and pay a $900,000 fine. The fine was paid in accordance with the terms of the AWC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":382},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":900000.0,"dk":"FILE NO. 3-22373","al":"The Securities and Exchange Commission (\"SEC\") alleged that Wells Fargo Clearing Services, LLC (the \"firm\"), from July 20, 2018 through February 24, 2023, in response to requests from the SEC, made approximately 11,195 electronic blue sheets submissions to the SEC that contained inaccurate information or omissions, as the result of various types of errors, in willful violation of section 17(a)(1) of the Securities Exchange Act of 1934 (\"Exchange Act\") and Exchange Act rules 17A-4(j) and 17A-25 thereunder.","res":"Order","sm":"On December 20, 2024, the SEC entered into a settlement order with the firm to settle an administrative action which alleged that the firm, from July 20, 2018 through February 24, 2023, in response to requests from the SEC, made approximately 11,195 electronic blue sheets submissions to the SEC that contained inaccurate information or omissions, as the result of various types of errors, in willful violation of section 17(a)(1) of the Securities Exchange Act of 1934 (\"Exchange Act\") and Exchange Act rules 17A-4(j) and 17A-25 thereunder. In determining the accept the firm's offer of settlement, the SEC considered remedial acts undertaken by the firm and cooperation afforded the SEC staff. The firm admitted the facts set forth in section III of the order and acknowledged that its conduct violated the federal securities laws. The firm agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a)(1) of the Exchange Act and Exchange Act rules 17A-4(j) and 17A-25 thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $900,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":383},{"d":"2024-12-20","di":"2024-12-20","dr":"2024-12-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000000.0,"dk":"FILE NO. 3-22375","al":"The SEC found that Deutsche Bank Securities, inc. (\"DBSI\") failed to timely file certain suspicious activity reports, and, on certain occasions failed to promptly investigate or complete investigations of potentially suspicious activity within a reasonable period of time. The SEC found that from April 2019 through March 2024, DBSI received certain requests in connection with law enforcement or regulator investigations or litigation and failed to promptly conduct or complete related investigations of suspicious activity within a reasonable period of time.","res":"Order","sm":"On December 20, 2024, without admitting or denying the findings therein, dbsi entered into a settlement with the SEC finding that dbsi failed to timely file certain suspicious activity reports, and, on certain occasions failed to promptly investigate or complete investigations of potentially suspicious activity within a reasonable period of time. The SEC found that from April 2019 through March 2024, dbsi received certain requests in connection with law enforcement or regulator investigations or litigation and failed to promptly conduct or complete related investigations of suspicious activity within a reasonable period of time. Dbsi was (I) ordered to cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-8 promulgated thereunder and (II) ordered to pay a civil monetary penalty in the amount of $4,000,000, which will be timely paid.","ab":"Deutsche Bank Securities","firms":[300838],"id":384},{"d":"2024-12-17","di":"2024-12-17","dr":"2024-12-17","k":"Regulatory Action","rg":"Other","reg":"Arizona Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"S-21333A-24-0245","al":"The state alleged 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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Arizona and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Arizona customers in an amount of no less than $136,168.02. Further, total restitution to participating states in an amount of no less than $8,383,167.46. 13. The firm neither admitted nor denied the statement of facts and violation of A.R.S. § 44­L96L (a)(3).","ab":"Raymond James Financial","firms":[705],"id":385},{"d":"2024-12-13","di":"2024-12-13","dr":"2024-12-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"A civil money penalty in the amount of $150,000","st":"Final","fine":150000.0,"dk":"FILE NO. 3-22352","al":"Failure to file and periodically update a report on form PF to provide information about the private funds they manage","res":"Decision & Order of Offer of Settlement","sd":"The firm submitted an offer of settlement, which the commission has determined to accept, without admitting or denying the findings, to resolve the matter in question.","sm":"The firm submitted an offer of settlement, which the commission has determined to accept, without admitting or denying the findings, to resolve the matter in question. No information Filed","ab":"The Catalyst Capital Group Inc.","self":true,"firms":[155299],"id":386},{"d":"2024-12-13","di":"2024-10-02","dr":"2024-12-13","k":"Regulatory Action","rg":"Other","reg":"Autorite Des Marches Financiers in France","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"On appeal","fine":11224625.0,"dk":"2023-12","al":"Non-compliance with publicly-traded equity security rules in France provided in article 12 of regulation (EU) no. 596/2014 of the european parliament and of the council of April 16, 2014 on market abuse, as amended. Non-compliance with publicly-traded equity security beneficial ownership reporting rules in France provided in article l. 233-7 of the french commercial code.","res":"Order","sd":"The Autorite des marches financiers (\"AMF\") in France stated that (I) registrant and MR. Nodelman violated articles 12 and 15 of the regulation (EU) no. 596/2014 of the european parliament and of the council of April 16, 2014 on market abuse, and (II) registrant had not complied with publicly-traded equity security beneficial ownership reporting requirements in France provided in article 233-7 of the french commercial code and rule 223-14 of the AMF's regulations. Under french law, there is strict liability for any violation, and the AMF does not have to show that anyone acted intentionally, recklessly or even negligently.","sm":"On December 13, 2024, the autoriite des financiers (\"AMF\") in France stated that (I) registrant and MR. Nodelman violated articles 12 and 15 of the regulation (EU) no. 596/2014 of the european parliament and of the council of April 16, 2014 on market abuse, and (II) registrant had not complied with publicly-traded equity security beneficial ownership reporting requirements in France provided in article 233-7 of the french commercial code and rule 223-14 of the AMF's regulations. Registrant was fined ?7 million, and MR. Nodelman was fined ?3 million. Under french law, there is strict liability for any violation, and the AMF does not have to show that anyone acted intentionally, recklessly or even negligently. On February 18, 2025, registrant and MR. Nodelman lodged an appeal on this AMF decision before the court of appeal of paris. This appeal is still pending. No information Filed","ab":"Nodelman, Oleg, NMN","firms":[167121],"id":387},{"d":"2024-12-13","di":"2024-12-13","dr":"2024-12-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure","st":"Final","fine":125000.0,"dk":"FILE NO. 3-22351","al":"This matter involves Kudu Investment Holdings, LLC's (\"KIH\") violations of the reporting provisions of rule 204(b)-1 under the Investment Advisers Act of 1940 (the \"Advisers Act\"), which requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on form PF to provide information about the private funds they manage. Pursuant to an order entered by the U.S. Securities and Exchange Commission (the \"commission\") on December 13, 2024 against KIH, the commission found that, from 2019 through 2023, KIH was subject to the reporting requirements of rule 204(b)-1, but failed to file or update a report on form PF.","res":"Order","sd":"Kih was ordered to pay a civil money penalty of $125,000, which was paid on December 13, 2024.","sm":"On December 13, 2024, the commission entered an order instituting administrative and cease-and-desist proceedings against kih. Pursuant to the order, the commission found that, from 2019 through 2023, kih was subject to the reporting requirements of rule 204(b)-1 under the Advisers Act, but failed to file or update a report on form PF. The order recognized the cooperation afforded the commission staff by kih. Kih submitted an offer of settlement without admitting or denying the findings in the order and agreed to: (I) cease and desist from committing or causing any violations and any future violations of rule 204(b)-1 under the Advisers Act, (II) a censure and (III) pay a civil money penalty of $125,000. No information Filed","ab":"Kudu Investment Holdings, LLC","self":true,"firms":[174350],"id":388},{"d":"2024-12-13","di":"2024-08-02","dr":"2024-12-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censured","st":"Final","fine":90000.0,"dk":"3-22349","al":"This matter involves Greenhaven's violations of the reporting provisions of rule 204(b)-1 under the Advisers Act.","res":"Decision & Order of Offer of Settlement","sd":"Order to pay a civil money penalty in the amount of $90,000.","sm":"On December 13, 2024, the advisor settled an SEC action related to its failure to report form PF and annual updates for its fiscal years 2021, 2022, and 2023. As part of the settlement, the adviser agreed to pay a fine of $90,000 and desist from committing or causing any future violations of rule 204(b)-1 under the Advisers Act (relating to the adviser's obligation to file a form PF). No information Filed","ab":"Greenhaven Road Investment Management, LP","self":true,"firms":[288555],"id":389},{"d":"2024-12-12","di":"2024-12-12","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"The private investor of Samsung a club yield plus GEN2 qualified investment-type private placement investment NO.2 alleged that the firm violated its fiduciary duty by neglecting to inform the investor of the associated risks.","ab":"Samsung Hedge Asset","firms":[158319],"id":390},{"d":"2024-12-12","di":"2024-12-12","dr":"2024-12-12","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Commission","san":"Cease and Desist","st":"Final","fine":6750000.0,"dk":"3-22349","al":"The Securities and Exchange Commission (\"commission\") deems it appropriate that cease-and-desist proceedings be, and hereby are, instituted against Cantor Fitzgerald, L.P. (\"CFLP\"). In anticipation of the institution of these proceedings, CFLP has submitted an offer of settlement which the commission has determined to accept. The commission finds that this matter concerns materially false and misleading statements made by two special purpose acquisition companies (\"SPACS\") controlled by Cantor Fitzgerald, L.P. (\"CFLP\"). The misstatements relate to activities CFLP, acting through a small team consisting of CFLP executives as well as personnel employed by CFLP subsidiaries, caused each spac to take prior to its initial public offering. This small CFLP team controlled the actions of the CFLP SPACS, including conducting a centralized search for potential business combination targets, and engaging in substantive discussions with potential targets. To date CFLP has sponsored nine SPACS through subsidiaries, with the majority launching their ipos over the seven months spanning August 2020 to February 2021. In November 2020, a CFLP spac, CF finance acquisition corp. II (\"cfac II\"), announced an agreement to merge with view, inc. in Form S-1 filings and a prospectus CFLP caused cfac II to file with the commission before its August 2020 IPO, cfac II falsely stated that neither cfac II nor anyone acting on its behalf had initiated any substantive discussions with any business combination target, contacted any of the prospective target businesses considered by CFLP's prior spac CF finance acquisition corp., or approached any specific target business. In fact, CFLP personnel, acting on behalf of the spac, had already initiated discussions with view and at least one other potential target regarding a potential business combination as early as June 2020, and those discussions continued during the time period before the cfac II IPO. The Form S-4 filings and a business combination proxy statement CFLP caused cfac II to file with the commission in February 2021 also included false statements about the true history of CFLP's interactions with view. Similarly, in July 2021, another CFLP spac, CF acquisition corp. v (\"cfac v\"), announced an agreement to merge with satellogic inc. the Form S-1 filings and a prospectus CFLP caused cfac v to file with the commission before its January 2021 IPO falsely stated that neither cfac v nor anyone acting on its behalf had initiated any substantive discussions with any business combination target, contacted any of the prospective target businesses considered by the four prior CFLP SPACS, or approached any specific target business. In fact, CFLP personnel, acting on behalf of its SPACS, had already initiated discussions with satellogic and at least two other potential targets regarding a potential business combination as early as December 2020, and those discussions continued during the time period before the cfac v IPO. Pre-IPO discussions with satellogic about a potential business combination with a CFLP spac explicitly included the possibility of using the not-yet-launched cfac v as the acquisition vehicle. The business combination proxy statement CFLP caused cfac v to file with the commission in November 2021 also included false statements about the true history of CFLP's interactions with satellogic. As a result of the materially misleading statements described throughout this order, CFLP caused cfac II and cfac v to violate sections 17(a)(2) and 17(a)(3) of the Securities Act, antifraud provisions of the federal securities laws. CFLP also caused cfac II and cfac v to violate section","res":"Order","sd":"CFLP is ordered to cease and desist from committing or causing any violations and any future violations of sections 17(a) (2) or 17(a)(3) of the Securities Act and section 14(a) of the Exchange Act and rule 14A-3 thereunder and shall pay a civil money penalty of $6.75 million.","sm":"CFLP caused cfac II and cfac v to violate sections 17(a)(2) and 17(a)(3) of the Securities Act, antifraud provisions of the federal securities laws. CFLP also caused cfac II and cfac v to violate section 14(a) of the Exchange Act and rule 14A-3 thereunder. Accordingly, it is hereby ordered that respondent CFLP shall cease and desist from committing or causing any violations and any future violations of sections 17(a)(2) or 17(a)(3) of the Securities Act and section 14(a) of the Exchange Act and rule 14A-3 thereunder and shall pay a civil money penalty of $6.75 million. We are required to make this disclosure in regard to Cantor Fitzgerald LP (\"CFLP\") being fined by the SEC. this is not related to investment advice provided by this firm. No information Filed","ab":"Cantor Fitzgerald, L.P.","firms":[336332],"id":391},{"d":"2024-12-09","dr":"2024-12-09","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, undertaking","st":"Final","fine":15000000.0,"dk":"FILE NO. 3-22339","al":"The Securities and Exchange Commission alleged that, Morgan Stanley Smith Barney LLC (the firm) failed to adopt and implement policies and procedures reasonably designed to prevent personnel from misusing and misappropriating funds in client accounts and the firm's inadequate policies and procedures and systems to implement them led to its failure reasonably to supervise the four fas, who misappropriated funds from client and customer accounts while employed at the firm. The SEC found that the firm failed to adopt and implement policies and procedures reasonably designed to prevent and detect unauthorized externally- initiated ach payments and unauthorized cash wires. The SEC found that the firm (1) willfully violated section 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 206(4)-7 thereunder; and (2) failed to supervise the fas within the meaning of section 203(e)(6) of the Advisers Act and/or section 15(b)(4)(e) of the Securities Exchange Act of 1934.","res":"Order","sm":"On December 9, 2024, the SEC entered into a settlement order with the firm settling an administrative action which found that the firm failed to adopt and implement policies and procedures reasonably designed to prevent personnel from misusing and misappropriating funds in client accounts and the firm's inadequate policies and procedures and systems to implement them led to its failure reasonably to supervise the four fas, who misappropriated funds from client and customer accounts while employed at the firm. The SEC found that the firm failed to adopt and implement policies and procedures reasonably designed to prevent and detect unauthorized externally-initiated ach payments and unauthorized cash wires. Upon being informed of the potential unauthorized activity of two of the fas, the firm promptly investigated the matters, terminated the fas, reported the fraud to law enforcement agencies, and fully repaid the affected clients. The firm also conducted a retroactive review of payment instructions for externally-initiated ach payment instructions, which led to the identification of misconduct by the other two fas. The firm accordingly terminated the other two fas and reported the misconduct to SEC staff. The firm proactively instituted new written procedures to address the conduct at issue and retained a compliance consultant. The SEC found that the firm (1) willfully violated section 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 206(4)-7 thereunder; and (2) failed to supervise the fas within the meaning of section 203(e)(6) of the Advisers Act and/or section 15(b)(4)(e) of the Securities Exchange Act of 1934. The firm consented, without admitting or denying the findings and without adjudication of any issue of law or fact, to: a censure, cease and desist from committing or causing future violations; certain undertakings, including the retention of an independent compliance consultant and pay a civil penalty of $15,000,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":392},{"d":"2024-12-06","di":"2024-12-06","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Monetary damages, equitable relief, and other relief as determined by the court","st":"Pending","al":"Plaintiff alleges breaches of fiduciary duty, breach of contract, unjust enrichment, fraud, and related claims in connection with the management and operation of private investment funds.","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":393},{"d":"2024-11-27","di":"2024-11-27","k":"Civil Judicial Action","san":"Other","os":"Civil fine/penalty, money damages, injunction and return of fees and costs.","st":"Pending","al":"On November 27, 2024, Texas attorney general ken paxton and attorneys general from 10 other states (Alabama, Arkansas, Indiana, Iowa, Kansas, Missouri, Montana, Nebraska, West Virginia, and Wyoming) filed a complaint against BlackRock, vanguard, and state street (the \"managers\") alleging that the managers used their ownership stakes in coal companies to artificially reduce coal output in violation of various state and federal antitrust laws. Texas also claims BlackRock made false and deceptive statements in connection with the marketing of its non-ESG ETFS.","ab":"BlackRock Inc; BlackRock, Inc.","firms":[106614,107105,282125,290336],"id":394},{"d":"2024-11-27","di":"2024-11-27","dr":"2024-11-27","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"\"- Warning - disciplinary actions against employees, including a three-month pay reduction, warning, and etc. - voluntary","st":"Final","al":"\"Financial services commission (FSC) alleged that Samsung Life Insurance co. LTD. has violated: - duty of care by misrepresentation and omission of material facts in the sale of financial investment products. - Its obligation to comply with the principle of suitability.\"","res":"Decision & Order of Offer of Settlement","sd":"See details below","sm":"On November 27, 2024, the FSC issued a notice of its decision, finding that Samsung Life Insurance co., LTD. was liable for the allegations listed in our response to question 7. As a result, FSC issued a warning and ordered disciplinary actions against employees, including a three-month pay reduction, warnings, etc. additionally, the FSC ordered voluntary corrective measures for its employees.","ab":"Samsung Life Insurance","firms":[158319],"id":395},{"d":"2024-11-25","di":"2024-11-25","dr":"2024-11-25","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"\"- Penalty sub-charge: KRW 2,021 mil / usd 1,372,496 (exchange rate 1472.5) - voluntary corrective measures on its employee\"","st":"Final","fine":1372496.0,"al":"\"Financial services commission (FSC) alleged that Samsung Life Insurance co. LTD. has violated: - prohibited conducts concerning the conclusion or solicitation of insurance contracts \"","res":"Decision & Order of Offer of Settlement","sd":"See below for detail","sm":"On November 25, 2024, the FSC issued a notice of its decision, finding that Samsung Life Insurance co., LTD. was liable for the allegations listed in our response to question 7. As a result, FSC imposed a fine of KRW 2.021 billion in aggregate and ordered voluntary corrective measures for its employees.","ab":"Samsung Life Insurance","firms":[158319],"id":396},{"d":"2024-11-15","di":"2024-11-15","dr":"2024-11-15","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":60000.0,"dk":"NO. 2020.06.0171","al":"The Nasdaq Stock Market LLC (\"Nasdaq\") alleged that Citigroup Global Markets, inc. (\"the firm\") (1) failed to satisfy its two-sided continuous quoting obligation from October 1, 2019 through June 30, 2020, in violation of Nasdaq rule 4613(a), (2) submitted bid/offer interest outside of the designated percentage from January 1, 2021 through June 30, 2021, in violation of Nasdaq rule equity 2, section 5(a)(2), and (3) failed to maintain a supervisory system reasonably designed to achieve compliance with Nasdaq rules 4613(a) and equity 2, section 5(a)(2) from October 1, 2019 through June 30, 2021, in violation of Nasdaq rules 3010 and 2010a (for conduct prior to December 6, 2019) and general 9, sections 20(a) and 1(a) (for conduct on or after December 6, 2019).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm entered an AWC under which it agreed to be censured and pay a $60,000 fine. The fine was paid in accordance with the terms of the AWC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":397},{"d":"2024-11-08","di":"2022-11-28","dr":"2024-11-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty and censure","st":"Final","fine":17500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22306","al":"The SEC alleged that Invesco Advisers, Inc. (\"IAI\") lacked comprehensive policies and procedures to determine the percentage of company-wide assets under management (\"AUM\") that was ESG integrated. The SEC also alleged that IAI made misleading statements concerning the company-wide percentage of AUM that was ESG integrated.","res":"Order","sd":"The settlement required Invesco Advisers, Inc. (\"IAI\") to pay a civil monetary penalty of $17.5 million. IAI paid the civil monetary penalty on November 14, 2024.","sm":"On November 8, 2024, Invesco Advisers, Inc. (\"IAI\") entered into a settlement with the SEC regarding IAI's environmental, social and governance (\"ESG\") policies and procedures. The SEC found that IAI lacked comprehensive policies and procedures to determine the percentage of company-wide assets under management (\"AUM\") that was ESG integrated. The SEC also found that IAI made misleading statements concerning the company-wide percentage of AUM that was ESG integrated. IAI was censured and ordered to cease and desist from violating sections 206(2) and 206(4) of the Advisers Act and rules 206(4)-1, 206(4)-7 and 206(4)-8 thereunder. IAI agreed to pay a penalty of $17.5 million. No information Filed","ab":"Invesco Advisers, Inc.","self":true,"firms":[104983,105360,107584,141854],"id":398},{"d":"2024-10-31","di":"2024-10-31","dr":"2024-10-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":45000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22278","al":"On October 31, 2024, J.P. Morgan Securities LLC (\"JPMS\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). JPMS consented to the entry of the order, which found that JPMS willfully violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 206(4)-7 thereunder. The order arose out of JPMS, from at least July 2017 until October 11, 2024, failing to fully and fairly disclose the financial incentive of itself and certain of its financial advisors to recommend a certain advisory program - the portfolio manager program - over other advisory programs offered by JPMS that use third-party managers. The order also found that JPMS failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with the disclosure of conflicts of interest presented by the fee structure of the advisory programs for itself and its financial advisors.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":399},{"d":"2024-10-31","di":"2024-10-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":10000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22280","al":"On October 31, 2024, J.P. Morgan Securities LLC (\"JPMS\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). JPMS consented to the entry of the order, which found that JPMS willfully violated sections 17(a)(2) and (3) of the Securities Act of 1933 (\"Securities Act\"). The order arose out of JPMS, from January 2019 through June 2022, using inaccurate disclosures with brokerage customers investing in certain products through a program which pooled customer money into a private fund (\"private fund\") and then invested in private equity or hedge funds (\"third-party fund\") that customers might not be able to access directly. The order found that JPMS did not disclose to the brokerage customers invested in the private funds that one of its affiliates would be exercising complete investment discretion over the timing of sales of certain shares of companies that had recently undertaken an initial public offering or another liquidity event and had been distributed by the third-party funds back to the private fund in which the brokerage customers were invested.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":400},{"d":"2024-10-31","di":"2024-10-31","dr":"2024-10-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure","st":"Final","dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22279","al":"On October 31, 2024, J.P. Morgan Securities LLC (\"JPMS\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). JPMS consented to the entry of the order, which found that JPMS willfully violated rule 15L-1(a) under the Securities Exchange Act of 1934 (the \"Exchange Act\"). The order finds that, from at least June 30, 2020 through July 14, 2022, JPMS, through its registered representatives, recommended certain mutual fund products to its retail brokerage customers when materially less expensive ETF products that offered the same investment portfolio to investors were also available on JPMS's platform for recommendation to these customers. The order further finds that, through this conduct, JPMS violated the care obligation of Regulation Best Interest (\"reg bi\") and that JPMS also violated reg bi's compliance obligation by failing to enforce its written policies and procedures reasonably designed to achieve compliance with reg bi's care obligation.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":401},{"d":"2024-10-30","di":"2024-10-30","dr":"2024-10-30","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000.0,"dk":"DQA-24-1536","al":"On October 30, 2024, CME Group market regulation (\"CME\") concluded its 2024 electronic trading recordkeeping examination of Goldman Sachs & Co. LLC (\"GSCO\") for trade dates April 1 through June 30, 2024. During the review, CME found issues concerning certain operator ids that were active and required to be registered in the exchange fee system but were not registered until after the review period, in violation of CME rule 576 (\"identification of globex terminal operators\"). GSCO registered the operator ids during the examination.","res":"Decision","sm":"CME imposed a $4,000 summary fine on gsco for failure to comply with CME rule 576. Gsco paid the fine on November 12, 2024.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":402},{"d":"2024-10-28","di":"2024-10-28","k":"Regulatory Action","dk":"24SEC145","ab":"Duckett, Stephen, Gregory","firms":[7691],"id":403},{"d":"2024-10-24","di":"2024-10-24","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"A former employee of another company that I own, which is not involved in the securities industry, pleaded guilty to orchestrating a ponzi scheme. See addabbo VS bossetti, no. 24 CV 008197. I was not charged in connection with the ponzi scheme by the prosecutors, and I cooperated with their investigation and provided them all relevant documentation. I have not been charged civilly by any regulator in connection with the ponzi scheme. Neither I nor my company received any funds from ponzi scheme investments, made any payments to investors in connection with the ponzi scheme, or received any commissions, compensation or other financial benefit from the ponzi scheme whatsoever. Nevertheless, we have been sued by investors in the ponzi scheme in two separate civil actions pending in Ohio state court. The allegations in those cases, generally speaking, are that my company and I are responsible for investment losses for various reasons, including negligent supervision and as a de- facto partnership. I have denied all liability in the matter, because I was not involved in the ponzi scheme.","ab":"Sekinger, Jeffrey, ronald","firms":[305225],"id":404},{"d":"2024-10-23","di":"2024-10-23","dr":"2024-10-23","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000000.0,"dk":"2024-CFPB-0011","al":"On October 23, 2024, Goldman Sachs Bank USA (\"GS bank\") entered into a consent order (the \"order\") with the Consumer Financial Protection Bureau (\"CFPB\") related to the administration of the apple card between 2019 and 2021. Specifically, the CFPB conducted an investigation of GS bank's handling of disputes and its offering of the interest-free purchase promotion known as apple card monthly installments (\"ACMI\"). In the order, the CFPB alleged that between December 2019 and approximately July 2020, GS bank made misleading representations about ACMI enrollment and, between December 2019 and approximately May 2021, misrepresented how refunds to consumers' ACMI and non-ACMI balances would be applied. In addition, the CFPB alleged that GS bank's handling of credit card transaction disputes between product launch in August 2019 and approximately December 2021 violated the truth in lending act and its implementing regulation z, and also involved unfair practices under the Consumer financial protection act of 2010.","res":"Consent","sm":"Without admitting or denying the allegations in the order, GS bank stipulated to the entry of the order and agreed to pay a $45 million civil money penalty to the CFPB, $19.8 million in redress to consumers with credit given for restitution GS bank already provided to affected consumers, to refrain from violating relevant statues and regulations, and to take certain other remedial measures, including creating and implementing a comprehensive compliance plan designed to ensure compliance with applicable laws.","ab":"Goldman Sachs Bank USA","firms":[361],"id":405},{"d":"2024-10-18","di":"2024-03-05","dr":"2024-10-18","k":"Regulatory Action","rg":"Other","reg":"Reserve Bank of India (Rbi)","san":"Cease and Desist","os":"Cease and desist, with immediate effect, from doing any form of financing against shares and debentures including sanction and disbursal","st":"Final","dk":"NOT APPLICABLE","al":"The principal allegations are: JMFPL allegedly facilitated IPO and NCD subscriptions using loaned funds with inadequate credit underwriting and very low margins. JMFPL operated customers' application processes, demat accounts, and bank accounts through powers of attorney (POAS), effectively acting as both lender and borrower, raising concerns about regulatory compliance and corporate governance.","res":"Other","sd":"Not applicable","sm":"Within the space provided). Rbi vide its order dated March 5, 2024 had directed JMFPL to cease and desist, from doing any form of financing against shares and debentures including sanction and disbursal of loan against initial public offering (IPO) of shares as well as against subscription to debentures, till a special audit instituted by rbi was completed. Post submission of response by JMFPL, rbi vide its letter dated October 18, 2024, lifted the restrictions imposed by it on JMFPL. However, as a corrective measure, JMFPL decided to discontinue its IPO business (matter closed).","ab":"JM Financial Products Limited","firms":[293667],"id":406},{"d":"2024-10-17","di":"2024-10-17","dr":"2024-10-17","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1250.0,"dk":"N/A","al":"Bloomberg SEF LLC (\"Bloomberg SEF\") alleged that on March 13, 2023, Verition Fund Management LLC (\"Verition Fund Management\") in executing offsetting and correcting trades on BSEF with another participant, violated BSEF rule 516.a(a) by failing to use functionality approved by BSEF when entering offsetting and correcting trades. Bloomberg SEF found the violation did not result in financial harm to customers.","res":"Decision","sd":"Without admitting or denying the allegations , Verition Fund Management agreed to a fine of $1,250, which was paid on 11/25/2024.","sm":"In its written decision dated 10/17/2024, BSEF imposed a fine in the amount of $1,250 for a violation of Bloomberg SEF rule 516. Without admitting or denying the allegations, Verition Fund Management agreed to a fine of $1,250, which was paid on 11/25/2024. No information Filed","ab":"Verition Fund Management LLC","self":true,"firms":[156610],"id":407},{"d":"2024-10-16","di":"2024-10-16","dr":"2024-10-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement and prejudgment interest.cease and desist order.","st":"Final","fine":100000.0,"dk":"3-22255","al":"The SEC alleged that between February 2019 and February 2021, the firm published quotes on a daily basis for between 4,300 and 6,500 different municipal bonds at above-market prices for a customer that was a sophisticated municipal market professional, without independently evaluating the fair market values of the bonds at the time it made the quotations. The SEC also alleged that on 204 occassions, the firm, acting in a principal capacity, facilitated the sales of the bonds attributable to the quotes without evaluating the prevailing market prices for the bonds. The SEC also alleged that on 51 occassions, the firm failed to report these transactions as \"away from the market trades. Based on the foregoing, the SEC alleged that the firm violated MSRB rules G-13, G-14, G-17, G-27 and G-30 and, as a result, section 15b(c)(1) of the Securities Exchange Act of 1934.","res":"Decision & Order of Offer of Settlement","sd":"The firm agreed to pay disgorgement of $11,369.00, prejudgment interest of $2,407.38, and a civil penalty of $100,000.00.","sm":"Without admitting or denying the SEC's findings, the firm submitted an offer of settlement which was accepted by the SEC, and which calls for a censure, cease and desist, civil monetary penalty of $100,000, and disgorgement of $11,369.00 (plus $2,407 in prejudgment interest).","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":408},{"d":"2024-10-14","di":"2024-08-22","dr":"2024-10-14","k":"Regulatory Action","rg":"Other","reg":"Korean Financial Services Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":16000.0,"al":"In October 2024 the Korean Financial Services Commission (\"FSC\") levied an administrative fine on Abrdn Investments Limited (\"AIL\") in connection with a single breach in January 2021 of the Korean financial investment services and capital markets act, specifically in relation to the provisions on short selling. AIL, acting as a discretionary investment manager, inadvertently executed a small number of shares of a Korean stock which the client account did not own at the time of the order. The FSC levied a fine of an equivalent of KRW 24m (circa £13,500). Abrdn's systems have been fully upgraded since 2021 to prevent re­ occurrence of an equivalent breach.","res":"Decision","sd":"Fine levied of KRW 30m (c.$20,000) reduced to KRW 24m for early payment. This was paid on 25 October 2024.","ab":"Abrdn Investments Limited","self":true,"firms":[162309],"id":409},{"d":"2024-10-10","di":"2024-10-10","dr":"2024-10-10","k":"Regulatory Action","rg":"Other","reg":"Indiana Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"23211-AG24-0425-075","al":"The enforcement division of the Indiana Department of Insurance alleged that Edward jones violated an insurance law and was liable for a civil penalty under Indiana code § 27­1­15.6­12(b)(2) in connection with the firm's failure to disclose its January 2024 consent agreement and order with the Pennsylvania department of banking and securities to the Indiana Department of Insurance in a timely manner.","res":"Consent","sm":"On March 20, 2024, the firm reported its January 2024 consent agreement with the Pennsylvania department of banking and securities (the \"Pennsylvania order\") to the Indiana Department of Insurance(the \"department\") and advised the department of its inadvertent omission of the Pennsylvania order in the firm's January 22, 2024 renewal application for its Indiana nonresident producer business entity license. Pursuant to Indiana code section 27-1-15.6-12(b)(2), the commissioner may levy a civil penalty on an insurance producer's license for violating an insurance law, including Indiana code section 27-1-15.6-17(a). Edward jones agreed to pay a civil penalty of $1,000.00.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":410},{"d":"2024-10-07","dr":"2024-10-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1400000.0,"dk":"NO. 2021070664101","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from October 2012 through March 2021, Citigroup Global Markets Inc. (\"the firm\") failed to collect initial and maintenance margin on over-the-counter equity option contracts it entered with two affiliated entities, resulting in violations of sections 7(c), 15(c)(3) and 17(a)(1) of the Securities Exchange Act of 1934 (\"Exchange Act\"), Exchange Act rules 15C3-1(c), 17A-3 and 17A-5, FINRA rules 4210, 4511 and 2010 and section 220.8 of regulation t of the Board of Governors of the Federal Reserve system.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings in the AWC, the firm agreed to be censured and pay a $1,400,000 fine. The fine will be paid in accordance with the terms of the AWC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":411},{"d":"2024-09-30","di":"2024-09-30","dr":"2024-09-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":2000000.0,"dk":"2019062983001","al":"The Financial Industry Regulatory Authority (FINRA) found that Merrill Lynch, Pierce, Fenner & Smith (the firm) failed to accurately report to the trade reporting and compliance engine (TRACE) certain customer transactions in TRACE-eligible securities from March 2010 to September 2020, in violation of FINRA rules 6730(a), (c), and (d) and 2010, over-reported certain municipal securities transactions for retail customers to the real-time transaction reporting system (RTRS) from September 2017 to February 2019, in violation of municipal securities rulemaking board (MSRB) rule G-14(b), and failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA rule 6730 and RTRS reporting, in violation of NASD rule 3010, FINRA rules 3110(a) and (b) and 2010, and MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to the imposition of a censure and a fine in the amount of $2,000,000 ($50,000 of which pertains to the violations of MSRB rules G-14 and G-27). The fine will be paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":412},{"d":"2024-09-30","di":"2024-09-30","dr":"2024-09-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and civil penalty","st":"Final","fine":1500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22219","al":"The order alleges that registrant's policies and procedures regarding the treatment of materially non-public information (\"MNPI\") were not reasonably designed to address risks related to the potential for receipt and misuse of MNPI resulting from participation on ad hoc creditors' committees. Although registrant maintained written policies and procedures regarding MNPI, the order alleges that registrant did not specifically maintain policies and procedures for registrant's employees to conduct due diligence concerning financial advisers' evaluation or handling of any potential MNPI resulting from an ad hoc creditors' committee, or for obtaining a representation from such advisers concerning their policies and procedures for handling MNPI. Pursuant to an offer of settlement, the commission found, and registrant neither admitted nor denied, that registrant violated sections 204a and 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","res":"Order","sd":"A civil money penalty in the amount of $1,500,000 was paid on October 11, 2024.","sm":"The registrant, without admitting or denying any findings except as to the commission's jurisdiction and the subject matter of the proceedings, consented to the entry of an order instituting administrative and cease and desist proceedings in settlement of an administrative proceeding. The order concluded the commission's inquiry into this matter. No information Filed","ab":"Marathon Asset Management, L.P.","self":true,"firms":[124613],"id":413},{"d":"2024-09-26","di":"2024-09-26","dr":"2024-09-26","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22208","al":"On September 26, 2024, GQG Partners LLC (\"GQG\"), entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\") that required GQG to pay a civil monetary penalty in the amount of $500,000. GQG consented to the entry of the order, without admitting or denying the findings therein, except as to jurisdiction, which found that GQG willfully violated rule 21F-17(a) under the Securities Exchange Act of 1934 (the \"Exchange Act\"). The order found that GQG, from November 2020 through September 2023, asked certain potential employees to sign a non- disclosure agreement (\"NDA\") that prohibited them from disclosing, including to government agencies specifically, that they had confidential information about GQG. While the NDA permitted them to respond to requests for information from the SEC, it required notification to GQG of any such request and prohibited them from responding to requests arising from their voluntary act of disclosure. The order also found that GQG entered into a release and settlement agreement with a former employee that required representations by the former employee that he/she (I) had not sought to initiate any investigation by any governmental agency; (II) was aware of no facts that would form the basis of such an investigation; and (III) would withdraw any statements already made that would form the basis of an investigation.","res":"Order","sd":"Fine of $500,000 paid by GQG Partners LLC on October 02, 2024.","sm":"The SEC entered an order on September 26, 2024. GQG has paid the civil money penalty in accordance with the terms of the order. No information Filed","ab":"GQG Partners LLC","self":true,"firms":[283720],"id":414},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":300000.0,"dk":"3-22185","al":"On September 25, 2024, The Goldman Sachs Group, inc. (\"GS group\") entered into an order instituting cease-and-desist proceedings with the U.S. Securities and Exchange Commission (\"SEC\"), which alleged GS group and relevant GS group affiliates failed to timely file section 16(a) reports with respect to certain issuers, including late-reported transactions executed from March 2018 to November 2021. Without admitting or denying the findings, GS group consented to the entry of the SEC's order to cease and desist from committing or causing any violations and any future violations of section 16(a) of the Securities Exchange Act of 1934 and rule 16A-3 and agreed to pay a civil monetary penalty in the amount of $300,000, which GS group paid on October 15, 2024.","res":"Order","ab":"The Goldman Sachs Group,","firms":[361],"id":415},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Censure","st":"Final","fine":1000000.0,"dk":"FILE NO. 3-22173","al":"The Securities and Exchange Commission (SEC) alleged that Merrill Lynch, Pierce, Fenner & Smith (MLPF&s), from March 2016 to April 2018, failed to adequately notify certain clients with which it had a fiduciary relationship of the clients' over-exposure to the harvest volatility management LLC's collateral yield enhancement strategy, an options overlay strategy for which harvest was the third party private investment manager and MLPFS the custodian. The order found that in doing so, MLPFS willfully breached its fiduciary duty under sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-7 thereunder to such fiduciary clients.","res":"Order","sm":"Without admitting or denying the findings, MLPF&s agreed to the imposition of a censure, cease and desist order, an order to pay disgorgement and prejudgment interest totaling $2,800,000, and a civil monetary penalty in the amount of $1,000,000. The fine was paid in accordance with the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":416},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","st":"Final","fine":1500000.0,"dk":"CFTC DOCKET NO. 24-31","al":"The Commodity Futures Trading Commission (\"CFTC\") entered into a settlement order (\"order\") with Merrill Lynch commodities, inc. (\"MLCI\") to settle an administrative action that found MLCI (a) held positions in certain fixed price futures contracts that violated federal spot-month position limits and did not otherwise meet the requirements for an exemption from the federal position limits pursuant to CFTC regulations, in violation of section 4a(b)(2) of the Commodity Exchange Act (\"CEA\") and CFTC regulation 150.2; (b) exceeded the ICE futures U.S.-set spot-month position limit in certain fixed price futures contracts and did not comply with the terms of an exemption that had been granted by ICE futures U.S., in violation of section 4a(e) of the CEA; and (c) did not establish and enforce written policies and procedures reasonably designed to monitor for and prevent violations of applicable federal, designated contract market, or swap execution facility position limits and to monitor for and prevent improper reliance upon any exemption or exclusions from such position limits, and thereby did not diligently supervise its employees, in violation of section 4s(h)(1)(b) and (c) of the CEA and CFTC regulations 23.601(a) and 23.602(a).","res":"Order","sm":"Mcli admitted to certain facts in the settlement order, acknowledged its conduct violated certain provisions of the cea and CFTC regulations and agreed to the following sanctions: (a) to cease and desist from violating sections 4a(b)(2) and (e) and 4s(h) (1)(b) and (c) of the cea and CFTC regulations 23.601(a), 23.602(a), and 150.2, (b) to pay a civil monetary penalty in the amount of $1,500,000, and (c) to comply with certain conditions and undertakings.","ab":"Merrill Lynch","firms":[7691],"id":417},{"d":"2024-09-25","di":"2023-07-24","dr":"2024-09-25","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Via to publish a written adverse publicity notice specified in the annexure to the orders; and maintain the prescribed","st":"Final","fine":8772000.0,"al":"On 25 July 2023, ASIC lodged civil penalty proceedings in the federal court of Australia against Vanguard Investments Australia LTD (VIA), alleging misrepresentations in relation to claims about certain environmental, social and governance (ESG) exclusionary screens applied to investments in the Vanguard ethically conscious global aggregate bond index and ETF. ASIC alleged that the description of the exclusionary screens in the product disclosure statements (PDS) did not provide a sufficiently detailed explanation that certain company debt issuers lacking ESG research coverage were included in the benchmark such that the fund and ETF had exposure to certain securities that may not have reasonably expected by investors. In addition, ancilliary statements made by VIA, in the form of a media release and two industry presentations, were alleged to not adequately disclose the limitations of the exclusionary screens applied to the products.","res":"Judgment Rendered","sd":"N/a","ab":"Vanguard Investments","firms":[105958],"id":418},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":375000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22179","al":"The SEC found that Oaktree Capital Management, L.P. failed to timely file required section 16(a) reports and failed to timely file schedule 13d and schedule 13g amendments and therefore violated and caused violations of sections 13(d) and 16(a) of the Securities Exchange Act of 1934 and rules 13D-2 and 16A-3 promulgated thereunder.","res":"Order","sd":"The order is final","sm":"On September 25, 2024, the SEC accepted Oaktree's offer to resolve an investigation involving sections 13(d) and 16(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rules 13D-2 and 16A-3 thereunder, which require certain investors, like Oaktree, that beneficially own the registered equity securities of a public company to file reports with the SEC of their beneficial ownership in the equity of the company, including changes in their beneficial ownership, within specified timeframes. Oaktree cooperated immediately and fully with the SEC's investigation, and, without admitting or denying the SEC's findings, in a settled proceeding agreed to cease and desist from committing or causing any violations and any future violations of sections 13(d) and 16(a) of the Exchange Act and rules 13D-2 and 16A-3 thereunder and to pay a $375,000 penalty. No information Filed","ab":"Oaktree Capital Management, L.P.","self":true,"firms":[106793],"id":419},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":200000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22190","al":"Fig LLC did not timely file two initial schedule 13d disclosures, one Form 3 disclosure, and one schedule 13d amendment disclosure.","res":"Decision & Order of Offer of Settlement","sd":"The order is final and the penalty was paid in full to the SEC on September 30, 2024.","sm":"On September 25, 2024, the SEC published an administrative order of settlement between it and Fig LLC (the \"order\") in which the firm neither admitted nor denied the findings related to the timeliness of three schedule 13d filings and one Form 3 filing. The firm consented to the entry of the settled administrative order finding violations of section 13(d)(1), 13(d)(2), and 16(a) of the Exchange Act and rules 13D-1, 13D-2, and 16A-3 thereunder, and was ordered to cease and desist from future violations of section 13(d)(1), 13(d)(2), and 16(a) of the Exchange Act and rules 13D-1, 13D-2, and 16A-3 thereunder and pay a civil monetary penalty of $200,000. No information Filed","ab":"Fig LLC","self":true,"firms":[129612],"id":420},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Penalty","st":"Final","fine":130000.0,"dk":"3-22189","al":"In relation to two equity ownership reports that were inadvertently filed late in 2020 and 2022, an affiliate of Bain Capital Credit, LP, in September 2024, voluntarily agreed, without admitting any wrongdoing, to pay a penalty as part of a settlement with the SEC. under section 13(d) of the Securities Exchange Act of 1934 and related rules, in effect during this time, any person who has acquired beneficial ownership of more than 5% of certain equity securities must file, within 10 days, a disclosure statement with the SEC. there is no state of mind requirement for section 13(d) reporting requirements. As the SEC found, in some private credit transactions, entities may not have knowledge of their precise holdings in an issuer until after a transaction closes, which in these instances affected the timely monitoring of changes to holdings of public securities. The SEC alleged that during the global COVID-19 pandemic, the affiliate's internal processes did not timely identify the need to make these ownership filings, and as a result, the affiliate inadvertently filed the schedule 13d reports for these transactions late. The SEC considered that the affiliate of Bain Capital Credit, LP took remedial steps and recognized its cooperation in the matter. The penalty was paid by the affiliate of Bain Capital Credit, LP and was not borne by any of its funds or investors in its funds.","res":"Decision & Order of Offer of Settlement","sd":"An affiliate of Bain Capital Credit, LP agreed to pay a $130,000 penalty. Bain Capital Credit, LP made the payment on September 27, 2024, and no fund or investor bore any portion of such payment in resolving the matter. In addition, the affiliate of Bain Capital Credit, LP was ordered to cease and desist from committing or causing any violations and any future violations of section 13(d)(1) of the Exchange Act and rule 13D-1 thereunder.","sm":"Order is final and the penalty has been paid in full. No information Filed","ab":"Bain Capital Credit","firms":[134852],"id":421},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil money penalty","st":"Final","fine":225000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22177","al":"The SEC found that registrant failed to timely file on behalf of a reporting group of registrant's affiliated entities and private funds certain beneficial ownership forms and reports required under sections 13 and 16 of the Securities Exchange Act of 1934.","res":"Settled","sd":"Civil money penalty in the amount of $225,000 paid by registrant on 09/26/2024.","sm":"On September 25, 2024, the SEC issued an order in which it found that Essex Woodlands Management, Inc. failed to (1) file on a timely basis multiple required section 16(a) reports of holdings and transactions in the securities of one issuer on behalf of a reporting group of Essex Woodlands Management, Inc.'s affiliated entities and private funds that shared direct or indirect beneficial ownership of more than 10% of that issuer's registered class of common stock and (2) timely file an initial statement and certain amendments required under section 13(d) with respect to beneficial ownership in the issuer. Essex Woodlands Management, Inc. promptly undertook a number of remedial efforts, which the SEC considered in determining to accept Essex Woodlands Management, Inc.'s offer of settlement. Without admitting or denying the SEC's findings, Essex Woodlands Management, Inc. consented to the entry of the SEC's order that it cease and desist from committing or causing any violations and any future violations of sections 13(d) and 16(a) of the Securities Exchange Act of 1934 and rules 13D-1, 13D-2, and 16A-3 promulgated thereunder and paid a civil money penalty of $225,000. No information Filed","ab":"Essex Woodlands Management, Inc.","self":true,"firms":[158263],"id":422},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil monetary penalty","st":"Final","fine":200000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22175","al":"In August 2024, the Securities and Exchange Commission alleged that Adage Capital Management, L.P. (\"ACM\") failed to make on a timely basis certain filings under section 13 and section 16 of the Securities Exchange Act of 1934, with respect to holdings of Adage capital partners, L.P., a private fund managed by ACM","res":"Consent","sd":"Civil monetary penalty in the amount of $200,000, which amount has been paid in full by acm.","sm":"Without admitting or denying the findings, acm consented to the entry of an order by the SEC and paid a civil penalty of $200,000. No information Filed","ab":"Adage Capital Management, L.P.","self":true,"firms":[160679],"id":423},{"d":"2024-09-25","di":"2024-09-25","dr":"2024-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":300000.0,"dk":"3-22185","al":"On September 25, 2024, the Goldman Sachs groups, inc. (\"GS group\") entered into an order instituting cease and desist proceedings with The Securities and Exchange Commission (the \"SEC\" and the order, the \"SEC order\"), which alleged that GS group and certain of its affiliates failed to timely file reports on forms 3 and 4 in accordance with section 16(a) of the Securities Exchange Act 1934, as amended, and rule 16A-3 thereunder.","res":"Order","sd":"Pursuant to the SEC order, the SEC required GS group to pay a civil money penalty in the amount of $300,000. GS group paid the penalty on 10/15/2024.","sm":"GS group paid a civil money penalty in the amount of $300,000 to the SEC on 10/15/2024.","ab":"The Goldman Sachs Group,","firms":[283221,286067],"id":424},{"d":"2024-09-24","di":"2024-09-24","dr":"2024-09-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":35000000.0,"dk":"3-22168","al":"The Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against Stifel, Nicolaus & Company, inc. (\"Stifel\" or \"respondent\"). In anticipation of the institution of these proceedings, respondent has submitted an offer of settlement that the commission has determined to accept. The commission finds that from at least January 2020 (the \"relevant period\"), Stifel personnel sent and received off-channel communications that related to its broker-dealer business. Additionally, during the relevant period, Stifel personnel sent and received off-channel communications related to the investment adviser's receipt, disbursement or delivery of funds or securities. Stifel did not maintain or preserve the substantial majority of these written communications. Stifel's failure was firm-wide and involved personnel at various levels of authority. Stifel's supervisors, who were responsible for supervising junior personnel, routinely communicated off-channel using their personal devices. In fact, senior personnel responsible for supervising junior personnel themselves failed to comply with Stifel's policies and procedures by communicating, through non-approved methods, on their personal devices about respondent's business. Stifel's widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its personnel within the meaning of section 15(b)(4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act. During the relevant period, Stifel received and responded to commission subpoenas for documents and records requests in various commission investigations. As a result, Stifel's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. The commission staff uncovered Stifel's misconduct after commencing a risk based initiative to investigate the use of off-channel and unpreserved communications at broker dealers and registered investment advisers. Stifel has initiated a review of its recordkeeping failures and begun a program of remediation. As set forth in the undertakings below, Stifel will retain an independent compliance consultant to review and assess Stifel's remedial steps relating to its recordkeeping practices, policies and procedures, related supervisory practices, and employment actions. As a result, Stifel willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and willfully violated section 204 of the Advisers Act and rule 204-2(a) (7) thereunder. Stifel failed reasonably to supervise its personnel with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act.","res":"Order","sm":"As a result, Stifel willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and willfully violated section 204 of the Advisers Act and rule 204-2(a)(7) thereunder. Stifel failed reasonably to supervise its personnel with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act. Accordingly, it is hereby ordered that Stifel shall cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder and section 204 of the Advisers Act and rule 204-2 thereunder, is censured, shall comply with the undertakings enumerated in the order, and shall pay a civil money penalty of $35,000,000. The civil money penalty was paid on October 4TH, 2024.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":425},{"d":"2024-09-24","di":"2023-05-15","dr":"2024-09-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty/fine, censure, and undertakings","st":"Final","fine":35000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22165","al":"The SEC alleged that Invesco Advisers, Inc. (\"IAI\") and Invesco Distributors, Inc. (\"IDI\") failed to adequately preserve certain electronic communications pursuant to applicable recordkeeping provisions of federal securities law.","res":"Order","sd":"The settlement required Invesco Advisers, Inc. (\"IAI\") and Invesco Distributors, Inc. (\"IDI\") pay a civil monetary penalty of $35 million and comply with certain undertakings, including the retention of a compliance consultant. Invesco paid the civil monetary penalty on October 1, 2024.","sm":"On September 24, 2024, Invesco Advisers, Inc. (\"IAI\"), an investment advisory affiliate of Oppenheimerfunds, inc. and Invesco Distributors, Inc. (\"IDI\"), an affiliated broker-dealer (together, with IAI, \"Invesco\") have entered into a settlement with the U.S. securities & exchange commission (SEC) in connection with the agency's industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement censures Invesco and requires that Invesco cease and desist from any existing and future violations, pay a civil monetary penalty of $35,000,000 and retain an independent compliance consultant, following the format for all other recent electronic communications settlements. Invesco cooperated with the government's inquiry and has already taken significant steps to further strengthen the firm's compliance environment as it relates to electronic communications, including by enhancing its policies and procedures, implementing increased training regarding the use of electronic communications, and beginning to implement changes to the technology available to employees.","ab":"Invesco Advisers, Inc.; Invesco Distributors, Inc.","firms":[104983,107584,141854],"id":426},{"d":"2024-09-24","di":"2023-05-15","dr":"2024-09-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty/fine, censure and undertakings","st":"Final","fine":35000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22165","al":"The SEC alleged that Invesco Advisers, Inc. (\"IAI\") and Invesco Distributors, Inc. (\"IDI\"), an affiliated broker-dealer of IAI, failed to adequately preserve certain electronic communications pursuant to applicable recordkeeping provisions of federal securities law.","res":"Order","sd":"The settlement required Invesco Advisers, Inc. (\"IAI\") and Invesco Distributors, Inc. (\"IDI\"), an affiliated broker-dealer of IAI, pay a civil monetary penalty of $35 million and comply with certain undertakings, including the retention of a compliance consultant. Invesco paid the civil monetary penalty on October 1, 2024.","sm":"On September 24, 2024, Invesco Advisers, Inc. (\"IAI\") and Invesco Distributors, Inc. (\"IDI\") (together, with IAI, \"Invesco\") have entered into a settlement with the U.S. securities & exchange commission (\"SEC\") in connection with the agency's industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement censures Invesco and requires that Invesco cease and desist from any existing and future violations, pay a civil monetary penalty of $35,000,000 and retain an independent compliance consultant, following the format for all other recent electronic communications settlements. Invesco cooperated with the government's inquiry and has already taken significant steps to further strengthen the firm's compliance environment as it relates to electronic communications, including by enhancing its policies and procedures, implementing increased training regarding the use of electronic communications, and beginning to implement changes to the technology available to employees.","ab":"Invesco Distributors, Inc.","firms":[105360],"id":427},{"d":"2024-09-24","di":"2024-09-24","dr":"2024-09-24","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Monetary fine: $1.25 million","st":"Final","fine":1250000.0,"dk":"24-29","al":"On September 24, 2024, the Commodity Futures Trading Commission (\"CFTC\") announced a settlement with Canadian Imperial Bank of commerce (\"CIBC\") for failing to timely report swap transactions to a registered swap data repository as required by the commodity Exchange Act (CEA) and CFTC regulations sections 2(a)(13)(f) and (g) of the commodity Exchange Act (\"act\"), 7 U.S.C. §§ 2(a)(13)(f), (g), and current commission regulations (\"regulations\") 43.3(a), 45.3(b)(1), and 45.4(c), 17 C.F.R. §§ 43.3(a), 45.3(b) (1),45.4(c) (2023), as well as former commission regulations 43.3(a), 43.4(a), 45.3(b) and 45.4, 17 C.F.R. §§ 43.3(a), 43.4(a), 45.3(b), 45.4 (2020).","res":"Consent","sd":"CIBC and its successors and assigns shall cease and desist from violating the applicable sections CFTC regulations and CIBC shall pay a civil monetary penalty in the amount of usd$1,250,000 within fourteen days of the date of the entry of this order.","sm":"CIBC has submitted an OFFER of settlement (\"OFFER\"), which the commission has determined to accept, and admits the facts set forth in section II below, acknowledges that its conduct violated the act and regulations and consents to the entry of this order instituting proceedings pursuant to section 6(c) and (d) of the commodity Exchange Act, making findings, and imposing remedial sanctions (\"order\"), and acknowledges service of the order.","ab":"Canadian Imperial Bank of","firms":[106508],"id":428},{"d":"2024-09-24","di":"2024-09-24","dr":"2024-09-24","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"As part of the settlement, CIBC has undertaken to conduct a comprehensive review and assessment of CIBC's remediation","st":"Final","fine":30000000.0,"dk":"24-28","al":"The Commodity Futures Trading Commission (\"commission\") has reason to believe that from at least September 2018 to the present (\"relevant period\"), Canadian Imperial Bank of commerce (\"CIBC\") violated, as set forth below, sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the commodity Exchange Act (\"act\"), 7 U.S.C. §§ 6s(f)(1)(c), 6s(g)(1), (3), 6s(h)(1)(b), and commission regulations (\"regulations\") 1.31, 23.201(a),23.202(a)(1) and (b)(1), and 23.602(a), 17 C.F.R. §§ 1.31, 23.201(a), 23.202(a)(1), (b) (1), and 23.602(a) (2023).","res":"Consent","sd":"Monetary fine of 30 million","sm":"During the relevant period, as a result of the widespread employee use of unapproved communication methods, CIBC failed to maintain commission-required transaction records and pre-execution communications. By this conduct, CIBC violated sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the act and regulations 23.201(a) and 23.202(a)(1) and (b)(1). By failing to keep all commission- required records in such a manner as to make them \"readily accessible,\" CIBC violated regulation 1.31. CIBC failed to supervise its swap dealer business activities diligently during the relevant period. CIBC failed to maintain an adequate supervisory system to ensure that employees did not utilize unapproved methods to engage in communications relating to firm business, including the swap dealer business. CIBC's failure to supervise is demonstrated by its failure to detect, prevent, and remediate repeated violations of the commission's recordkeeping requirements and firm policies and procedures. Supervisory personnel failed to ensure that employees complied with CIBC's commission recordkeeping obligations and firm communications policies and in some instances, themselves violated the policies. These supervision failures also resulted in the failure to keep and maintain commission-required records and the failure to maintain the records in such a manner as to make them readily available. By this conduct, CIBC failed to supervise diligently its officers, employees, and agents, in violation of section 4s(h)(1)(b) of the act and regulation 23.602(a). No information Filed","ab":"Canadian Imperial Bank of","firms":[106508],"id":429},{"d":"2024-09-24","di":"2024-09-24","dr":"2024-09-24","k":"Regulatory Action","rg":"Other","reg":"U.S. Securities & Exchange Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":2000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-22164","al":"In September 2024, Glazer capital entered a settlement with the SEC and consented to the entry of an order (the \"order\") finding that Glazer capital did not adhere to applicable recordkeeping provisions of the federal securities laws by failing to maintain and preserve certain off-channel communications, and that its failure to implement its policies and procedures that prohibited these off-channel communications was a failure to reasonably supervise its personnel. The violations fell under section 203(e) (6) of the Advisers Act, section 204 of the Advisers Act, and rule 204-2(a)(7) thereunder. The order required Glazer capital to cease and desist from committing or causing future violations, censured Glazer capital, and required Glazer capital to pay a civil monetary penalty. Glazer capital paid the civil monetary penalty on September 26, 2024, no portion of which was borne by Glazer capital's clients.","res":"Decision & Order of Offer of Settlement","sd":"Glazer capital, LLC paid a civil monetary penalty in the amount of $2,000,000 on September 26, 2024.","ab":"Glazer Capital, LLC.","self":true,"firms":[136932],"id":430},{"d":"2024-09-23","di":"2024-09-23","dr":"2024-09-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":215000.0,"dk":"2023078116101","al":"The Financial Industry Regulatory Authority (FINRA) alleged that between July 2022 and December 2022, Merrill Lynch, Pierce, Fenner & Smith (MLPFS) and bofa securities, inc. (BOFAS) failed to timely file amendments for their registered representatives' uniform applications for securities industry registration (forms U4) to update the representatives' outside business activities and to reflect changes in the representatives' business addresses, in violation of article v, section 2(c) of FINRA's by-laws and FINRA rules 1122 and 2010, and failed to establish and maintain a supervisory system reasonably designed to ensure the timely filing of Form U4 amendments, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPFS agreed to the imposition of a censure and a fine in the amount of $215,000. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":431},{"d":"2024-09-20","di":"2024-09-20","dr":"2024-09-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"ADMIN. PROCEEDING FILE NO. 3-22147","al":"See response to item 13 below.","res":"Settled","sd":"The full $150,000 civil money penalty was paid by the adviser on September 24, 2024.","sm":"On September 20, 2024, Jordan/Zalaznick Advisers, Inc. (\"JZAI\") agreed to the payment of a civil penalty of $150,000 in settlement of findings by the SEC of certain deficiencies in the implementation of JZAI's compliance policies and procedures. To effectuate the settlement, JZAI consented to the entry of an administrative and cease-and-desist order (the \"settlement order\") containing findings by the SEC that JZAI did not admit or deny. According to the settlement order, the SEC found that, between December 2018 and May 2022, JZAI did not sufficiently perform certain activities contemplated by JZAI's policies and procedures. In addition to the monetary penalty, the settlement order included findings of violations of sections 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder, a cease-and desist provision, and a censure. No information Filed","ab":"Jordan/Zalaznick Advisers, Inc.","self":true,"firms":[160932],"id":432},{"d":"2024-09-19","di":"2024-09-19","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Administrative fine engagement of independent compliance consultant","st":"Final","fine":300000.0,"dk":"3-22145","al":"The SEC alleged that Inspire misrepresented its research process, did not apply its investment criteria consistently, invested in companies that should have been excluded based on Inspire's stated investment criteria, and had a research process that failed to prevent departures from its stated investment criteria. The SEC further alleged that Inspire also failed to adopt reasonably designed policies and procedures related to its investment process.","res":"Consent","sd":"Respondent Inspire was ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Advisers Act and rules 206(4)-1, 206(4)- 7, and 206(4)-8 thereunder, and section 34(b) of the Investment Company Act. Inspire was also censured and ordered to pay to the Securities and Exchange Commission, a civil money penalty in the amount of $300,000 within ten (10) days of the entry of the order.","sm":"Inspire timely made the required payment, has timely engaged an independent compliance consultant not unacceptable to the SEC, and is working through the process set forth in the order. No information Filed","ab":"Inspire Investing, LLC","self":true,"firms":[171988],"id":433},{"d":"2024-09-17","di":"2024-09-17","dr":"2024-09-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement, prejudgment, civil money penalty","st":"Final","fine":57615.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO 3-22132","al":"This regulatory action is related to Gates Capital Management, Inc.'s violation of rule 105 of Regulation M under the securities and Exchange Act of 1934. Rule 105 generally prohibits buying an equity security in an underwritten secondary public offering if the buyer sold short the same security during the restricted period specified in rule 105. Gates Capital Management, Inc. identified and self-reported the rule 105 violation.","res":"Settled","sd":"Gates Capital Management, Inc. paid disgorgement of $432,564 (the amount of gains made by its client in connection with the applicable transaction), prejudgment interest of $5,445, and a civil money penalty of $57,615, for a total of $495,624 on September 18, 2024. Gates Capital Management, Inc. was also ordered to cease and desist from committing or causing any violations and any future violations of rule 105 of Regulation M under the securities and Exchange Act of 1934.","sm":"Gates Capital Management, Inc. entered into an offer of settlement with The Securities and Exchange Commission to resolve the matter, without admitting or denying the findings therein, and the order was filed as a settled regulatory proceeding. No information Filed","ab":"Gates Capital Management, Inc.","self":true,"firms":[137842],"id":434},{"d":"2024-09-17","di":"2024-01-19","dr":"2024-09-17","k":"Regulatory Action","rg":"Other","reg":"U.S. Securities & Exchange Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":725000.0,"dk":"NO. 3-22138","al":"On 9/17/2024, the SEC settled administrative proceedings against Nepc in connection with its failure to make Form 13f filings from the quarter ending 12/31/2019 to 9/30/2023. Nepc also identified a potential issue relating to the timely filing of Form 13h and self-reported the issue to the SEC. Nepc agreed to cease and desist from committing or causing any violations of sections 13(f)(1) and 13(h) under the Securities Exchange Act of 1934, as amended. Nepc paid the fine of $725,000. The SEC did not order a penalty relating to Form 13h in recognition of Nepc's self-report. Nepc immediately corrected its filings policies and became current with all 13f and 13h filings, prior to the final date of settlement.","res":"Decision & Order of Offer of Settlement","sd":"$725,000 was paid on 9/25/2024.","ab":"Nepc, LLC","firms":[145186],"id":435},{"d":"2024-09-12","di":"2024-09-12","dr":"2024-09-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Disgorgement","os":"Fine; censure; restitution; and applicable interest","st":"Final","fine":400000.0,"dk":"2019061442702","al":"FINRA raised concerns with WFCS regarding the adequacy of the firm's supervision of short-term trading in three securities which FINRA views as products generally intended to be held for the long term, namely: syndicate preferred stocks; syndicate closed end funds; and medium-term notes.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm voluntarily reached a settlement with FINRA regarding FINRA concerns related to the adequacy of the firm's supervision of short-term trading in three securities: syndicate preferred stocks; syndicate closed end funds; and medium-term notes. The settlement acknowledged the firm's supervisory system enhancements and provided for a firm censure, a fine of $400,000, a disgorgement payment to FINRA in the amount of $2,031,972.10 plus applicable interest, and customer restitution in the amount of $599,025.29, plus applicable interest.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":436},{"d":"2024-09-09","di":"2024-09-09","dr":"2024-09-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":190000.0,"dk":"2021069334401","al":"JPMS consented to sanctions and to entry of findings that (1) from October 2020 through January 2022, the firm permitted 10 individuals in the firm's U.S. investment and corporate banking group (ICB) to perform investment banking activities requiring registration during periods when they were not registered with FINRA, in violation of FINRA rules 1210 and 2010; and (2) during the same period, the firm's supervisory system was not reasonably designed to achieve compliance with FINRA registration requirements, in violation of FINRA rules 3110(a) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the letter of acceptance, waiver, and consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":437},{"d":"2024-09-09","di":"2024-09-09","dr":"2024-09-09","k":"Regulatory Action","rg":"Other","reg":"Korean Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3870.0,"dk":"N/A","al":"Allegation that on November 22, 2021, LMR Partners Limited short sold shares of a Korean-listed issuer, which it did not own.","res":"Order","sm":"13.on September 9, 2024, the Korean Securities and Futures Commission imposed an administrative penalty of approximately $3,870 on LMR Partners Limited ( \"LMR HK\") in connection with a trade executed by LMR HK on November 22, 2021, which inadvertently resulted in an uncovered short position in the securities of an issuer listed on the korea exchange. The short position was the result of a manual operational error, which was quickly remediated and the position covered.","ab":"LMR Partners Limited","self":true,"firms":[282637],"id":438},{"d":"2024-09-06","di":"2021-04-29","dr":"2024-09-06","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"See below","st":"On appeal","al":"The private investor of a Samsung a club yield plus GEN2 qualified investment-type private placement investment NO.3 alledged that the firm has violated the fiduciary duty by neglected to inform the investment risk.","res":"Other","sd":"See below","ab":"Samsung Hedge Asset","firms":[158319],"id":439},{"d":"2024-09-05","di":"2024-09-05","dr":"2024-09-05","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, undertaking","st":"Final","fine":2000000.0,"dk":"E-2023-0034","al":"The Massachusetts Securities Division (MSD) alleged that Morgan Stanley Smith Barney LLC (the \"firm\") (1) did not have a specific process for review of trades by insiders of FDIC-regulated institutions, and (2) failed to conduct a reasonable post-trade review of certain transactions by a firm client, and (3) that a firm employee engaged in business-related communications using an unapproved method of communication in violation of section 204(a)(2)(j) of the Massachusetts uniform Securities Act (the \"act\").","res":"Order","sm":"On September 5, 2024, the firm became the subject of a consent order issued by the MSD regarding allegations that the firm (1) did not have a specific process for review of trades by insiders of FDIC-regulated institutions and (2) failed to conduct a reasonable post-trade review of certain transactions by a firm client, and (3) that a firm employee engaged in business-related communications using an unapproved method of communication in violation of section 204(a)(2)(j) of the act. Without admitting or denying the statement of facts and the violations of law and without adjudication of any issue of law or fact, the firm consented to (1) the entry of the order, (2) a cease-and-desist order, (3) the imposition of a censure, (4) certain undertakings, and (5) payment of an administrative fine in the amount of $2,000,000. The administrative fine will be paid in accordance with the terms of the order.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":440},{"d":"2024-09-04","di":"2024-09-04","dr":"2024-09-04","k":"Regulatory Action","rg":"Other","reg":"Fsma (Belgium)","san":"Other","os":"No sanction - transactional agreement","st":"Final","al":"The belgian financial services and markets authority (Fsma) considered that, during the period from 4 April to 31 May 2023, Belfius Bank committed several infringements in connection with the public offering of deposit certificates. There was no question of intentional wrongdoing. As soon as the head of legal informed olivier onclin (member of the management board, responsible for PBR) and johan vankelecom (CFO responsible for legal at that time) of the situation, the kasbon / bon de caisse offer was immediately stopped and the management board implemented different actions to remedy and to prevent it in the future. A settlement between the Fsma and Belfius Bank has been concluded on 4 September 2024. The settlement consists of the payment of 1 million euro, Belfius Bank's commitment to reinforce its legal risk management by appointing a new member of the management board with solid legal background. From January 1, 2025 and as long as the above mentioned strengthening has not taken place, Belfius has taken the commitment to set up an executive committee comprising at least one member with a solid legal background to assist and advice the management board on the implementation of Belfius' strategy and policy. Belfius Bank also agreed for this settlement to be published, including disclosure of names, on the Fsma's website.","res":"Settled","sd":"No sanction - transactional agreement","ab":"Belfius Bank","firms":[173355,340676],"id":441},{"d":"2024-09-03","di":"2024-09-03","dr":"2024-09-03","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Censure","st":"Final","fine":333000.0,"dk":"NO. 20170550870-04","al":"CBOE Byx Exchange, Inc. (BYX) alleged that Bofa Securities, Inc. (BOFAS), from September 2018 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 to present, failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to detect and prevent potentially manipulative trading, in violation of BYX rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of exchange rules were committed, bofas and MLPFS consented to the imposition of a censure and a fine in the amount of $333,000. The fine was paid in accordance with the terms of the letter of consent. The letter of consent was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, the Nasdaq stock market LLC, NYSE ARCA, inc., CBOE edga exchange, inc., CBOE BZX exchange, inc., CBOE edgx exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":442},{"d":"2024-09-03","di":"2024-09-03","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","san":"Censure","st":"Final","fine":333000.0,"dk":"NO. 20170550870-06","al":"CBOE Edga Exchange, Inc. (EDGA) alleged that Bofa Securities, Inc. (BOFAS), from September 2018 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 to June 2019, failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to detect and prevent potentially manipulative trading, in violation of EDGA rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of exchange rules were committed, bofas and MLPFS consented to the imposition of a censure and a fine in the amount of $333,000. The fine was paid in accordance with the terms of the letter of consent. The letter of consent was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, the Nasdaq stock market LLC, NYSE ARCA, inc., CBOE edgx exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":443},{"d":"2024-09-03","di":"2024-09-03","dr":"2024-09-03","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Censure","st":"Final","fine":333000.0,"dk":"NO. 20170550870-07","al":"CBOE Edgx Exchange, Inc. (EDGX) alleged that Bofa Securities, Inc. (BOFAS), from September 2018 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 to June 2019, failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to detect and prevent potentially manipulative trading, in violation of EDGX rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of exchange rules were committed, bofas and MLPFS consented to the imposition of a censure and a fine in the amount of $333,000. The fine was paid in accordance with the terms of the letter of consent. The letter of consent was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, the Nasdaq stock market LLC, NYSE ARCA, inc., CBOE edga exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":444},{"d":"2024-09-03","di":"2024-09-03","dr":"2024-09-03","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Censure","st":"Final","fine":333000.0,"dk":"NO. 2017055087005","al":"CBOE BZX Exchange, Inc. (BZX) alleged that Bofa Securities, Inc. (BOFAS), from September 2018 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 to present, failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to detect and prevent potentially manipulative trading, in violation of BZX rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of exchange rules were committed, bofas and MLPFS consented to the imposition of a censure and a fine in the amount of $333,000. The fine was paid in accordance with the terms of the letter of consent. The letter of consent was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, the Nasdaq stock market LLC, NYSE ARCA, inc., CBOE edga exchange, inc., CBOE byx exchange, inc., CBOE edgx exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":445},{"d":"2024-09-02","di":"2023-11-22","dr":"2024-09-02","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 48-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from September 2023 through October 2023, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 149 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2024, DB AG received a decision from fse issued on July 22, 2024 finding that, from September 2023 through October 2023, DB AG failed to convert 149 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":446},{"d":"2024-09-02","di":"2023-10-04","dr":"2024-09-02","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 36-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from July 2023 through August 2023, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 175 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2024, DB AG received a decision from fse issued on July 22, 2024 finding that, from July 2023 through August 2023, DB AG failed to convert 175 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":447},{"d":"2024-09-02","di":"2023-03-22","dr":"2024-09-02","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 12-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from November 2022 through December 2022, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 339 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2024, DB AG received a decision from fse issued on July 13, 2024 finding that, from November 2022 through December 2022, DB AG failed to convert 339 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":448},{"d":"2024-09-02","di":"2023-06-14","dr":"2024-09-02","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 23-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from March 2023 through April 2023, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 353 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2024, DB AG received a decision from fse issued on July 12, 2024 finding that, from March 2023 through April 2023, DB AG failed to convert 353 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":449},{"d":"2024-09-02","di":"2023-05-24","dr":"2024-09-02","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 19-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from January 2023 through February 2023, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 389 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2024, DB AG received a decision from fse issued on July 9, 2024 finding that, from January 2023 through February 2023, DB AG failed to convert 389 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":450},{"d":"2024-08-29","di":"2024-08-29","dr":"2024-08-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":525000.0,"dk":"2018059564801","al":"Without admitting or denying the findings, the firms consented to the sanctions and to the entry of findings that they have failed to reasonably supervise the firms' reporting, and timely reporting, of customer complaints via FINRA rule 4530 filings and amendments to registered representatives' forms U4 and US. The findings also stated that the firms falled to reasonably supervise at least 4.7 million mutual fund purchases made directly with mutual fund companies on behalf of firm customers. The firms inadvertently employed a data filter that blocked over a million purchases that were made pursuant to periodic investment plans from being ingested into its automated surveillance system. Upon discovering the data filter, the firms deactivated it. In addition, the firms failed to review through its automated surveillance system over a million direct business transactions that registered representatives failed to timely match to a firm account. The firms conducted a comprehensive retrospective review of direct business transactions that they failed to supervise and determined that customers incurred approximately $111,724 in excessive sales charges and commissions in connection with these transactions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $525,000, ordered to pay $26,169.04, plus interest, in restitution to eligible customers, and certify that they have remediated the issues identified in the AWC.","ab":"Raymond James Financial","firms":[705],"id":451},{"d":"2024-08-29","di":"2024-08-29","dr":"2024-08-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":1825000.0,"dk":"2018059564801","al":"Entered into a letter of acceptance, waiver, and consent (AWC) with FINRA for not reasonably supervising the firm's reporting, including timeliness of reporting, of customer complaints via FINRA rule 4530 filings and amendments to registered representatives' forms U4 and U5 since at least January 2018. Additionally, from January 2012 to at least December 2017, the firm, which self-reported the issue, did not reasonably supervise mutual fund purchases that the firms' representatives made directly with mutual fund companies on behalf of firm customers; such transactions in many cases happened outside the firm's automated surveillance systems which were not configured to subject them to review. The firm and FINRA conducted retrospective reviews of the direct business identified and the firm agreed to the entry of findings and sanctions, including a censure, fine, and restitution.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firms were censured, fined in the amount of $525,000 (RJA) and $1,300,000 (RJFS), and required to pay restitution in the amount of $26,169.04 plus interest (RJA) and $85,554.94 plus interest RJFS. Further, within 180 days of the date of the notice of acceptance of this AWC, a member of each respondent's senior management who is a registered principal of each firm shall certify in writing that, as of the date of the certification, the firms have remediated the customer complaint and direct business system configuration issues identified in this AWC and implemented a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with article v, sections 2 and 3 of FINRA's by-laws, and FINRA rules 3110, 1122, and 4530 regarding the issues identified in this AWC.","sm":"Please see numbers 7 through 12 for a summary of the matter and resolution. No information Filed","ab":"Raymond James Financial","firms":[149018],"id":452},{"d":"2024-08-28","di":"2024-08-28","dr":"2024-08-28","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Censure","st":"Final","fine":333000.0,"dk":"NO. 2017055087008","al":"NYSE ARCA, Inc. (ARCA) alleged that Bofa Securities, Inc. (BOFAS), from July 2019 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 to July 2019, failed to establish, maintain, and enforce a supervisory system and written supervisory procedures reasonably designed to detect and prevent potentially manipulative trading by customers of BOFAS and MLPFS, in violation of NYSE ARCA rules 11.18(b) and (c) (supervision).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, bofas and MLPFS consented to the imposition of a censure, a fine in the amount of $333,000, and certain undertakings. The fine was paid in accordance with the terms of the AWC. The AWC was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, the Nasdaq stock market LLC, CBOE edga exchange, inc., CBOE edgx exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":453},{"d":"2024-08-28","di":"2024-08-28","dr":"2024-08-28","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC","san":"Censure","os":"Undertaking","st":"Final","fine":333000.0,"dk":"NO. 2017055087002","al":"The Nasdaq Stock Market LLC (NASDAQ) alleged that Bofa Securities, Inc. (BOFAS), from 2019 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 through present, failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to detect and prevent potentially manipulative trading by customers of BOFAS and MLPFS, in violation of NASDAQ rules general 9, section 20(a) and its predecessor, NASDAQ rule 3010, and NASDAQ rule general 9, section 1(a) and its predecessor, NASDAQ rule 2010a..","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, bofas and MLPFS consented to the imposition of a censure, a fine in the amount of $333,000, and certain undertakings. The fine was paid in accordance with the terms of the AWC. The AWC was part of a total settlement bofas and MLPFS reached with the Financial Industry Regulatory Authority, NYSE ARCA, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":454},{"d":"2024-08-28","di":"2024-08-28","dr":"2024-08-28","k":"Regulatory Action","rg":"Other","reg":"Investors Exchange LLC","san":"Censure","os":"Undertaking","st":"Final","fine":333000.0,"dk":"NO. 2017055087001","al":"The Investors Exchange LLC (IEX) alleged that Bofa Securities, Inc. (BOFAS), from 2019 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from August 2016 through present, failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to detect and prevent potentially manipulative trading by customers of BOFAS and MLPFS, in violation of IEX rules 5.110 and 3.110.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, bofas and MLPFS consented to the imposition of a censure, a fine in the amount of $333,000, and certain undertakings. The fine was paid in accordance with the terms of the AWC. The AWC was part of a total settlement bofas and MLPFS reached with NYSE ARCA, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and the Nasdaq stock market LLC, and the Financial Industry Regulatory Authority.","ab":"Bofa Securities, Inc.","firms":[7691],"id":455},{"d":"2024-08-28","di":"2024-08-28","dr":"2024-08-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Undertaking","st":"Final","fine":669000.0,"dk":"NO. 2017055087003","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Bofa Securities, Inc. (BOFAS), from 2019 to present, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS), from December 2015 through present, failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to detect and prevent potentially manipulative trading by customers of BOFAS and MLPFS, in violation of FINRA rules 3110(a), 3110(b), and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, bofas and MLPFS consented to the imposition of a censure, a fine in the amount of $669,000, and certain undertakings. The fine was paid in accordance with the terms of the AWC. The AWC was part of a total settlement bofas and MLPFS reached with the Nasdaq stock exchange LLC, NYSE ARCA, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., CBOE byx exchange, inc., CBOE BZX exchange, inc., and investors exchange LLC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":456},{"d":"2024-08-22","di":"2024-08-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana Securities Commissioner","san":"Cease and Desist","st":"Pending","dk":"24-0013 CD","al":"On August 22, 2024, the Indiana securities commissioner (the \"commissioner\") issued a cease and desist order (the \"order\") against BlackRock, Inc. and several of its advisory affiliates, (collectively, \"BlackRock\"). The order alleges that BlackRock has made misleading statements about how we manage our non-ESG and ESG funds. With respect to non-ESG funds, the order cites to our participation in climate organizations and our statements regarding ESG integration and stewardship activities, among other things, as evidence that our non-ESG funds actually pursue an ESG strategy. With respect to ESG funds, the order asserts that BlackRock falsely claims that sustainable investing will generate better returns. The order finds that this activity violates Indiana's securities law and directs BlackRock to cease engaging in the referenced activities.","ab":"BlackRock Capital; BlackRock Financial Management,; BlackRock, Inc.","firms":[106614,107105,282125,290336],"id":457},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, monetary fine, undertaking","st":"Final","fine":40000000.0,"dk":"ADMIN. PRO. FILE NO. 3-22009","al":"On August 14, 2024, the U.S. Securities and Exchange Commission (\"SEC\") issued a settled administrative order in which it found that BNY Mellon Securities Corporation (\"BNYMSC\") and Pershing LLC (\"Pershing\") willfully violated section 17(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rule 17A-4(b) thereunder. The order also found that BNYMSC and Pershing failed to reasonably supervise their employees within the meaning of Exchange Act section 15(b)(4)(e). Specifically, the order found that from at least January 2020 to the date of the order, BNYMSC and Pershing personnel sent and received text message communications on platforms that were not approved for business purposes, many of which were not preserved by BNYMSC or Pershing. In numerous instances, BNYMSC and Pershing supervisors themselves communicated using these unapproved communication platforms. In determining to accept BNYMSC's and Pershing's offers of settlement, the SEC considered remedial acts promptly undertaken by BNYMSC and Pershing and cooperation afforded the commission staff.","res":"Decision & Order of Offer of Settlement","sd":"Bnymsc and Pershing were (I) censured; (II) ordered to cease and desist from committing or causing any violations and any future violations of Exchange Act section 17(a) and rule 17A-4 thereunder; (III) ordered to pay a penalty of $40 million; and (IV) ordered to comply with certain undertakings, including the retention of an independent compliance consultant to review their policies and procedures related to electronic communications.","sm":"Provided). Bnymsc and Pershing consented to entry of the order and admitted the facts alleged in the order and acknowledged that their conduct violated the federal securities laws. The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12.","ab":"BNY Mellon Securities Corporation; Pershing LLC","self":true,"firms":[231],"id":458},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure and undertakings","st":"Final","fine":50000000.0,"dk":"FILE NO. 3-22001","al":"The U.S. Securities and Exchange Commission (\"SEC\"), in connection with an industry-wide investigation, alleged Edward jones violated recordkeeping provisions of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and section 204 of the Investment Advisers Act of 1940 (\"Advisers Act\") and supervisory provisions of section 15(b)(4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act, and applicable rules thereunder, in connection with retention of electronic communications stored on personal devices or messaging platforms that have not been approved by Edward jones for business use by its employees.","res":"Decision & Order of Offer of Settlement","sm":"On August 14, 2024, Edward jones entered into a settlement with the SEC, to resolve the matter. Prior to the settlement, Edward jones fully cooperated with the SEC's investigation and enhanced its policies and procedures concerning the use of approved communication methods. The settlement imposes a cease-and-desist order and censure, requires Edward jones to pay a civil monetary penalty of $50 million, and requires Edward jones to comply with undertakings including retention of an independent compliance consultant to assess the firm's policies and systems regarding electronic communications recordkeeping and assist Edward jones in further enhancing those policies and systems.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":459},{"d":"2024-08-14","di":"2024-08-09","dr":"2024-08-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"FILE NO. URE-257-06","al":"On August 14, 2024, CBOE Byx Exchange, Inc. (\"CBOE byx\" or the \"exchange\") accepted a letter of consent (\"LOC\") submitted by Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), in which gsco neither admitted nor denied the violations but consented to the sanctions. In connection with a December 15, 2022 order, CBOE byx found that gsco failed to implement reasonably designed pre- order controls to prevent erroneously priced limit orders from being entered on the exchange. As a result, the exchange determined that gsco violated SEC rule 15C3-5 and byx rule 3.2.","res":"Consent","sm":"Pursuant to the loc, gsco was censured and agreed to pay a monetary fine of $7,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":460},{"d":"2024-08-14","di":"2024-08-09","dr":"2024-08-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"FILE NO. URE-257-07","al":"On August 14, 2024, CBOE Edgx Exchange, Inc. (\"CBOE edgx\" or the \"exchange\") accepted a letter of consent (\"LOC\") submitted by Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), in which gsco neither admitted nor denied the violations but consented to the sanctions. In connection with a December 15, 2022 order, CBOE edgx found that gsco failed to implement reasonably designed pre-order controls to prevent erroneously priced limit orders from being entered on the exchange. As a result, the exchange determined that gsco violated SEC rule 15C3-5 and edgx rule 3.2.","res":"Consent","sm":"Pursuant to the loc, gsco was censured and agreed to pay a monetary fine of $7,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":461},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":50000000.0,"dk":"3-22002","al":"The Securities and Exchange Commission (\"SEC\") entered a settled administrative order in connection with its off-channel communications initiative, finding that Raymond James & Associates, Inc. (\"Raymond james\") failed to (1) maintain and preserve off- channel communications related to Raymond james's broker-dealer business, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder, as well as communications related to, among other things, recommendations made or proposed to be made and advice given or proposed to be given with respect to Raymond james's investment advisory business, in willful violation of section 204 of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 204-2(a)(7) thereunder; and (2) reasonably supervise its personnel with a view to preventing or detecting certain of its employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder; and within the meaning of section 15(b)(4)(e) of the Exchange Act, and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act.","res":"Order","sd":"Raymond James & Associates, Inc. admitted to the facts in the settlement order, acknowledged its conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17a thereunder and section 204 of the Advisers Act and rule 204-2 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $50,000,000, which was paid in full and timely on August 26, 2024, and (d) comply with certain undertakings related to the retention of electronic communications, including retention of an independent compliance consultant.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":462},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":50000000.0,"dk":"3-22006","al":"The Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against LPL Financial LLC (\"LPL\" or \"respondent\"). In anticipation of the institutionof these proceedings, respondent has submitted an OFFER of settlement (\"OFFER\") that the commission has determined to accept. The commission finds that from at least June 2019 (the\"relevant period\"), LPL personnel sent and received off-channel communications that were records required to be maintained under Exchange Act rule 17A-4(b)(4) and/or advisers actrule 204-2(a)(7). Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failures were firm-wide, including financial advisors who, together with other personnel they supervised, were responsible for generating some of the highest levels of revenue for LPL during a time period within the relevant period. LPL'SWIDESPREAD failure to implement a system reasonably expected to determine whether personnel were following its policies and procedures that prohibit off-channel communications led to its failure to reasonably supervise its personnel. During the relevant period, LPL received and responded to commission subpoenas for documents and/or records requests in a number of commission investigations. As a result, LPL's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff found LPL's misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at investment advisers. LPL has initiated a review of its recordkeeping failures and begun a program of remediation. As a result of its conduct, the firm willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder; failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons'aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act.","res":"Order","sm":"As a result of its conduct, the firm willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7)there under; failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act. Accordingly, it is hereby ordered that the firm cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder and section 204 of the Advisers Act and rule 204-2 thereunder; is censured; shall comply with the undertakings enumerated in the order; and shall pay a civil money penalty in the amount of $50,000,000 to the SEC. the firm paid the fine in full on 08/27/2024.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":463},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":45000000.0,"dk":"3-22003","al":"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 Markets, LLC (RBC or respondent). In anticipation of the institution of these proceedings, respondent has submitted an offer of settlement that the commission has determined to accept. The commission finds that from at least June 2019 (the relevant period), RBC personnel sent and received off-channel communications that were records required to be maintained under Exchange Act rule 17A-4(b)(4) and/or Advisers Act rule 204- 2(a)(7). Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failures were firm-wide and involved personnel at various levels of authority throughout the organization. RBC's widespread failure to implement a system reasonably expected to determine whether personnel were following its policies and procedures that prohibit off-channel communications led to its failure to reasonably supervise its personnel within the meaning of section 15(b) (4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act. During the relevant period, RBC received and responded to commission subpoenas for documents and/or records requests in a number of commission investigations. As a result, RBC's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff found RBC's misconduct after commencing a risk- based initiative to investigate the use of off-channel and unpreserved communications at investment advisers. RBC has initiated a review of its recordkeeping failures and begun a program of remediation. As a result of its conduct, RBC willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder.","res":"Order","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":464},{"d":"2024-08-14","di":"2024-08-14","dr":"2024-08-14","k":"Regulatory Action","rg":"Other","reg":"U.S. Securities & Exchange Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure.","st":"Final","fine":1250000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21999","al":"On August 14, 2024, psam entered into a settlement with the SEC and consented to the entry of an order finding that from October 18, 2018 through December 21, 2021 psam violated section 204 of the Advisers Act and rule 204-2(a)(7) thereunder by failing to maintain or preserve certain off-channel communications. The order further found that psam failed to implement a system of monitoring reasonably expected to determine whether personnel were following its policies and procedures that prohibit off-channel communications which led to its failure to reasonably supervise its personnel within the meaning of section 203(e)(6) of the Advisers Act. The order stated that the SEC considered psam's cooperation with the SEC staff in the investigation and the remedial steps psam had undertaken, including the initiation of implementation of technological improvements to enhance the firm's capability to preserve its employees' electronic communications, the retention and continued use of a compliance consultant tasked with remediating its recordkeeping deficiencies, and the conducting of ongoing monitoring for potential non-compliance with firm policies. The order required psam to cease and desist from committing or causing any violations and any future violations of section 204 of the Advisers Act and rule 204-2 thereunder, censured psam, and required psam to pay a civil monetary penalty of $1,250,000. No portion of the penalty will be borne by psam's clients.","res":"Decision & Order of Offer of Settlement","sd":"Psam paid a civil monetary penalty in the amount of $1,250,000 on August 26, 2024.","ab":"P. Schoenfeld Asset Management LP","self":true,"firms":[149236],"id":465},{"d":"2024-08-13","di":"2024-08-09","dr":"2024-08-13","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":2000.0,"dk":"FILE NO. 84787","al":"The Minnesota Department of Commerce alleged that Edward jones violated minn. R. 2876.5021 subp. 1 when it received notice of a uniform commercial code collateral lien on a customer account and gave thecustomer an incorrect total of her assets subject to the lien and did not timely provide the customerwith her collateral-free account balance.","res":"Consent","sm":"On August 13, Edward jones entered into a civil penalty agreement with the Minnesota Department of Commerce to resolve this matter. Pursuant to the civil penalty agreement, the firm agreed to pay a civil penalty of $2,000 and to cease and desist from violating any laws, rules, or orders related to the duties and responsibilities entrusted to the commissioner of the Minnesota Department of Commerce. The firm paid the penalty on August 19, 2024.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":466},{"d":"2024-08-13","di":"2024-08-13","dr":"2024-08-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":400000.0,"dk":"2021069319401","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that from May 2018 through July 2022: the firm (1) provided written trade confirmations to non-institutional customers that did not disclose at all the firm's mark-ups and mark-downs for certain municipal securities and corporate debt transactions and did not disclose the time of execution, and/or a security-specific url for certain fixed price, primary market transactions involving municipal securities and certain primary market transactions involving corporate or agency debt securities, in violation of MSRB rule G-15 and FINRA rules 2232 and 2010; and (2) failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPS), reasonably designed to achieve compliance with MSRB G-15 and FINRA rule 2232, in violation of MSRB rule G-27 and FINRA rules 3110(a) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 13, 2024, the firm became subject to a letter of acceptance, waiver and consent issued by FINRA regarding allegations that from May 2018 through July 2022: the firm (1) provided written trade confirmations to non-institutional customers that did not disclose at all the firm's mark-ups and mark-downs for certain municipal securities and corporate debt transactions and did not disclose the time of execution, and/or a security-specific url for certain fixed price, primary market transactions involving municipal securities and certain primary market transactions involving corporate or agency debt securities, in violation of MSRB rule G-15 and FINRA rules 2232 and 2010; and (2) failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPS), reasonably designed to achieve compliance with MSRB G-15 and FINRA rule 2232, in violation of MSRB rule G-27 and FINRA rules 3110(a) and 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and fine in the amount of $400,000. The firm will pay the fine in accordance with the terms of the AWC.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":467},{"d":"2024-08-01","di":"2023-02-24","dr":"2024-08-01","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 6-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from September 2022 through October 2022, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 238 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On August 1, 2024, DB AG received a decision from fse issued on June 24, 2024 finding that, from September 2022 through October 2022, DB AG failed to convert 238 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The fse closed the proceeding without any sanctions, but required DB AG to pay a fee for the proceeding of eur 1,000 (approximately usd 1,100), which will be timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":468},{"d":"2024-07-31","di":"2022-11-15","dr":"2024-07-31","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"NA","st":"Final","fine":11933.0,"dk":"ORDER/NH/RJ/2024-25/30635-30641","al":"JM Financial Trustee Company private limited (\"JMFTCPL\") was alleged to have violated the provisions of clause 2 of fifth schedule to the sebi (mutual funds) regulations, 1996","res":"Order","sd":"Sebi imposed a monetary penalty of inr 10,00,000/- (approximately equivalent to usd 11,933/-) on JMFTCPL as per section 15HB of the sebi act, 1992 which has been paid by JMFTCPL on September 4, 2024","sm":"Within the space provided). Sebi issued a show-cause notice dated November 15, 2022 to JMFTCPL in respect of transactions executed by certain employees of JM Financial asset management limited in the schemes of JM Financial mutual fund, which was responded to by JMFTCPL. JMFTCPL is the trustee to the schemes of JM Financial mutual fund. Post the submissions of JMFTCPL, sebi issued an order on July 31, 2024 imposing a penalty of inr 10,00,000/- (approximately equivalent to usd 11,933/-) on JMFTCPL as per section 15HB of sebi act, 1992 for failing to comply with clause 2 of fifth schedule to sebi (mutual funds) regulations, 1996. The above penalty was paid by JMFTCPL on September 4, 2024. (Matter closed)","ab":"JM Financial Trustee Company","firms":[293667],"id":469},{"d":"2024-07-31","di":"2022-11-15","dr":"2024-07-31","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"NA","st":"Final","fine":29831.0,"dk":"ORDER/NH/RJ/2024-25/30635-30641","al":"JM Financial Asset management limited (\"JMFAML\") was alleged to have acted in contravention of the sebi circular dated November 17, 2016 and violated the provisions of clause 2 of fifth schedule to the sebi (mutual funds) regulations, 1996.","res":"Order","sd":"Sebi imposed a monetary penalty of inr 25,00,000/- (approximately equivalent to usd 29,831/-) on jmfaml as per section 15e of sebi act, 1992 which has been paid by jmfaml on September 4, 2024.","sm":"Within the space provided). Sebi issued a show-cause notice dated November 15, 2022 to jmfaml in respect of transactions executed by certain employees of jmfaml in the schemes of JM Financial mutual fund, which was responded to by jmfaml. Post the submissions of jmfaml, sebi issued an order on July 31, 2024 imposing a penalty of inr 25,00,000/- (approximately equivalent to usd 29,831/-) on jmfaml as per section 15e of sebi act, 1992 for failing to comply with the provisions of sebi circular dated November 17, 2016 and clause 2 of fifth schedule to sebi (mutual funds) regulations, 1996. The above penalty was paid by jmfaml on September 4, 2024. (Matter closed)","ab":"JM Financial Asset","firms":[293667],"id":470},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc. (Edgx)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3225.0,"dk":"2020067957711","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to establish that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and edgx rule 11.8(c), in violation of rule 611(c) of regulation NMS and edgx rules 3.2 and 11.8(c), and (2) between September 2019 and July 2021, JPMS' supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 611(c) of regulation NMS and edgx rule 11.8(c), in violation of edgx rule 5.1.","res":"Consent","sm":"The allegations, dispositions, findings and sanctions of the letter of consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":471},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc. (Edga)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3200.0,"dk":"2020067957708","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to establish that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and edga rule 11.8(c), in violation of rule 611(c) of regulation NMS and edga rules 3.2 and 11.8(c), and (2) between September 2019 and July 2021, JPMS' supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 611(c) of regulation NMS and edga rule 11.8(c), in violation of edga rule 5.1.","res":"Consent","sm":"The allegations, dispositions, findings and sanctions of the letter of consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":472},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC (American)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":8090.0,"dk":"2020067957704","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and NYSE american rule 7.31e(e)(3), in violation of rule 611(c) of regulation NMS and american rule 7.31e(e)(3), and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with rule 611(c) of regulation NMS and american rule 7.31e(e)(3), in violation of american rules 3110(a) and (b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":473},{"d":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc. (ARCA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3090.0,"dk":"20200679577-03","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and NYSE ARCA rule 7.31-e(e)(3), in violation of rule 611(c) of regulation NMS and ARCA rule 7.31-e(e)(3), and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to ensure compliance with rule 611(c) of regulation NMS and ARCA rule 7.31-e(e)(3), in violation of ARCA rules 11.18(b) and (c).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":474},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE National, Inc. (National)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":6590.0,"dk":"2020067957706","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and NYSE national rule 7.31(e)(3), in violation of rule 611(c) of regulation NMS and national rule 7.31(e)(3), and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system, including its written supervisory procedures, reasonably designed to achieve compliance with rule 611(c) of regulation NMS and national rule 7.31(e) (3), in violation of national rules 11.3.2 and 11.5.1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":475},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC (NYSE)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":36100.0,"dk":"2020067957707","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and NYSE rule 7.31(e)(3), in violation of rule 611(c) of regulation NMS and NYSE rule 7.31(e)(3), and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with rule 611(c) of regulation NMS and NYSE rule 7.31(e)(3), in violation of NYSE rules 3110(a) and (b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":476},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE National, Inc. (National)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3090.0,"dk":"20200679577-05","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS did not take reasonable steps to establish that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS, in violation of rule 611(c) of regulation NMS and chicago rule 7.31(e)(3), and (2) between September 2019 and July 2021, JPMS' supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 611(c) of regulation NMS and chicago rule 7.31(e)(3), in violation of chicago article 6, rules 5(a) and 5(c).","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":477},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":18090.0,"dk":"2020067957701","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirement set forth in rule 600(b)(31) of regulation NMS, in violation of rule 611(c) of regulation NMS and FINRA rule 2010, and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with rule 611(c) of regulation NMS, in violation of FINRA rules 3110(a), 3110(b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":478},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"Other","reg":"Investors Exchange LLC (Iex)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":6090.0,"dk":"2020067957702","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to ensure that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS, in violation of rule 611(c) of regulation NMS and iex rules 11.190(b)(12) and 3.120, and (2) between September 2019 and July 2021, JPMS failed to establish and maintain a supervisory system including written procedures, reasonably designed to achieve compliance with rule 611(c) of regulation NMS, in violation of iex rules 5.110(a) and 5.110(b)(1).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":479},{"d":"2024-07-30","di":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc. (Byx)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":9000.0,"dk":"2020067957710","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to establish that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and byx rule 11.9(d), in violation of rule 611(c) of regulation NMS and byx rules 3.2 and 11.9(d), and (2) between September 2019 and July 2021, JPMS' supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 611(c) of regulation NMS and byx rule 11.9(d), in violation of byx rule 5.1.","res":"Consent","sm":"The allegations, dispositions, findings and sanctions of the letter of consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":480},{"d":"2024-07-30","dr":"2024-07-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3435.0,"dk":"2020067957709","al":"JPMS consented to sanctions and to entry of findings that (1) between September 2019 and May 2021, JPMS failed to take reasonable steps to establish that the intermarket sweep orders it routed met the requirements set forth in rule 600(b)(31) of regulation NMS and BZX rule 11.9(d), in violation of rule 611(c) of regulation NMS and BZX rules 3.2 and 11.9(d), and (2) between September 2019 and July 2021, JPMS' supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 611(c) of regulation NMS and BZX rule 11.9(d), in violation of BZX rule 5.1.","res":"Consent","sm":"The allegations, dispositions, findings and sanctions of the letter of consent are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":481},{"d":"2024-07-25","di":"2023-11-06","dr":"2024-07-25","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (Sebi).","san":"Other","os":"Monetary fine","st":"Final","fine":5962.61,"al":"Sebi issued a SCN dated nov 06, 2023 under section 15-I(3) of sebi act, 1992 calling upon amin to show cause as to why the ao order dated aug 23, 2023 should not be revised under section 15-I(3) of sebi act, 1992.","res":"Order","sm":"Amin acquired the entire share capital of l&t investment management limited (\"l&t amc\"), the asset management company of erstwhile l&t mutual fund, on 25 November 2022 and l&t amc was subsequently merged with amin. Pursuant to the sebi inspection of l&t amc for the period 01 April 2019 to 31 March 2021, sebi had issued show cause notice (SCN) dated 20 March 2023 & supplementary SCN dated June 16, 2023 alleging l&t amc of not complying with sebi circular no. MFD/cir/6/73/2000 dated 27 July 2000, regulation 25(2) and clause 9 of fifth schedule-part a of sebi (mutual funds) regulations, 1996. Adjudicating officer (AO) of sebi vide its order dated 23 August 2023, had disposed of the said SCNS without imposing any penalty. Subsequently, sebi issued a SCN dated 06 nov 2023 under section 15-I(3) of sebi act, 1992 calling upon amin to show cause as to why the AO order dated 23 aug 2023 should not be revised under section 15-I(3) of sebi act, 1992. Amin has responded to the SCN on 22 December 2023. A personal hearing on the matter was held on 28 February 2024. Sebi vide its order dated 25 July 2024 imposed a penalty of inr 5 lakhs on amin. Amin paid the penalty to sebi on 1 August 2024.","ab":"HSBC Asset Management (India) Private Limited","self":true,"firms":[324468],"id":482},{"d":"2024-07-23","di":"2024-07-23","dr":"2024-07-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"2022074617402","al":"FINRA alleged that Janney did not accurately report certain transactions to the municipal securities rulemaking board (\"MSRB\") from July 2019 to May 2021; and trade reporting and compliance engine (\"TRACE\") from March 2022 to March 2023. FINRA also alleged that Janney did not have proper supervisory systems and written supervisory procedures regarding such trade reporting.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm agreed to a $150,000 settlement.","sm":"On July 23, 2024, Janney entered into an AWC with FINRA, without admitting or denying any findings, the firm agreed to a $150,000 settlement with respect to the allegations and updated applicable written supervisory procedures.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":483},{"d":"2024-07-18","di":"2023-01-24","dr":"2024-07-18","k":"Regulatory Action","rg":"Other","reg":"Bourse de Montreal Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Costs","st":"Final","fine":100477.8,"dk":"FILE NO. EN-DC-23002","al":"The Bourse de Montreal Inc. (\"Bourse\") alleged that Citigroup Global Markets Inc. systematically failed to report the positions in options on futures contracts that exceeded the prescribed reporting threshold and failed to establish and maintain a system to supervise the activities of each employee that is reasonably designed to achieve compliance with the requirements of article 6.500 of the Bourse rules.","res":"Decision","sm":"In connection with the decision, Citigroup Global Markets Inc. (\"CGMI\") consented to a fine in the amount of cad 138,000 (approximately usd 100,477.80) and costs in the amount of cad 10,600 (approximately usd 7,717.86).","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":484},{"d":"2024-07-18","di":"2024-07-18","dr":"2024-07-18","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"NYMEX 23-1708-BC","al":"The New York Mercantile Exchange (\"NYMEX\") business conduct COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") (1) submitted inaccurate large trader position reports to the exchange, failed to provide the exchange with large trader corrections; and failed to submit position change data to the clearing house in a timely manner in violation of NYMEX rules 561 and 811; (2) submitted an open interest adjustment representing a decrease greater than two percent of open interest in violation of NYMEX rule 854.b; and (3) submitted adjustments to re-open positions in certain futures in violation of NYMEX rule 854.c","res":"Other","sm":"Without admitting or denying the findings, the firm agreed to a settlement under which it paid a $35,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":485},{"d":"2024-07-18","di":"2024-07-18","dr":"2024-07-18","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"CME 23-1708-BC","al":"The Chicago Mercantile Exchange Inc. (\"CME\") business conduct COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") (1) submitted inaccurate large trader position reports to the exchange, failed to provide the exchange with large trader corrections; and failed to submit position change data to the clearing house in a timely manner in violation of CME rules 561 and 811; and (2) submitted adjustments to re-open positions in certain futures and options in violation of CME rule 854.c..","res":"Other","sm":"Without admitting or denying the findings, the firm agreed to a settlement under which it paid a $30,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":486},{"d":"2024-07-18","di":"2024-07-18","dr":"2024-07-18","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"CBOT 23-1708-BC","al":"The Chicago Board of Trade (\"CBOT\") business conduct COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") (1) submitted inaccurate large trader position reports to the exchange, failed to provide the exchange with large trader corrections; and failed to submit position change data to the clearing house in a timely manner in violation of CBOT rules 561 and 811; and (2) submitted adjustments to re-open positions in certain futures and options in violation of CBOT rule 854.c.","res":"Other","sm":"Without admitting or denying the findings, the firm agreed to a settlement under which it paid a $30,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":487},{"d":"2024-07-18","di":"2024-07-18","dr":"2024-07-18","k":"Regulatory Action","rg":"Other","reg":"Commodity Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"COMEX 23-1708-BC","al":"The Commodity Exchange (\"COMEX\") business conduct COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") (1) submitted inaccurate large trader position reports to the exchange, failed to provide the exchange with large trader corrections; and failed to submit position change data to the clearing house in a timely manner in violation of COMEX rules 561 and 811; (2) submitted an open interest adjustment representing a decrease greater than two percent of open interest in violation of COMEX rule 854.b; and (3) submitted adjustments to re-open positions in certain futures in violation of COMEX rule 854.c.","res":"Other","sm":"Without admitting or denying the findings, the firm agreed to a settlement under which it paid a $35,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":488},{"d":"2024-07-12","di":"2023-06-06","dr":"2024-07-12","k":"Regulatory Action","rg":"Other","reg":"ComisiÓN Nacional Bancaria Y de Valores (\"CNBV\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":164000.0,"dk":"211-2B/28101798-AGCC/2023","al":"Failure to comply with certain regulations applicable to the management of mutual funds and the provision of investment advisory services in BlackRock's mexico city office","res":"Decision","sd":"Payment of fine approximately $164,000 (MNX $2,957,150)","sm":"On July 12, 2024, the ComisiÓN Nacional Bancaria Y de Valores (\"CNBV\") imposed a fine of approximately $164,000 (MNX $2,957,150) regarding the firm's compliance with certain regulations applicable to the management of mutual funds and the provision of investment advisory services in BlackRock's mexico city office. Specifically, the CNBV found that the registrations of 4 BlackRock sales representatives were associated with incorrect BlackRock entities and that BlackRock Mexico's public website did not give notice to users when users were redirected to third party websites. Payment of fine was submitted to the CNBV on August 2, 2024.","ab":"BlackRock Mexico; BlackRock Mexico Operadora, S.A. de","firms":[106614,107105,290336],"id":489},{"d":"2024-07-10","di":"2024-07-10","k":"Regulatory Action","dk":"NA","ab":"Canup, Leanna, Vallie","firms":[7691],"id":490},{"d":"2024-07-09","di":"2023-08-07","dr":"2024-07-09","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 31-2023","al":"The Frankfurt stock exchange (\"FSE\") found that, from May 2023 through June 2023, Deutsche bank AG, Frankfurt am main (\"DB AG\") failed to convert 169 short codes into long codes as required by section 114 para 3 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On July 9, 2024, DB AG received a decision from fse finding that, from May 2023 through June 2023, DB AG failed to convert 169 short codes into long codes as required by section 114 para 3 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014. The decision did not impose a fine or other monetary sanction.","ab":"Deutsche Bank AG (DB AG)","firms":[300838],"id":491},{"d":"2024-07-04","di":"2024-07-04","dr":"2024-07-04","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (BAFIN)","os":"N/a","st":"Final","dk":"GZ: BIIKO 2-WP 5505/00017#00002","al":"The German federal financial supervisory authority (\"BAFIN\") determined that the consolidated financial statements of Deutsche bank AG (\"DBAG\") for FY2019 misapplied the international financial reporting standards (\"IFRS\") - international accounting standards (\"IAS\") relating to specifics of the disclosure of deferred tax assets.","res":"Order","sm":"On July 4, 2024, dbag received a decision from BAFIN dated June 28, 2024, determining that the consolidated financial statements of dbag for FY2019 misapplied the ifrs - ias relating to specifics of the disclosure of deferred tax assets. The decision did not impose a fine or sanction against dbag.","ab":"Deutsche Bank AG (DB AG)","firms":[300838],"id":492},{"d":"2024-07-02","di":"2024-07-02","dr":"2024-07-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":75000.0,"dk":"2019063914601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies. The findings stated that the firm's oversightof discounts available through rights of reinstatement relied on an automated alert that was set to identify transactions in which a customer liquidates a position in a fund family and then purchases back into the same family at a later date. The alert was not designed to, and did not, capture all transactions eligible for reinstatement privileges. The firm also, at times, failed to reasonably review alerts that did trigger to ensure that eligible customers were credited with reinstatement privileges. As result, eligible customers paid $264,939.44 inexcess sales charges and fees.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":493},{"d":"2024-07-01","di":"2024-07-01","dr":"2024-07-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Restitution","st":"Final","dk":"2020067795501","al":"The Financial Industry Regulatory Authority (FINRA) found that Merrill Lynch, Pierce, Fenner & Smith (the firm), in connection with brokerage transactions involving certain products eligible for advisory fee waivers, failed to establish and maintain a supervisory system and written procedures reasonably designed to ensure that its registered representatives had a reasonable basis to believe their recommendations were suitable or in each customer's best interest between January 2018 and June 2022, in violation of FINRA rules 3110 and 2010; and failed to comply with the compliance obligation of Regulation Best Interest between June 30, 2020 and June 30, 2022, in violation of rule 15L-1(a)(1) under the Securities Exchange Act of 1934.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to pay restitution to affected customers totaling $1,486,380, plus interest. The firm will make these payments in accordance with terms of the AWC. FINRA also recognized the firm's extraordinary cooperation in connection with the matter.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":494},{"d":"2024-06-27","di":"2024-06-27","dr":"2024-06-27","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"24E121","al":"The state alleged 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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Kansas and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Kansas customers in an amount of no less than $47,189.70. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of K.A.R. 81-3-7(a)(4) and k.s.a 17-12A412(d)(9).","ab":"Raymond James Financial","firms":[705],"id":495},{"d":"2024-06-26","di":"2024-06-26","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Other","os":"No sanctions have been ordered as the matter is pending.","st":"Pending","al":"Sebi claims the adviser and mark Kingdon colluded in a scheme devised to use advance knowledge of non-public information regarding the existence, timing and overall nature of a report that hindenburg research LLC published to allegedly enable adviser clients to build a short position in the futures of adani enterprises limited (\"AEL\") and share in profits resulting from lowering of AEL share prices owing to publication of the report, which report was purportedly designed to lower AEL stock prices. This, sebi claims, qualifies as an unfair trade practice under indian law. The sebi notice notes that the adviser \"took confirmation from legal counsel that it could 'enter into a research services agreement with a third-party that publicly releases short reports on companies, pursuant to which [the adviser] would be given a draft copy of the report before it is made publicly available and would have the opportunity to accordingly make investments before the report's public dissemination.\"","sm":"The adviser received a show cause notice on June 27, 2024, which notice was dated June 26, 2024. The adviser's indian counsel replied to the show cause notice on May 14, 2025 and is working with sebi to set a date for the hearing. No information Filed","ab":"Kingdon, Mark, Elliot","firms":[157509],"id":496},{"d":"2024-06-25","di":"2024-04-24","dr":"2024-06-25","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland (Eurex)","san":"Reprimand","st":"Final","dk":"M 2024/06","al":"Eurex deutschland (\"Eurex\") found that, in November 2023, Deutsche Bank AG, frankfurt am main (\"DB AG\") failed to convert 16 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On June 25, 2024, DB AG received a decision dated June 10, 2024 from Eurex finding that, in November 2023, DB AG failed to convert 16 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014, and issuing a reprimand to DB AG, but not imposing a fine or other monetary sanction.","ab":"Deutsche Bank AG","firms":[300838],"id":497},{"d":"2024-06-20","di":"2024-06-20","dr":"2024-06-20","k":"Regulatory Action","rg":"Other","reg":"Securities and Commodities Authority - Uae","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"On appeal","fine":13613.0,"dk":"2024/2449/KH/ET","al":"The Securities and Commodities Authority - Uae (\"SCA\") found that Deutsche Bank AG, Dubai branch (Deutsche securities and services) (\"DSS\") failed to timely submit a required annual financial report for the period ending December 31, 2023.","res":"Order","sm":"On June 20, 2024, sca issued an enforcement notice to DSS dated June 10, 2024, finding that DSS failed to timely submit a required annual financial report for the period ending December 31, 2023. The penalty notice imposed a fine on DSS of aed 50,000, which is approximately usd $13,613, which will be timely paid. DSS filed an appeal with sca on June 27, 2024, which remains pending.","ab":"Deutsche Bank AG, Dubai","firms":[300838],"id":498},{"d":"2024-06-18","di":"2024-06-18","dr":"2024-06-18","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC (\"Cfe\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"FILE NO. URE-289-09","al":"Alleged violation of cfe rule 410a by misreporting open interest in various futures contracts to the options clearing corporation and cfe rule 412b(a)(II) on or about May 18, 2022 through April 4, 2023. Also, an alleged violation of violating cfe rule 501 by failing to prepare and keep current accurate books and records from on or about March 13, 2023 through on or about May 22, 2023","res":"Consent","sm":"Firm consented to a fine of $70,000.00","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":499},{"d":"2024-06-18","di":"2024-06-18","k":"Regulatory Action","dk":"2024-0148-S","ab":"Wallach, Roger, M","firms":[7691],"id":500},{"d":"2024-06-18","di":"2018-06-19","dr":"2024-06-18","k":"Regulatory Action","rg":"Other","reg":"Federal Department of Finance - Switzerland (\"FDF\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35680.0,"dk":"G01187787; A0000289766; B103201­0000014, RÉF. 442.2­628","al":"The FDF alleged that Wellington had not provided an additional table that provides a breakdown of shares among our client accounts with six large shareholder disclosure filings made in 2016 and 2017 in accordance with art. 151 in relation with art. 120 of the federal act on financial market infrastructures and market conduct in securities and derivatives trading (finmia; SR 958.1). The omission was uncovered by Wellington and self-disclosed to the regulator in 2017. While the shares held by Wellington Management group LLP were properly disclosed, Wellington did not include a breakdown of shares held among our accounts as required under the regulation.","res":"Settled","sd":"The amount of the settlement was CHF 31,550 (approximately usd 35,500)","sm":"Wellington consented to the fine in full settlement of the matter. There were no additional conditions imposed. No information Filed","ab":"Wellington Management","firms":[106595],"id":501},{"d":"2024-06-17","di":"2023-12-08","dr":"2024-06-17","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":150000.0,"dk":"REG-24-CAF-04","al":"Advisory affiliate sold federally covered securities in the state of Texas during a time when it was not registered as an issuer- dealer in the state. As a consequence, the state would not accept notice filings on regulation a offerings without a named issuer-dealer, which caused a notice filing violation.","res":"Order","sd":"Administrative fine of $150,000 levied against the advisory affiliate. Funds were paid on 6/28/24 with no portion waived.","sm":"Consent order was signed and entered on 6/17/24","ab":"Masterworks","firms":[324239],"id":502},{"d":"2024-06-12","di":"2024-06-12","k":"Regulatory Action","dk":"2022073421501","ab":"somlo, marvin","firms":[7691],"id":503},{"d":"2024-06-11","di":"2024-06-11","dr":"2024-06-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":1250000.0,"dk":"FILE NO. 3-21961","al":"The SEC alleged that Anson Funds Management (\"Anson funds\") and Anson advisors inc. (\"Anson advisors\") violated section 206(4) of the Advisers Act and rule 206(4)-8(a)(1) and (2) thereunder by omitting from the private placement memorandum of one of their advisory client funds (the \"PPM\") their agreements with and payments to short publishers, which rendered statements about Anson funds' short strategy misleading. The SEC also alleged that Anson funds violated section 206(4) of the Advisers Act and rule 204-2(a)(1) and (2) thereunder by inaccurately recording the payments for the benefit of a short publisher in its journal and ledgers as payments to a third-party intermediary for research services, when in fact they were to the short publisher for trading profits. Finally, the SEC alleged that Anson funds violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder by failing to implement its compliance policy when it approved and paid the short publisher through the third-party intermediary, and when it omitted from the description of its short strategy in the PPM its practice of working with short publishers and paying them a share of the fund client's trading profits.","res":"Order","sd":"Without admitting or denying the allegations, (I) Anson funds agreed to cease and desist from violating sections 204 and 206(4) of the Advisers Act and rules 204-2(a), 206(4)-7 and 206(4)-8 thereunder, (II) Anson advisors agreed to cease and desist from violating section 206(4) of the Advisers Act and rule 206(4)-8 thereunder, (III) Anson funds and Anson advisors agreed to a censure, (IV) Anson advisors agreed to pay a $1,000,000 civil money penalty, which will be timely paid, and (IV) Anson funds agreed to pay a $1,250,000 civil money penalty, which was paid on June 14, 2024.","sm":"On June 11, 2024, Anson funds and Anson advisors, without admitting or denying the findings or conclusions therein, entered into a settlement with the SEC. the SEC approved the settlement in its order instituting administrative and cease-and-desist- proceedings, pursuant to sections 203(e) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order, including the following terms and conditions. Anson funds agreed to cease and desist from violating sections 204 and 206(4) of the Advisers Act and rules 204-2(a), 206(4)-7 and 206(4)-8 thereunder; to a censure; and to pay a $1,250,000 civil money penalty, which was paid on June 14, 2024. Anson advisors agreed to cease and desist from violating section 206(4) of the Advisers Act and rule 206(4)-8 thereunder; to a censure; and to pay a $1,000,000 civil money penalty, which was paid on June 14, 2024. No information Filed","ab":"Anson Funds Management LP","self":true,"firms":[125109],"id":504},{"d":"2024-06-06","di":"2024-01-30","dr":"2024-06-06","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Other","os":"CME rule 538.","st":"Final","fine":20000.0,"dk":"NYMEX 23-1661-BC","al":"On October 12, 2022, Schonfeld Strategic management LLC, an advisory affiliate of the registrant, engaged in \"exchange for related product\" transactions in platinum futures contracts that were found, under NYMEX rule 538.c, to have been non-bona fide due to an absence of market risk.","res":"Settled","sd":"$20,000","sm":"On October 12, 2022, Schonfeld Strategic management LLC (\"SSM\"), an advisory affiliate of the registrant, exchanged January 2023 platinum futures contracts that it was not able to take physical delivery of for an equivalent OTC position. On June 4, 2024, a panel of the NYMEX business conduct committee found this exchange for related position to be non-bona fide, under NYMEX rule 538.c., due to the absence of any market risk, and accepted an offer of settlement pursuant to which SSM agreed to pay a $20,000 fine while neither admitting nor denying any rule violation. (NYMEX 23-1661-BC-1) No information Filed","ab":"Schonfeld Strategic","firms":[281984],"id":505},{"d":"2024-05-31","di":"2024-05-31","dr":"2024-05-31","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"AP-23-16","al":"The state alleged that 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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Missouri and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Missouri customers in an amount of no less than $138,887.37. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of 15 CSR 30-51.171(2)(a-c).","ab":"Raymond James Financial","firms":[705],"id":506},{"d":"2024-05-27","di":"2023-08-04","dr":"2024-05-27","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":28652.65,"al":"The local regulator, Securities and Exchange Board of India (SEBI) issued a show cause notice dated 04 August 2023, to the advisory firm and the members of the fund trustees as on that date, (hereinafter referred to as \"said trustees\") alleging violation of regulation 18(9) of the SEBI (mutual funds) regulations, 1996 (\"the regulations\") by the said trustees, and violation of clause 5 of the fifth schedule of the regulations and clause 1.3.1 (c) of SEBI circular no. SEBI/ho/imd/DF2/cir/2021/683 dated 10 December 2021, by the advisory firm.","res":"Vacated","sm":"The advisory firm along-with the said trustees have filed a settlement application dated 05 October 2023 under the sebi (settlement proceedings) regulations, 2018 and sebi vide its settlement order dated 27 May 2024 has disposed of the adjudication proceedings initiated vide show cause notice dated 04 August 2023.","ab":"HSBC Asset Management (India) Private Limited","self":true,"firms":[324468],"id":507},{"d":"2024-05-26","di":"2024-05-26","dr":"2024-05-26","k":"Regulatory Action","rg":"Other","reg":"Washington","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Investigative costs","st":"Final","fine":10000.0,"dk":"S-19-2660-23-CO01","al":"Failure to adequately supervise reps sale of high yield bonds.","res":"Consent","sm":"Fahsholtz, michael; Stifel, nicolaus & co. - S-19-2660-23-CO01 - consent order on May 26, 2024, the securities division entered a consent order with respondents michael fahsholtz (\"fahsholtz,\" CRD #2057306) and fahsholtz's former broker-dealer, Stifel, nicolaus & co., inc. (\"Stifel,\" CRD #793) (collectively, \"the respondents\"). As set forth in the consent order, fahsholtz sold significant quantities of high-yield bonds (commonly known as junk bonds) to many clients whose age and risk tolerance were inconsistent with high concentrations of risky bonds. The consent order alleges that these sales violated RCW 21.20.702, the suitability provision of the Securities Act of Washington. The consent order further alleges that Stifel failed to adequately monitor fahsholtz's sale of high-yield bonds and to note various discrepancies between fahsholtz's justifications for his sales and his customers' stated risk tolerance, investment objectives, and outside holdings, as required by RCW 21.20.110. In the consent order, the respondents neither admit nor deny the securities division's findings of fact and conclusions of law, but fahsholtz agrees to cease and desist from violating the suitability provisions of the Securities Act of Washington. Fahsholtz further agrees to pay a fine of $10,000; Stifel agrees to pay a fine of $10,000 and investigative costs of $20,000. The respondents waived their right to a hearing and to judicial review of this matter.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":508},{"d":"2024-05-23","di":"2024-05-23","dr":"2024-05-23","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s); undertaking","st":"Final","fine":200000000.0,"dk":"CFTC DOCKET NO. 24-07","al":"On May 23, 2024, J.P. Morgan Securities LLC(\"JPMS\") entered into a settlement with the Commodity Futures Trading Commission (\"CFTC\") resulting in an administrative order (\"order\"). JPMS consented to the entry of the order, which found that it failed to diligently supervise its business as a CFTC registrant in violation of CFTC regulation 166.3 in connection with meaningful gaps in its trade surveillance on multiple venues and trading systems due to its surveillance not operating correctly.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":509},{"d":"2024-05-21","di":"2023-05-25","dr":"2024-05-21","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Other","os":"No action taken by sebi","st":"Final","fine":18000.0,"dk":"NOT APPLICABLE","al":"Sebi had issued a show-cause notice dated May 25, 2023 (\"SCN\") in the matter of voluntary delisting offer by one of the clients of JM Financial Limited (\"JMFL\") to certain entities, including JMFL. It was alledged in the SCN that JMFL failed to exercise due diligence, care and professional judgement as the manager to the delisting offer and hence, have allegedly violated regulation 29(4) of sebi (delisting of equity shares) regulations, 2021 & regulation 13 read with schedule III of sebi (merchant bankers) regulations, 1992","res":"Settled","sd":"JMFL settled with sebi the adjudication proceedings initiated against it, without admitting or denying the findings of facts and conclusions of law by agreeing to pay a settlement amount of inr. 15,00,000/- (approximately equivalent to usd 18,000/-) towards the settlement terms.","sm":"Within the space provided). JMFL had submitted its response to the SCN and had also filed a settlement application with sebi in the matter. JMFL settled with sebi the adjudication proceedings initiated against it vide the SCN, without admitting or denying the findings of facts and conclusions of law by agreeing to pay a settlement amount of RS. 15,00,000/- (approximately equivalent to usd 18,000/-) towards the settlement terms pursuant to which sebi passed a settlement order dated May 21, 2024 and the proceedings initiated in terms of the SCN, have been disposed of. (Matter closed)","ab":"JM Financial Limited","self":true,"firms":[293667],"id":510},{"d":"2024-05-16","di":"2024-05-16","dr":"2024-05-16","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"DQA-24-1369","al":"On May 16, 2024, the market regulation department of the CME Group Inc. (\"CME\") notified Goldman Sachs & Co. LLC (\"gsco\" or \"the firm\") that CME recently conducted a suspense account exam for trade dates October 1, 2023 through December 31, 2023, where CME identified potential violations of rule 536.c regarding bunched orders and orders eligible for post execution allocation, for using a general suspense account and not obtaining specific account designations until after order entry for six orders.","res":"Decision","sm":"CME imposed a summary fine in the amount of $1,000, which gsco paid by submission of a wire on June 12, 2024.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":511},{"d":"2024-05-16","dr":"2024-05-16","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"FILE NO. URE-264-05","al":"Stifel, Nicolaus & Company, Incorporated violated sea rule 15C3-5 and BZX rule 3.2 in that the firm's risk management controls and procedures were not reasonably designed to prevent the entry of erroneous orders on BZX, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":512},{"d":"2024-05-16","di":"2024-05-09","dr":"2024-05-16","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"FILE NO. URE-264-07","al":"Stifel, Nicolaus & Company, Incorporated violated sea rule 15C3-5 and edgx rule 3.2 in that the firm's risk management controls and procedures were not reasonably designed to prevent the entry of erroneous orders on edgx, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":513},{"d":"2024-05-09","di":"2024-05-09","dr":"2024-05-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":825000.0,"dk":"2017054488401","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Merrill Lynch, Pierce, Fenner & Smith (MLPF&s) failed to reasonably supervise the execution timeliness of customer orders and the accuracy of memoranda for retail brokerage equity orders MLPF&s received electronically, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPF&s agreed to the imposition of a censure, a fine in the amount of $825,000, and certain undertakings. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":514},{"d":"2024-05-08","di":"2024-05-08","dr":"2024-05-08","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"\"Fine : KRW 370 mil / usd 251,273 (exchange rate 1472.5) voluntary corrective measures on its employee\"","st":"Final","fine":251273.0,"al":"\"Financial services commission (FSC) alleged that Samsung Life Insurance co. LTD. violated: - recording obligations when entering into a trust agreement with an unsuitable investor or an investor over the age of 70. - Investment advertising rules for investment trusts. - The prohibition of promoting a specific money trust to an unspecified number of investors.\"","res":"Decision & Order of Offer of Settlement","sd":"See below for details","sm":"On May 8, 2024, the FSC issued a notice of its decision, finding that Samsung Life Insurance co., LTD. was liable for the allegations listed in our response to question 7. As a result, FSC imposed a fine of KRW 370 million in aggregate and ordered voluntary corrective measures for its employees.","ab":"Samsung Life Insurance","firms":[158319],"id":515},{"d":"2024-04-30","di":"2024-04-30","dr":"2024-04-30","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"2023-025","al":"On April 30, 2024, the market regulation department of ICE Futures U.S., Inc. (\"IFUS\") found that Goldman Sachs & Co. LLC (\"GSCO\") failed to meet the requirements of exchange rules 4.19(c)(II)(2), and 4.19(e), by failing to preserve the required order message data.","res":"Decision","sm":"Ifus imposed a summary fine of $15,000, which gsco paid by submission of a wire on May 8, 2024.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":516},{"d":"2024-04-29","di":"2024-04-29","dr":"2024-04-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":375000.0,"dk":"2015046503001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The inaccuracies stemmed from coding errors in the electronic systems that the firm relied on for sending trade confirmations. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited and vice versa. These inaccuracies resulted from the firm's coding of its fixed income trade order management system to automatically populate certain confirmations with a designation that the transactions were solicited, and others with a designation that the transactions were unsolicited. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations. Furthermore, the firm failed to send trade confirmations for millions of dividend reinvestment program (DRIP) transactions. The firm did not provide customers with a detailed written description of the DRIP prior to enrollment containing certain disclosures, as required by a no-action letter that the SEC published. The firm instead confirmed automatic dividend reinvestments pursuant to a DRIP through monthly account statements rather than trade-by-trade confirmations. However, by failing to comply with the conditions of the no-action letter, the firm did not qualify for exemptive relief from rule 10B-10(a)'s trade-by-trade confirmation requirement. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPS, reasonably designed to achieve compliance with trade confirmation requirements. The firm's WSPS failed to describe how supervisors should conduct periodic monitoring to confirm that internal firm systems and third-party vendor systems were working as intended to send customers trade confirmations when required and with accurate information. The firm also failed to conduct reasonable monitoring and periodic testing to confirm that the systems it relied upon for sending and generating accurate trade confirmations were working as intended. As a result, the firm did not timely detect multiple issues that impacted trade confirmations. The findings also included that the firm violated regulation t promulgated by the Board of Governors of the Federal Reserve system under section 7 of the Exchange Act by extending credit to certain customers of the firm and its introducing firms. Certain firm customers with cash accounts and certain customers of introducing brokers with cash accounts for which the firm was the clearing broker sold securities without previously paying for them in full. However, the firm failed to withdraw from those customers the privilege of delaying payment beyond the trade date for 90 calendar days following the date of sale of the security, as required by regulation t. As a result, the firm incorrectly executed hundreds of trades in those accounts and frequently sold the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":517},{"d":"2024-04-29","di":"2024-04-29","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Monetary damages, equitable relief, and other relief as determined by the court","st":"Pending","al":"Plaintiff alleges breaches of fiduciary duty, breach of contract, and fraud in connection with the management and operation of a private investment fund, including access to books and records.","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":518},{"d":"2024-04-19","di":"2024-04-19","dr":"2024-04-19","k":"Regulatory Action","rg":"Other","reg":"Missouri Department of Commerce and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":13000.0,"dk":"390226","al":"New York Life Group insurance company of New York and the predecessor company filed forms and provided data to the state from 2018 to 2022 that contained inaccuracies.","res":"Settled","sd":"New York life agrees to pay the $13,000 forfeiture and to take remedial action bringing it into compliance with the statutes and regulations of Missouri and agrees to maintain those remedial actions at all times.","ab":"New York Life Group","firms":[173355],"id":519},{"d":"2024-04-17","di":"2024-04-17","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Monetary damages, equitable relief, and other relief as determined by the court","st":"Pending","al":"Plaintiffs allege tortious interference with contractual and unitholder voting rights in connection with a fund liquidation.","ab":"Hatteras Investment Partners, LP","self":true,"firms":[170628],"id":520},{"d":"2024-04-05","di":"2024-04-05","dr":"2024-04-05","k":"Regulatory Action","rg":"Other","reg":"ICE NGX Canada Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"N/A","al":"Atlas NG LLC submitted an invoice payment one day late to ICE NGX Canada Inc.","res":"Other","sd":"A summary sanction of one thousand ($1,000) canadian dollars was levied against Atlas NG LLC. the sanction was paid on April 11, 2024.","ab":"Atlas NG, LLC","firms":[138111],"id":521},{"d":"2024-04-04","di":"2024-04-04","dr":"2024-04-04","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"CASE NO. 2023-018","al":"ICE Futures U.S., Inc. (\"IFUS\") found that Deutsche bank (\"DBAG\") failed to comply with IFUS rule 4.19(c)(I) relating to audit trail requirements by not populating a \"manual order\" identifier on certain order messages between January and August 2023.","res":"Order","sm":"On April 4, 2024, ifus issued a summary fine notice to dbag, finding that dbag failed to comply with ifus rule 4.19(c)(I) relating to audit trail requirements by not populating a \"manual order\" identifier on certain order messages between January and August 2023. The summary fine notice imposed a fine of usd $10,000, which was timely paid on April 26, 2024.","ab":"Deutsche Bank AG","firms":[300838],"id":522},{"d":"2024-04-04","di":"2019-12-23","dr":"2024-04-04","k":"Regulatory Action","rg":"Other","reg":"AutoritÉ Des MarchÉS Financiers","st":"Final","fine":20345000.0,"dk":"PROCEDURE NO. 2019-03","al":"On December 23, 2019, Elliott Capital Advisors, L.P. (\"ECALP\") received, and subsequently on December 31, 2019, Elliott advisors (UK) limited (\"EAUK\") received, a copy of an AutoritÉ Des MarchÉS Financiers (the \"AMF\") investigative report (the \"report\") to the sanctions commission of the AMF in France. (ECALP and EAUK are together referred to below as \"Elliott\".) The report reflects non-binding recommendations as to certain allegations set forth by the AMF as a result of their investigation into Elliott's activity concerning a tender offer conducted by xpo logistics, inc. and xpo logistics France (collectively \"xpo\") for the shares of norbert dentressangle SA (\"NDSA\") in 2015. The recommendations set forth in the report are that (I) although Elliott's public disclosure of its position in NDSA was not misleading or manipulative, it inaccurately described its derivative holdings as \"contracts for difference\" rather than as \"equity swaps\"; (II) Elliott did not declare its intention to not tender its holdings in NDSA into xpo's tender offer in a timely manner; and (III) despite responding to each of the AMF's requests for information in a timely manner, and despite Elliott having voluntarily agreed to answer requests it was not compelled to answer, EAUK impeded the AMF's investigation by making a delayed production of documents that Elliott, in the AMF's view, should have understood were being sought by the AMF.","res":"Decision","sd":"The sanctions commission of the AMF assessed a fine of eur 15 million (approximately $16,500,000) against eauk and eur 5 million (approximately $5,500,000) against ecalp. The paris Court of Appeals reduced the fine against eauk by eur 1 million (approximately $1,100,000) and against ecalp by eur 0.5 million (approximately $555,000).","sm":"On April 22, 2020, Elliott received a written decision in an administrative proceeding from the sanctions commission of the AMF in France relating to Elliott's activity concerning a tender offer conducted by xpo for the shares of ndsa in 2015. In the written decision the AMF found (I) that Elliott inaccurately described their derivative holdings as \"contracts for difference\" rather than as \"equity swaps\" in their public disclosure of their position in ndsa; (II) that Elliott did not declare their intention to not tender their holdings in ndsa into xpo's tender offer in a timely manner; and (III) that eauk impeded the AMF's investigation by making a delayed production of documents that Elliott, in the AMF's view, should have understood were being sought by the AMF. Although the sanctions commission accepted that Elliott's declarations relating to xpo's tender offer did not in fact mislead or cause market participants to modify their strategies concerning the tender offer, and found no intent by eauk to impede the AMF's investigation through the delayed production of materials, it nevertheless imposed a fine of eur 15 million against eauk and a fine of eur 5 million against ecalp. Elliott strongly disagrees with the findings against Elliott in this administrative proceeding, considers them wholly without foundation, vigorously opposes any suggestion of wrongdoing, and appealed the matter to the paris Court of Appeals. On March 24, 2022 the paris Court of Appeals determined that Elliott was not in fact required in its declarations of intent to distinguish the type of its derivative holdings and reduced the fine against eauk by eur 1 million and against eca by eur 0.5 million. However, the Court of Appeals upheld the AMF's findings that: (I) Elliott was nevertheless required to distinguish the type of its derivative holdings in its other filings; (II) Elliott did not declare its intention to not tender its holdings in ndsa into xpo's tender offer in a timely manner; and (III) eauk impeded the AMF's investigation by making a delayed production of documents that Elliott, in the AMF's view, should have understood were being sought by the AMF. Elliott disagreed with the decision of the paris Court of Appeals and appealed the decision to the french Supreme Court, the cour de cassation. On April 4, 2024 the cour de cassation affirmed the decision of the paris Court of Appeals. Elliott disagrees with the decision of the cour de cassation and on August 2, 2024, Elliott submitted an application to the european court of human rights to hear an appeal. On November 13, 2025, the european court of human rights declined to hear Elliott's application. None of the costs associated with this matter (including the penalty assessed by the sanctions commission and the cost of the appeal) have been or will be borne by the Elliott funds, and Elliott continues to believe that this matter did not have an adverse impact on the funds.","ab":"Elliott Capital Advisors,","firms":[307151],"id":523},{"d":"2024-04-03","di":"2024-04-03","dr":"2024-04-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Undertaking, civil monetary penalty, and censure","st":"Final","fine":6500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21900","al":"The SEC found that Senvest Management, LLC (\"Senvest\") violated: (1) section 204 of the Advisers Act and rule 204-2(a)(7) by failing to adequately preserve certain off-channel communications related to its business; (2) section 206(4) of the Advisers Act and rule 206(4)-7 by failing to adopt and implement written policies and procedures reasonably designed to prevent violation of the Advisers Act and the rules thereunder; (3) section 204a of the Advisers Act and rule 204A-1 by failing to establish, maintain, and enforce a written code of ethics that meets the minimum standards set forth in rule 204A-1; and (4) section 203(e)(6) of the advisers acy by failing to reasonably supervise certain employees.","res":"Order","sd":"In connection with the entry of the order, Senvest has agreed to (1) a censure, (2) cease and desist from committing or causing any future violations of sections 204, 204a, and 206(4) of the Advisers Act, (3) pay a $6.5 million civil money penalty and (4) perform undertakings described in response to question 13 of this disclosure reporting page.","sm":"On April 3,2024 , the SEC issued a settled administrative order (the \"order\") finding violations described above under item 7 of this DRP. Senvest paid the civil money penalty on April 3, 2024. In addition to the other sanctions detailed in item 12 of this DRP, pursuant to the order, Senvest has undertaken to retain a compliance consultant to review certain aspects of Senvest's compliance program related to the use of unauthorized communication methods for business communications, including related policies, procedures, trainings, surveillance program, technological solutions, and other preventative measures. Senvest has undertaken to implement such consultant's recommendations, subject to the terms of the order, and agreed to a follow-on review. No information Filed","ab":"Senvest Management, LLC","self":true,"firms":[137312],"id":524},{"d":"2024-04-01","di":"2022-03-23","dr":"2024-04-01","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fine- $17,400","st":"Final","fine":17400.0,"dk":"FI DNR 20-28953","al":"In August 2019, Lazard Asset Management LLC (\"LAM\") submitted a notification with the sfsa disclosing that LAM's ownership of shares of a Swedish issuer had exceeded 5%. Due to an administrative error, such notification was filed after the notification deadline specified in the Swedish financial instrument trading act.","res":"Settled","sd":"In May 2022, the sfsa sent lam an invoice for a fine of sek 185,000 (approximately usd 17,400). Lam did not receive the invoice at that time. Lam received the invoice and paid the fine in April 2024.","sm":"In August 2019, Lazard Asset Management LLC (\"LAM\") filed a notification with the Swedish Financial Supervisory Authority (\"Sfsa\") disclosing that LAM's ownership of shares in a Swedish issuer had surpassed the 5% threshold. In May 2022, the SFSA issued an invoice to LAM imposing a fine of sek 185,000 (approximately usd 17,400). However, LAM did not receive the invoice at that time. The invoice was subsequently received by LAM in April 2024, at which point LAM promptly remitted payment for the fine. No information Filed","ab":"Lazard Asset Management LLC","self":true,"firms":[122836],"id":525},{"d":"2024-03-29","di":"2024-03-29","dr":"2024-03-29","k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":75000.0,"dk":"MS-23-7-18","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to New Mexico and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain New Mexico customers in an amount of no less than $53,951.01. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of nmsa 1978, §58­13c­412(c)(9).","ab":"Raymond James Financial","firms":[705],"id":526},{"d":"2024-03-28","di":"2024-03-28","dr":"2024-03-28","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Other","os":"Settlement","st":"Final","fine":30000.0,"dk":"URE-298-09","al":"RBC Dominion Securities, inc. violated CBOE exchange rules 412b(b) for alleged failure to submit timely large trader reports for a single customer.","res":"Settled","ab":"RBC Dominion Securities","firms":[31194],"id":527},{"d":"2024-03-25","di":"2024-03-25","dr":"2024-03-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":920000.0,"dk":"2019061350401","al":"Without admitting or denying the findings, the firms consented to the sanctions and to the entry of findings that they failed to establish, maintain, and enforce a supervisory system, including WSPS, reasonably designed to achieve compliance with their suitability obligations in connection with non-traditional exchange-traded product (NT-etp) transactions. The findings stated that although the firms revised their WSPS following a previously issued AWC, the WSPS still failed to provide reasonable guidance about how to identify and address potentially unsuitable NT-etp recommendations. The WSPS did not require supervisors to take any action to assess whether NT-etp recommendations, including recommended exit or hold strategies, were consistent with the intended holding periods identified in the products' prospectuses. In addition, the firms' system for identifying and addressing potentially unsuitable NT-etp recommendations was not reasonably designed. In response to the previous AWC, the firms implemented a new automated alert that was designed to flag, for supervisory review, all NT-etp positions that had been held for longer than 30 days. However, the firms almost immediately deactivated the alert after it resulted in over 2,000 hits per day. Even after the firms reactivated the alert, supervisors had broad discretion to resolve the alerts, but the firms did not provide supervisors with any training on how to evaluate the red flags presented by the long holding periods. As a result, supervisors routinely cleared the 30-day holding-period alerts without any analysis of the suitability of the underlying NT-etp recommendations that led to the alerts. Further, in response to discovering that representatives were routinely recommending long-term holding periods for NT-etps, the firms' compliance department instituted a clean-up effort that involved tracking NT-etp positions held for more than 30 calendar days and encouraging (but not requiring) supervisors to speak with representatives and customers about selling aged positions. However, the clean-up was not sufficient in certain instances to prevent representatives from continuing to recommend a strategy of buying and then holding these products for periods well beyond the periods identified in the products' prospectuses. As a result of these supervisory failures, the firms failed to detect or address hundreds of occasions in which the firms' representatives recommended that customers buy and then hold NT-etps for potentially unsuitable periods. Some of the affected customers were seniors, and many had conservative investment objectives or moderate risk tolerances. In total, the firms' representatives recommended at least 438 daily-reset NT-etp positions that were held for more than seven days, and 45 monthly reset NT-etps that were held for more than 60 days. Collectively, these transactions resulted in realized customer losses of $1,289,937.17 in accounts.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":528},{"d":"2024-03-15","di":"2024-03-15","dr":"2024-03-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":400000.0,"dk":"2019062348302","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish a supervisory system reasonably designed to review and monitor the transmittal of customer funds when a broker had power of attorney over a customer's account and failed to reasonably follow up on red flags concerning a broker of theirs. The findings stated that the broker was the power of attorney on the brokerage account of a senior customer, which provided him the authority to write checks on the customer's behalf. The broker converted at least $105,000 from the customer by writing checks on her account that he made payable to himself or to a bank account that he controlled. The firm later ceased granting exceptions to its prohibition on brokers from serving as power of attorney for a non-family member account and memorialized its prohibition without exceptions and fully reimbursed the customers estate for the broker's misconduct. The findings also stated that the firm failed to reasonably follow up on red flags of unsuitable trading by a different broker in options and a high-risk microcap security. The firm failed to reasonably respond to certain alerts contained in reports that the broker's options trades were potentially unsuitable. The broker recommended more than 100 speculative options trades in one of the brokerage accounts of the customer, who was a 64-year-old retiree with no options experience or knowledge, causing the account to lose nearly 80 percent of its funds. The firm was aware of the volume of options trading and discussed the trading in the account with the representative. However, despite the fact that the trading generated more than 10 alerts, the firm failed to reasonably investigate whether the trading was consistent with the customer's investment objectives and risk tolerance. Instead, the firm approved a change in the customer's investment objectives from \"growth and income\" to \"speculative/active trading/complex strategies\" based on broker's representations and suppressed several subsequent options alerts involving the customer's account. An additional customer of the broker with no options experience, a growth and income objective, and a moderate risk tolerance was recommended call options that resulted in $27,745.94 in losses. The firm also failed to reasonably respond to red flags of this broker's unsuitable recommendations of a high-risk microcap security. The broker recommended a stock to additional customers that had fallen substantially prior to the purchases due to (among other things) substantial doubts being raised in public reports about the company's ability to continue as a going concern. After excessive commission alerts were generated regarding some of these trades, the firm noted that broker was purchasing a \"collapsing equity\" and flagged this trading activity for further monitoring; yet the firm failed to take steps other than asking the broker about the customers' knowledge of and comfort with the purchases. The broker continued to recommend additional purchases of the stock as the price continued to fall and the customers had incurred realized losses of $53,498 due to this trading.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":529},{"d":"2024-03-15","di":"2024-03-15","k":"Regulatory Action","dk":"N/A","ab":"Hardison, Don","firms":[7691],"id":530},{"d":"2024-03-06","di":"2024-03-06","dr":"2024-03-06","k":"Regulatory Action","rg":"Other","reg":"Rhode Island Dept. of Business Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"2023-SC-004","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Rhode Island and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Rhode Island customers in an amount of no less than $12,954.52. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of ri gen. Laws section 7-11-212(b)(11).","ab":"Raymond James Financial","firms":[705],"id":531},{"d":"2024-03-01","di":"2022-06-06","dr":"2024-03-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":950000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 34-99651","al":"The allegations related to the timeliness of HG Vora Capital Management LLC's schedule 13d filing regarding its shareholdings in a public company.","res":"Decision & Order of Offer of Settlement","sd":"The $950,000 penalty noted above was paid by HG Vora Capital Management, LLC on March 5, 2024.","sm":"On March 1, 2024, the SEC published an administrative order of settlement between it and the firm (the \"order\") in which the firm neither admitted nor denied the findings related to the timeliness of its schedule 13d filing related to its shareholdings in a public company. The order found that the firm filed the required schedule 13d disclosing a control purpose on May 13, 2022, but should have filed the form no later than May 6, 2022. The firm consented to the entry of the settled administrative order finding violations of section 13(d)(1) of the Securities Exchange Act of 1934 and rule 13D-1 thereunder, and agreed to a cease-and-desist order against future violations of these provisions and a $950,000 penalty. No information Filed","ab":"HG Vora Capital Management, LLC","self":true,"firms":[161788],"id":532},{"d":"2024-02-29","di":"2023-08-11","dr":"2024-02-29","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12054.26,"dk":"SO/AS/EFD2/2022-223/7365","al":"In March 2023, due to a technical issue with a third-party service provider, gmo made a late filing of a routine shareholder holdings disclosure report required under indian regulations. Pursuant to customary market practice, gmo entered into a settlement with the Securities and Exchange Board of India (SEBI) on February 29, 2024 and agreed to pay an immaterial settlement amount in connection with the late filing.","res":"Decision","sd":"Note: fine was paid in indian rupees in the amount of 10,00,000 (rupees ten lakhs), and has been converted above to usd.","sm":"In accordance with the settlement offer, gmo has been ordered to pay a fine in the amount of 10,00,000/- (rupees ten lakhs only) which was paid on February 8, 2024.","ab":"Gmo Emerging Markets","firms":[106220],"id":533},{"d":"2024-02-29","di":"2024-02-02","dr":"2024-02-29","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (\"Sebi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":13060.0,"dk":"SO/AN/RG/2023-24/7386","al":"The securities and exchange board of india alleged Deutsche Bank AG, Mumbai branch (\"DBAG\") violated section 4(d) of the sebi (foreign portfolio investors) regulations, 2019, for granting registration or renewal to foreign portfolio investors that were not eligible for such status.","res":"Order","sm":"On a June 19, 2023 sebi issued a show cause notice (the \"show cause notice\") to dbag alleging dbag violated section 4(d) of the securities and exchange board of india (foreign portfolio investors) regulations, 2019, for granting registration or renewal to foreign portfolio investors that were not eligible for such status. On February 29, 2024, without admitting or denying the allegations, dbag agreed to a settlement amount of 1,105,000 inr which is approximately $13,060 usd, which was timely paid.","ab":"Deutsche Bank AG, Mumbai","firms":[300838],"id":534},{"d":"2024-02-28","di":"2024-02-28","dr":"2024-02-28","k":"Regulatory Action","rg":"State regulator","reg":"State of Georgia, Commissioner of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. charged unreasonable commissions on low-principal","st":"Final","fine":75000.0,"dk":"N/A","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Georgia and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Georgia customers in an amount of no less than $343,914.40. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of O.C.G.A. Section 10-5-41(d)(9) of the Georgia uniform Securities Act of 2008.","ab":"Raymond James Financial","firms":[705],"id":535},{"d":"2024-02-24","di":"2024-02-24","dr":"2024-02-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Alaska","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"23-111-S","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Alaska and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Alaska customers in an amount of no less than $25,223.09. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation as 45.55.060(b) and 45.56.440(d)(9).","ab":"Raymond James Financial","firms":[705],"id":536},{"d":"2024-02-22","di":"2024-02-22","dr":"2024-02-22","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"116857-S","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Florida and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Florida customers in an amount of no less than $1,096,109.24. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of rule 69W-600.013(1)(h)1.(2021).","ab":"Raymond James Financial","firms":[705],"id":537},{"d":"2024-02-21","di":"2024-02-21","dr":"2024-02-21","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2022-033","al":"On February 21, 2024, a subcommittee of the ICE Futures U.S. business conduct committee (\"IFUS\") determined that Goldman Sachs & Co. LLC (\"GSCO\") may have violated exchange rule 4.02(c) on July 29, 2022, when an employee, upon receipt of simultaneous buy and sell orders in the same futures contract, failed to inquire about the ownership to confirm whether they belonged to the same principal, and entered the orders resulting in a wash trade.","res":"Settled","sm":"In accordance with the terms of settlement, in which gsco neither admitted nor denied the alleged rule violation, gsco agreed to pay a monetary penalty of $10,000. The fine was paid in full on February 26, 2024.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":538},{"d":"2024-02-21","di":"2024-02-21","dr":"2024-02-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil money penalty; disgorgement; prejudgment interest","st":"Final","fine":140000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21860","al":"Contrarian Capital Management, L.L.C. (\"Contrarian\") was alleged to have violated rule 105 of Regulation M of the Securities Act of 1934. Rule 105 makes it unlawful to buy an equity security in an underwritten secondary public offering if the buyer sold short the same security during the restricted period specified in the rule (generally five business days before pricing of the security).","res":"Order","sd":"Civil penalty: $140,000; disgorgement: $351,726.86; prejudgment interest: $29,600.50","sm":"On February 21, 2024 Contrarian consented, without admitting or denying the findings therein, to the entry of an order issued by the SEC finding that on two occassions in 2020 it violated rule 105 of Regulation M of the Securities Exchange Act of 1934. In settlement of this matter, Contrarian agreed to pay a civil monetary fine of $140,000, disgorgment of $351,726.86 and prejudgment interest of $29,600.50; and to cease and desist from committing or causing any violations and any future violations of rule 105. No information Filed","ab":"Contrarian Capital Management LLC","self":true,"firms":[109979],"id":539},{"d":"2024-02-15","di":"2024-02-15","dr":"2024-02-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1600000.0,"dk":"2020065102001","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that: from December 2016 through August 2021, the firm failed to cancel or close out 239 failed inter-dealer municipal securities transactions totaling approximately $9 million within 20 calendar days after settlement, in violation of MSRB rule g- 12(h); from January 2016 through August 2021, the firm failed to take prompt steps to obtain physical possession or control of 247 short positions in municipal securities totaling approximately $9.4 million resulting from failed inter-dealer municipal securities transactions, in violation of section 15(c)(3) of the Securities Exchange Act of 1934 (\"Exchange Act\"), Exchange Act rule 15C3-3(d)(2), and FINRA rule 2010; and, from January 2016 through September 2021, the firm failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with (1) the timely close-out requirements under MSRB rule G-12(h) relating to failed inter-dealer municipal securities transactions; and (2) the requirement under Exchange Act rule 15C3-3(d)(2) that the firm take prompt steps to obtain physical possession or control of municipal securities aged more than 30 calendar days that the firm failed to receive, in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On February 15, 2024, the firm became subject to a letter of acceptance, waiver and consent issued by FINRA regarding allegations that: from December 2016 through August 2021, the firm failed to cancel or close out 239 failed inter-dealer municipal securities transactions totaling approximately $9 million within 20 calendar days after settlement, in violation of MSRB rule G-12(h); from January 2016 through August 2021, the firm failed to take prompt steps to obtain physical possession or control of 247 short positions in municipal securities totaling approximately $9.4 million resulting from failed inter-dealer municipal securities transactions, in violation of section 15(c)(3) of the Securities Exchange Act of 1934 (\"Exchange Act\"), Exchange Act rule 15C3-3(d) (2), and FINRA rule 2010; and, from January 2016 through September 2021, the firm failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with (1) the timely close-out requirements under MSRB rule G-12(h) relating to failed inter-dealer municipal securities transactions; and (2) the requirement under Exchange Act rule 15C3-3(d)(2) that the firm take prompt steps to obtain physical possession or control of municipal securities aged more than 30 calendar days that the firm failed to receive, in violation of MSRB rule G-27. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and fine in the amount of $1,600,000. The firm paid the fine in accordance with the terms of the AWC.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":540},{"d":"2024-02-08","dr":"2024-02-08","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":54081.0,"dk":"ZR 6-FR 2840/00001#00005","al":"The German federal financial supervisory authority (\"BAFIN\") found that Deutsche Bank AG (\"Dbag\") failed to inform BAFIN of an informaton technology security incident that occurred in June 2023 in a timely or proper manner.","res":"Order","sm":"On February 8, 2024, BAFIN issued a fine notice to dbag, finding that dbag failed to inform BAFIN of an informaton technology security incident that occurred in June 2023 in a timely or proper manner. The fine notice imposed a fine on dbag of eur 50,000, which is approximately usd $54,081, which will be timely paid.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":541},{"d":"2024-02-06","di":"2024-02-06","dr":"2024-02-06","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":37000.0,"dk":"2019063499507","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), submitted letters of consent and letters of acceptance, waiver, and consent (collectively, \"letters\"), which were accepted to enter settlements with FINRA and 13 exchanges. Gsco neither admitted nor denied the findings in the letters, and consented to the sanctions and entry of findings that its supervisory system was not reasonably designed to identify potentially manipulative trading activity. Specifically, FINRA and the 13 exchanges found that gsco failed to include warrants, rights, units, and certain over-the-counter (\"OTC\") equity securities in certain surveillance reports designed to identify potentially manipulative proprietary and customer trading. These securities were excluded for extended periods ranging from approximately two years to more than 12 years, between 2009 and 2023. The firm's supervisory system did not require a review of its automated surveillance reports, and as a result, gsco failed to detect these deficiencies. Gsco completed remediation for all surveillance reports, and also implemented reviews to identify if any security was inadvertently excluded from new or modified surveillance reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total amount of $512,500 by FINRA and the 13 exchanges, allocated as follows: $37,000 by FINRA; $47,000 by CBOE byx exchange, inc.; $47,000 by CBOE BZX exchange, inc.; $47,000 by CBOE edga exchange, inc.; $47,000 by CBOE edgx exchange, inc.; $20,000 by investors exchange LLC; $37,000 by the Nasdaq Stock Market LLC; $37,000 by Nasdaq BX, inc.; $37,000 by Nasdaq PHLX LLC; $37,000 by the New York Stock Exchange LLC; $37,000 by NYSE american; $37,000 by NYSE ARCA, inc.; $37,000 by NYSE chicago, inc.; and $8,500 by NYSE national, inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":542},{"d":"2024-02-06","di":"2024-02-06","dr":"2024-02-06","k":"Regulatory Action","rg":"Other","reg":"Investors' Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2019063499506","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), submitted letters of consent and letters of acceptance, waiver, and consent (collectively, \"letters\"), which were accepted to enter settlements with FINRA and 13 exchanges. Gsco neither admitted nor denied the findings in the letters, and consented to the sanctions and entry of findings that its supervisory system was not reasonably designed to identify potentially manipulative trading activity. Specifically, FINRA and the 13 exchanges found that gsco failed to include warrants, rights, units, and certain over-the-counter (\"OTC\") equity securities in certain surveillance reports designed to identify potentially manipulative proprietary and customer trading. These securities were excluded for extended periods ranging from approximately two years to more than 12 years, between 2009 and 2023. The firm's supervisory system did not require a review of its automated surveillance reports, and as a result, gsco failed to detect these deficiencies. Gsco completed remediation for all surveillance reports, and also implemented reviews to identify if any security was inadvertently excluded from new or modified surveillance reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total amount of $512,500 by FINRA and the 13 exchanges, allocated as follows: $37,000 by FINRA; $47,000 by CBOE byx exchange, inc.; $47,000 by CBOE BZX exchange, inc.; $47,000 by CBOE edga exchange, inc.; $47,000 by CBOE edgx exchange, inc.; $20,000 by investors exchange LLC; $37,000 by the Nasdaq stock market LLC; $37,000 by Nasdaq BX, inc.; $37,000 by Nasdaq PHLX LLC; $37,000 by the New York Stock Exchange LLC; $37,000 by NYSE american; $37,000 by NYSE ARCA, inc.; $37,000 by NYSE chicago, inc.; and $8,500 by NYSE national, inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":543},{"d":"2024-02-05","di":"2024-02-05","dr":"2024-02-05","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":37000.0,"dk":"2019063499510","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), submitted letters of consent and letters of acceptance, waiver, and consent (collectively, \"letters\"), which were accepted to enter settlements with FINRA and 13 exchanges. Gsco neither admitted nor denied the findings in the letters, and consented to the sanctions and entry of findings that its supervisory system was not reasonably designed to identify potentially manipulative trading activity. Specifically, FINRA and the 13 exchanges found that gsco failed to include warrants, rights, units, and certain over-the-counter (\"OTC\") equity securities in certain surveillance reports designed to identify potentially manipulative proprietary and customer trading. These securities were excluded for extended periods ranging from approximately two years to more than 12 years, between 2009 and 2023. The firm's supervisory system did not require a review of its automated surveillance reports, and as a result, gsco failed to detect these deficiencies. Gsco completed remediation for all surveillance reports, and also implemented reviews to identify if any security was inadvertently excluded from new or modified surveillance reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total amount of $512,500 by FINRA and the 13 exchanges, allocated as follows: $37,000 by FINRA; $47,000 by CBOE byx exchange, inc.; $47,000 by CBOE BZX exchange, inc.; $47,000 by CBOE edga exchange, inc.; $47,000 by CBOE edgx exchange, inc.; $20,000 by investors exchange LLC; $37,000 by the Nasdaq stock market LLC; $37,000 by Nasdaq BX, inc.; $37,000 by Nasdaq PHLX LLC; $37,000 by the New York Stock Exchange LLC; $37,000 by NYSE american; $37,000 by NYSE ARCA, inc.; $37,000 by NYSE chicago, inc.; and $8,500 by NYSE national, inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":544},{"d":"2024-02-05","di":"2024-02-05","dr":"2024-02-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE National, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8500.0,"dk":"2019063499514","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), submitted letters of consent and letters of acceptance, waiver, and consent (collectively, \"letters\"), which were accepted to enter settlements with FINRA and 13 exchanges. Gsco neither admitted nor denied the findings in the letters, and consented to the sanctions and entry of findings that its supervisory system was not reasonably designed to identify potentially manipulative trading activity. Specifically, FINRA and the 13 exchanges found that gsco failed to include warrants, rights, units, and certain over-the-counter (\"OTC\") equity securities in certain surveillance reports designed to identify potentially manipulative proprietary and customer trading. These securities were excluded for extended periods ranging from approximately two years to more than 12 years, between 2009 and 2023. The firm's supervisory system did not require a review of its automated surveillance reports, and as a result, gsco failed to detect these deficiencies. Gsco completed remediation for all surveillance reports, and also implemented reviews to identify if any security was inadvertently excluded from new or modified surveillance reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total amount of $512,500 by FINRA and the 13 exchanges, allocated as follows: $37,000 by FINRA; $47,000 by CBOE byx exchange, inc.; $47,000 by CBOE BZX exchange, inc.; $47,000 by CBOE edga exchange, inc.; $47,000 by CBOE edgx exchange, inc.; $20,000 by investors exchange LLC; $37,000 by the Nasdaq stock market LLC; $37,000 by Nasdaq BX, inc.; $37,000 by Nasdaq PHLX LLC; $37,000 by the New York Stock Exchange LLC; $37,000 by NYSE american; $37,000 by NYSE ARCA, inc.; $37,000 by NYSE chicago, inc.; and $8,500 by NYSE National, Inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":545},{"d":"2024-02-05","di":"2024-02-05","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":877.0,"dk":"REF. NO DSA-2023-05-0192G-DSA-L-BA","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for certain reporting violations between March 31, 2022 and September 30, 2022.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP49,200.00 (approximately USD877) on bana. The payment will be made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":546},{"d":"2024-02-02","di":"2024-02-02","k":"Regulatory Action","dk":"2024-0019-S","ab":"Senegal, Ronald, CHARLES","firms":[7691],"id":547},{"d":"2024-02-02","di":"2024-02-02","dr":"2024-02-02","k":"Regulatory Action","rg":"Other","reg":"Securities and Commodities Authority - Uae","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2750.0,"dk":"FS/ES/2272/2024","al":"The Securities and Commodities Authority - Uae (\"SCA\") found that Deutsche Bank AG, Dubai branch (Deutsche securities and services) (\"DSS\") failed to submit required quarterly auditor-reviewed reports for the period ending September 30, 2023.","res":"Order","sm":"On February 2, 2024, sca issued an enforcement notice to DSS, finding that DSS failed to submit required quarterly auditor- reviewed reports for the period ending September 30, 2023. The enforcement notice imposed a fine on DSS of aed 10,000, which is approximately usd $2,750. DSS filed an appeal with sca on February 7, 2024, which was rejected on February 12, 2024.","ab":"Deutsche Bank AG, Dubai","firms":[300838],"id":548},{"d":"2024-01-31","dr":"2024-01-31","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut, Dept. of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"CO-24-202326-S","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Connecticut and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Connecticut customers in an amount of no less than $129,145.74. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of section 36B-31-6F(b)of CT regulations.","ab":"Raymond James Financial","firms":[705],"id":549},{"d":"2024-01-31","di":"2024-01-31","dr":"2024-01-31","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency (OCC)","san":"Cease and Desist","st":"Final","fine":65000000.0,"dk":"OCC ENFORCEMENT ACTION FILE NO. AA-ENF-2024-8","al":"The OCC found that the bank engaged in unsafe or unsound practices, including its failure to establish effective risk management and internal controls. This failure also resulted in noncompliance with 12 CFR part 30, appendix d, \"OCC guidelines establishing heightened standards for certain large insured national banks, insured federal savings associations, and insured federal branches.\" The bank also violated the Bank Secrecy Act (BSA) and 12 CFR part 9 - fiduciary activities of national banks.","res":"Order","sd":"City National Bank paid the penalty to the U.S. Treasury.","sm":"Without admitting or denying the findings, the bank consented to the entry of the order instituting cease-and-desist proceedings and imposing a cease and desist order. No information Filed","ab":"City National Bank","firms":[117198],"id":550},{"d":"2024-01-30","di":"2024-01-30","k":"Regulatory Action","dk":"118067-SR","ab":"Reid, Wayne, Dale","firms":[7691],"id":551},{"d":"2024-01-30","dr":"2024-01-30","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":89000.0,"dk":"NONE","al":"On January 30, 2024, Arrowstreet was fined KRW 118,500,000 (approximately $89,000) by the Securities and Futures Commission of Korea. The fine was paid on February 6, 2024. The fine was levied in connection with a single trade placed in May 2021 on behalf of a client's separate account to sell long shares of a korean-listed security. At the time the trade was placed, a portion of the client's shares that were to be sold long were on loan through the client's securities lending program. The client participated in a securities lending program operated by a third party agent unaffiliated with Arrowstreet. Arrowstreet was not responsible for directing, operating or supervising the account's securities lending or recall activity. Arrowstreet communicated the execution of the sell long trade in a timely manner, and while the trade settled on the intended settlement date, settlement was delayed intraday. The korean regulator determined that because a portion of the client's shares were on loan at the time the trade was placed and were not timely recalled, the client was deemed not to own the shares and, therefore, the transaction constituted a naked short sale in violation of korean short sale regulations","res":"Decision","ab":"Arrowstreet Capital, Limited Partnership","self":true,"firms":[111298],"id":552},{"d":"2024-01-25","di":"2024-01-24","dr":"2024-01-25","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":47000.0,"dk":"STAR NO. 201906349955-02/FILE NO. URE-98-06","al":"Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), submitted letters of consent and letters of acceptance, waiver, and consent (collectively, \"letters\"), which were accepted to enter settlements with FINRA and 13 exchanges. Gsco neither admitted nor denied the findings in the letters, and consented to the sanctions and entry of findings that its supervisory system was not reasonably designed to identify potentially manipulative trading activity. Specifically, FINRA and the 13 exchanges found that gsco failed to include warrants, rights, units, and certain over-the-counter (\"OTC\") equity securities in certain surveillance reports designed to identify potentially manipulative proprietary and customer trading. These securities were excluded for extended periods ranging from approximately two years to more than 12 years, between 2009 and 2023. The firm's supervisory system did not require a review of its automated surveillance reports, and as a result, gsco failed to detect these deficiencies. Gsco completed remediation for all surveillance reports, and also implemented reviews to identify if any security was inadvertently excluded from new or modified surveillance reports.","res":"Consent","sm":"The firm was censured and fined a total amount of $512,500 by FINRA and the 13 exchanges, allocated as follows: $37,000 by FINRA; $47,000 by CBOE Byx Exchange, Inc.; $47,000 by CBOE BZX exchange, inc.; $47,000 by CBOE edga exchange, inc.; $47,000 by CBOE edgx exchange, inc.; $20,000 by investors exchange LLC; $37,000 by the Nasdaq stock market LLC; $37,000 by Nasdaq BX, inc.; $37,000 by Nasdaq PHLX LLC; $37,000 by the New York Stock Exchange LLC; $37,000 by NYSE american; $37,000 by NYSE ARCA, inc.; $37,000 by NYSE chicago, inc.; and $8,500 by NYSE national, inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":553},{"d":"2024-01-22","di":"2024-01-22","dr":"2024-01-22","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":59030.0,"dk":"REF. NO DSA-2024-01-0136AA-DSA-L-BA","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for non-compliance with the mandatory credit allocation for agriculture, fisheries and rural development (AFRD) for the quarters ended 9-30-2022 through 12-31-2022.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP3,309,740.78 (approximately USD59,030) on bana. The payment will be made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":554},{"d":"2024-01-20","di":"2024-01-20","dr":"2024-01-20","k":"Regulatory Action","rg":"Other","reg":"Washington Dept. of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"S-23-3590-23-CO01","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Washington and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Washington customers in an amount of no less than $112,506.29. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of RCW 21.20.110(1)(j).","ab":"Raymond James Financial","firms":[705],"id":555},{"d":"2024-01-19","di":"2024-01-19","dr":"2024-01-19","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Other","os":"Settlement","st":"Final","fine":25000.0,"dk":"23-CH-2313","al":"RBC Capital Markets, LLC violated CME rules 930.E.1. And 930.K.1.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":556},{"d":"2024-01-19","di":"2021-08-06","dr":"2024-01-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":100000.0,"dk":"2021071489101","al":"On January 19, 2024, the firm entered into a letter of acceptance, waiver and consent for failing to disclose certain mark-up and mark-down information on retail customer confirmations for the time period June 2020 to August 2021 for municipal securities transactions and corporate and agency debt securities transactions and for failing to establish, maintain, and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with the disclosure requirements in violation of MSRB rule G-27 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Rockefeller Financial LLC","self":true,"firms":[291361],"id":557},{"d":"2024-01-18","di":"2024-01-18","dr":"2024-01-18","k":"Regulatory Action","rg":"Other","reg":"Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"2023-21","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Maine and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Maine customers in an amount of no less than $58,042.65. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of Maine uniform Securities Act and Maine Office of Securities rules.","ab":"Raymond James Financial","firms":[705],"id":558},{"d":"2024-01-17","di":"2024-01-17","dr":"2024-01-17","k":"Regulatory Action","rg":"Other","reg":"Nebraska Dept. of Banking and Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Nebraska and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Nebraska customers in an amount of no less than $68,675.63. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of neb. Rev. Stat. § 8­1103(9)(a)(XI) (reissue 2022).","ab":"Raymond James Financial","firms":[705],"id":559},{"d":"2024-01-16","di":"2024-01-16","dr":"2024-01-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":18000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21829","al":"On January 16, 2024, J.P. Morgan Securities LLC (\"JPMS\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). JPMS consented to the entry of the order, which found that JPMS willfully violated rule 21F-17(a) under the Securities Exchange Act of 1934 (the \"Exchange Act\"). The order arose out of JPMS, from 2020 through July 2023, asking certain clients and customers to whom it had issued a credit or settlement over $1000 in value to sign a confidential release agreement that required the clients to keep confidential the release agreement and all information relating to the specified account at JPMS. The confidential release agreement neither prohibited nor restricted clients from responding to any inquiry about the confidential release agreement or its underlying facts from FINRA, the SEC, or any other government entity or self-regulatory organization, or as required by law, but did not permit voluntary communications with such regulators.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":560},{"d":"2024-01-16","di":"2024-01-16","dr":"2024-01-16","k":"Regulatory Action","rg":"Other","reg":"Oregon Dept. of Consumer and Business Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"S-23-0045","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Oregon and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Oregon customers in an amount of no less than $109,349.94. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"The firm neither admitted nor denied the statement of facts and violation of ors 59.205(13), and oar 441-205-0210(1).","ab":"Raymond James Financial","firms":[705],"id":561},{"d":"2024-01-12","di":"2024-01-12","dr":"2024-01-12","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement to comply with section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972.","st":"Final","fine":300000.0,"dk":"240001 (SEC-CAO)","al":"The Pennsylvania Department of Banking and Securities (the \"department\") alleged that from in or about January 2015 through the present, Edward jones failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972, 70 P.S. § 1­301(C.1)(1)(II).","res":"Consent","sm":"In the fall of 2023, Edward jones identified a historical compliance deficiency in connection with the Pennsylvania investment adviser representative registration requirement and self-reported the same to the Pennsylvania Department of Banking and Securities (\"the department\"). On January 12, 2024, Edward jones and the department entered into a consent order (\"the order\"). The department alleged that from in or about January 2015 through the present, Edward jones failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972 (\"the 1972 act\"), 70 P.S. § 1­301(C.1)(1)(II). Without admitting or denying the findings in the order, Edward jones agreed to pay a monetary fine of $300,000 and to comply with the relevant provision of the 1972 act.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":562},{"d":"2024-01-11","di":"2024-01-11","dr":"2024-01-11","k":"Regulatory Action","rg":"Other","reg":"Hawaii Dept. of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"SEB20230057","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Hawaii and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Hawaii customers in an amount of no less than $50,418.64. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of har section 16-39-470(b)(9) and HRS section 485A-412(d)(9).","ab":"Raymond James Financial","firms":[705],"id":563},{"d":"2024-01-05","di":"2024-01-05","dr":"2024-01-05","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"\"Fine : KRW 80 mil / usd 54,329 (exchange rate 1472.5) warning, voluntary corrective measures on its employee\"","st":"Final","fine":54329.0,"al":"\"Financial services commission (FSC) alleged that Samsung Life Insurance co. LTD. violated: - its obligation to comply with the principles of calculating insurance rates and the standards for managing underlying documentation. - The senior actuary's obligation to validate rates.\"","res":"Decision & Order of Offer of Settlement","sd":"Warning to its employee and voluntary corrective measure","sm":"On January 5, 2024, the FSC issued a notice of its decision, finding that Samsung Life Insurance co. LTD was liable for the allegations listed in our answers to question 7. As a result, FSC imposed a fine of KRW 80 mil in aggregate, issued a warning to its employee, and ordered voluntary corrective measures.","ab":"Samsung Life Insurance","firms":[158319],"id":564},{"d":"2024-01-04","di":"2024-01-04","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (Sebi)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":23193.36,"al":"Sebi has issued a show cause notice dated January 4, 2024, under rule 4 of sebi (procedure for holding inquiry and imposing penalties) rules, 1995 to one of the key employees of the amc in a matter pertaining to his past employer and along with others, alleging violation of sebi regulations.","res":"Consent","ab":"Gupta, Abhishek, Mukesh","firms":[324468],"id":565},{"d":"2024-01-03","di":"2024-01-03","dr":"2024-01-03","k":"Regulatory Action","rg":"Other","reg":"Ohio Dept. of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"24-001","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Ohio and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Ohio customers in an amount of no less than $346,111.83. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of Ohio revised code 1707.19(a) (1)(I).","ab":"Raymond James Financial","firms":[705],"id":566},{"d":"2023-12-29","di":"2023-12-29","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"A former employee of another company that I own, which is not involved in the securities industry, pleaded guilty to orchestrating a ponzi scheme. See U.S. v. bossetti, 2:25-CR-00066 (S.D. Ohio). I was not charged in connection with the ponzi scheme by the prosecutors, and I cooperated with their investigation and provided them all relevant documentation. I have not been charged civilly by any regulator in connection with the ponzi scheme. Neither I nor my company received any funds from ponzi scheme investments, made any payments to investors in connection with the ponzi scheme, or received any commissions, compensation or other financial benefit from the ponzi scheme whatsoever. Nevertheless, we have been sued by investors in the ponzi scheme in two separate civil actions pending in Ohio state court. The allegations in those cases, generally speaking, are that my company and I are responsible for investment losses for various reasons, including negligent supervision and as a de- facto partnership. I have denied all liability in the matter, because I was not involved in the ponzi scheme.","ab":"Sekinger, Jeffrey, ronald","firms":[305225],"id":567},{"d":"2023-12-27","di":"2023-12-27","dr":"2023-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":5500000.0,"dk":"2017052494701","al":"The Financial Industry Regulatory Authority (FINRA) alleged that LPL Financial LLC (the firm) failed to supervise the activities of its representatives that was reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to transactions its representatives placed directly with product sponsors (direct business transactions) on behalf of firm customers, in violation of FINRA rules 3110, 4511 and 2010, NASD rule 3010(a), section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and Exchange Act rules 15I-1 and 17A-3. The findings stated that from January 2012 to August 2019, the firm did not have a reasonable system to ensure direct business transactions appeared on the daily trade blotter in order for those transactions to be ingested into the firm's exception reports to identify potential sales practice violations and that its representatives collected relevant information regarding direct business customers' investment profiles for making suitability determinations. In addition, the findings stated that from February 2016 through June 2020, the firm sent to certain customers switch letters that contained inaccurate information about sales charges associated with switching from one security to another and a certain supervisory tool utilized in reviewing the suitability of switch transactions did not include sales charge information for certain products. The findings also stated that from May 2017 to November 2022, an electronic tool utilized by supervisors in the review of transactions in listed business development companies (BDCS) did not reasonably alert supervisors of potentially overconcentrated investments in listed BDCS to certain customers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm consented to the imposition of a censure, a monetary fine in the amount of $5,500,000, payment of customer restitution in the amount of $651,374.51, plus interest, and an undertaking related to the issues contained in the AWC involving listed BDCS","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":568},{"d":"2023-12-22","di":"2023-12-22","dr":"2023-12-22","k":"Regulatory Action","rg":"Other","reg":"Delaware Dept. of Justice, Investor Protection Unit","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"23-0173","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Delaware and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Delaware customers in an amount of no less than $26,611.99. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of Delaware Securities Act 73- 304(a)(10).","ab":"Raymond James Financial","firms":[705],"id":569},{"d":"2023-12-21","di":"2023-12-21","dr":"2023-12-21","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"IC23-CAF-08","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Texas and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Texas customers in an amount of no less than $726,447.46. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of Texas board rule section 115.10.","ab":"Raymond James Financial","firms":[705],"id":570},{"d":"2023-12-20","di":"2023-12-20","dr":"2023-12-20","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"N/A","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to New Jersey and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain New Jersey customers in an amount of no less than $241,814.73. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of N.J.S.A. 49:3-58(a)(2)(XI).","ab":"Raymond James Financial","firms":[705],"id":571},{"d":"2023-12-19","di":"2023-12-19","dr":"2023-12-19","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Dept. of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"SB-CO-10-23","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to District of Columbia and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain D.C. Customers in an amount of no less than $16,292.51. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of D.C. Official code SEC.31- 5602.07(a)(12).","ab":"Raymond James Financial","firms":[705],"id":572},{"d":"2023-12-18","di":"2023-12-18","dr":"2023-12-18","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"INV-2023-000024","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to New Hampshire and, in total, $4,200,000 to participating states. In addition to the administratinew hampshire customers in an amount of no less than $39,303.73. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of rsa 421-b:4-412(d)(9).","ab":"Raymond James Financial","firms":[705],"id":573},{"d":"2023-12-16","di":"2023-12-16","dr":"2023-12-16","k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"al":"New York Life Insurance company failed to use policy forms that were reviewed and approved by the state. In addition, certain forms did not comply with state regulations.","res":"Consent","sd":"New York life agreed to a consent order from the state and paid a fine of $100,000 related to use of forms in the state which were not approved by or did not comply with state regulations. In addition to paying the fine of $100,000 on 12/22/2023, nyl is also amending forms and agreement and resubmitting them to the state to comply with the appropriate regulations.","ab":"New York Life Insurance","firms":[107717,169553,173355,340676],"id":574},{"d":"2023-12-16","di":"2023-12-16","dr":"2023-12-16","k":"Regulatory Action","rg":"Other","reg":"Louisiana Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"al":"Nylic failed to use policy forms that were reviewed and approved by the state. In addition, certain forms did not comply with state regulations.","res":"Order","sd":"Nylic agreed to a consent order from the state and paid a fine of $100,000 related to use of forms in the state which were not approved by or did not comply with state regulations. In addition to paying the fine of $100,000 on 12/22/2023, nylic is also amending forms and agreement and resubmitting them to the state to comply with the appropriate regulations.","ab":"New York Life Insurance","firms":[309234],"id":575},{"d":"2023-12-14","di":"2023-12-14","dr":"2023-12-14","k":"Regulatory Action","rg":"Other","reg":"Minnesota Dept. of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"81981","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Minnesota and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Minnesota customers in an amount of no less than $117,577.70. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of minn. Stat. § 80A.67(d)(9).","ab":"Raymond James Financial","firms":[705],"id":576},{"d":"2023-12-13","di":"2023-12-13","dr":"2023-12-13","k":"Regulatory Action","rg":"Other","reg":"South Dakota Dept. of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"1019068","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to South Dakota and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain South Dakota customers in an amount of no less than $29,136.11. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of SDCL 47-31B-412(d)(9).","ab":"Raymond James Financial","firms":[705],"id":577},{"d":"2023-12-11","di":"2023-12-07","dr":"2023-12-11","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"CME 22-1622-BC","al":"CME Group (\"CME\") found that Deutsche Bank AG London branch (\"dbag London\"), in violation of CME rule 534, operated an automated trading system that entered multiple opposing buy and sell orders for the same account in June 2022 new zealand dollars futures noninverted CME FX link spreads, swiss franc futures inverted CME FX link spreads, and euro FX futures non- inverted CME FX link spreads. These orders then traded opposite each other in the same dbag London account causing self- matching to occur on more than an incidental basis. CME also found that dbag London reasonably should have known that entering orders in the manner it did would achieve a wash result.","res":"Consent","sm":"On December 11, 2023, dbag London entered into a settlement with CME, in which CME found that DB AG London, in violation of CME rule 534, operated an automated trading system that entered multiple opposing buy and sell orders for the same account in June 2022 new zealand dollars futures noninverted CME FX link spreads, swiss franc futures inverted CME FX link spreads, and euro FX futures non-inverted CME FX link spreads. These orders then traded opposite each other in the same dbag London account causing self-matching to occur on more than an incidental basis. CME also found that dbag London reasonably should have known that entering orders in the manner it did would achieve a wash result. Dbag London did not admit or deny the rule violation or factual findings in the settlement, and agreed to a fine of $70,000, which will be timley paid.","ab":"Deutsche Bank AG London","firms":[300838],"id":578},{"d":"2023-11-30","di":"2023-11-13","dr":"2023-11-30","k":"Regulatory Action","rg":"Other","reg":"Reserve Bank of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":120.0,"dk":"CO.FED.EPD.NO. 21.53.003/2023-2024","al":"The Reserve Bank of India (RBI) issued a speaking order and imposed a monetary penalty against Bank of America, National association (BANA) for allegedly contravening instructions issued to ad banks vide A.P. (Dir series) circular no. 23 dated April 12, 2018 by failing to upload certain information related to transactions undertaken under the liberalised remittance scheme.","res":"Order","sm":"Rbi imposed a fine in the amount of INR10,000 (approximately USD120) on bana. The fine was paid as directed.","ab":"Bank of America, National","firms":[7691],"id":579},{"d":"2023-11-28","di":"2023-11-28","dr":"2023-11-28","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Dept. of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"24-014","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of Oklahoma section 1-411(d) (9).","ab":"Raymond James Financial","firms":[705],"id":580},{"d":"2023-11-28","di":"2023-11-28","dr":"2023-11-28","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Cease and Desist","st":"Final","fine":12000000.0,"dk":"FILE NO. 2023-CFPB-0016","al":"The Consumer Financial Protection Bureau (\"CFPB\") alleged that Bank of America, National association (the firm) failed to accurately collect, record, and report information on mortgage loan applicants' race, ethnicity, and sex, in violation of section 2803 of the home mortgage disclosure act (\"HDMA\"), regulation c, 12 C.F.R. §§ 1003.4, 1003.5, and section 1036(a)(1)(a) of the Consumer financial protection act of 2010 (\"CFPA\"), 12 U.S.C. § 5536(a)(1)(a).","res":"Consent","sm":"Without admitting or denying the findings of fact or conclusions of law, the firm consented to (1) the entry of the consent order, (2) not violate the hmda, 12 U.S.C. §§ 2801­2810, and regulation c, 12 C.F.R. PT. 1003, (3) certain undertakings, and (4) pay a civil monetary penalty in the amount of $12,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bank of America, National","firms":[7691],"id":581},{"d":"2023-11-22","di":"2023-11-22","dr":"2023-11-22","k":"Regulatory Action","rg":"Other","reg":"European Commission","st":"Final","dk":"AT.40512","al":"The European Commission (\"commission\") found that DBAG (\"DBAG\") and another European bank took part in anticompetitive conduct relating to the secondary trading market within the European economic area of euro-denominated supra-sovereign, sovereign and agency (\"SSA\") and government guaranteed bonds. In particular, the commission found that from 2006 to 2016, certain DBAG traders participated in collusive conduct with traders at the other bank by coordinating on prices of the relevant bonds quoted to clients, in violation of European union rules prohibting anticompetitive business practives. As a result of its proactive cooperation with the commission and pursuant to the commission's 2006 leniency notice, DBAG was granted full immunity relating to the infringements described in the decision.","res":"Decision","sm":"On November 22, 2023, the commission issued a decision finding that dbag and another European bank took part in anticompetitive conduct relating to the secondary trading market within the European economic area of euro-denominated supra-sovereign, sovereign and agency (\"SSA\") and government guaranteed bonds. In particular, the commission found that from 2006 to 2016, certain dbag traders participated in collusive conduct with traders at the other bank by coordinating on prices of the relevant bonds quoted to clients, in violation of European union rules prohibiting anticompetitive business practives. As a result of its proactive cooperation with the commission and pursuant to the commission's 2006 leniency notice, dbag was granted full immunity relating to the infringements described in the decision.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":582},{"d":"2023-11-17","di":"2023-11-17","dr":"2023-11-17","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"23-0064","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of West Virginia code section 32-2-204(a)(j).","ab":"Raymond James Financial","firms":[705],"id":583},{"d":"2023-11-16","di":"2023-11-16","dr":"2023-11-16","k":"Regulatory Action","rg":"State regulator","reg":"Montana State Auditor, Commissioner of Securities and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"SEC-2023-00197","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of Montana code ann. § 30­10­ 201(13)(k).","ab":"Raymond James Financial","firms":[705],"id":584},{"d":"2023-11-16","di":"2023-11-16","dr":"2023-11-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":400000.0,"dk":"2023077632501","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that, from August 2020 to October 2022, it failed to deliver prospectuses to customers electing paper delivery in connection with 166,104 sales of 65 exchange-traded funds, in violation of FINRA rule 2010, and failed to establish and maintain a supervisory system reasonably designed to monitor and confirm the delivery of prospectuses to customers, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On November 16, 2023, the firm became subject to a letter of acceptance, waiver and consent issued by FINRA regarding allegations that, from August 2020 to October 2022, it failed to deliver prospectuses to customers electing paper delivery in connection with 166,104 sales of 65 exchange-traded funds, in violation of FINRA rule 2010, and failed to establish and maintain a supervisory system reasonably designed to monitor and confirm delivery of prospectuses to customers, in violation of FINRA rules 3110 and 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and fine in the amount of $400,000. FINRA credited the firm for its extraordinary cooperation in the matter and the firm paid the fine in accordance with the terms of the AWC.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":585},{"d":"2023-11-09","di":"2023-11-09","dr":"2023-11-09","k":"Regulatory Action","rg":"Other","reg":"ICE Futures Europe","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":738422.0,"dk":"23/172","al":"ICE Futures Europe (the \"exchange\") alleged that Citigroup Global Markets, inc. (the \"firm\") did not comply with exchange rules C.4, G.17.5, and P.2(a)(II) by reporting inaccurate client positions to the exchange and ICE clear europe through its large trader and gross customer margin reports. The exchange also alleged that the firm did not have adequate systems and controls in place to ensure accurate position reporting in violation of exchange rules A.11.1(a)(b) and (d) and B.3C(b).","res":"Other","sm":"The firm agreed to the entry of findings and to pay a fine in the amount of GBP 584,500 (approximately usd 738,422). The fine amount was decreased from GBP 835,000 (approximately usd 1,054,889) to GBP 584,500 for early settlement. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":586},{"d":"2023-11-07","di":"2023-11-07","dr":"2023-11-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":519646.23,"dk":"2020068655201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies. The findings stated that the firm's system that provided customers with rights of reinstatement benefits on eligible transactions was not reasonably designed in two basic respects. First, the firm's oversight of discounts available through rights of reinstatement relied on an automated alert that was designed primarily to monitor for mutual fund switches that occurred within 90 days of a prior sale. Thus, the alert was not designed to, and did not, capture all transactions eligible for reinstatement privileges because many funds' reinstatement periods exceeded 90 days. Second, the firm relied on an ineffective review of these alerts-based on a manual review of random samples-to supervise and confirm whether the firm credited eligible customers with reinstatement privileges. As a result of its supervisory deficiencies, baird did not provide accounts with rights of reinstatement benefits to which they were entitled, and customers paid $519,646.23 in excess sales charges and fees. The firm has since enhanced its supervisory system.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm paid $519,646.23 in restitution to customers prior to the effective date of this AWC.","sm":"Upon receipt of FINRA's sweep inquiry in 2021, baird conducted an internal review to identify potentially disadvantaged customers and calculated a remediation amount, voluntarily extending the review period beyond FINRA's requested date. Prior to resolving the matter with FINRA, baird proactively remediated 2,300 customers a total of $519,646.23, plus interest, for an average amount of impact per customer of approximately $225.00. Baird also enhanced its supervisory system, including by creating and implementing new exception reports designed specifically to identify missed rights of reinstatement. These enhancements also automated the previously manual review.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":587},{"d":"2023-11-03","di":"2023-11-03","k":"Regulatory Action","rg":"Other","reg":"Vermont Dept. of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"23-017-S","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Vermont and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Vermont customers in an amount of no less than $28,198.46. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of V.S.R. SEC. 2-2(b)(2).","ab":"Raymond James Financial","firms":[705],"id":588},{"d":"2023-11-03","di":"2023-04-17","dr":"2023-11-03","k":"Regulatory Action","rg":"Other","reg":"Financial Services Commission (\"FSC\") (South Korea)","san":"Other","os":"Administrative penalty","st":"Final","fine":200000.0,"al":"Rockefeller & co LLC was fined by the south korean financial services commission (\"FSC\") for the violation of korean short selling restriction under article 180 (1) of the financial investment services and capital markets act. Trade error resulted in an inadvertent short position and promptly covered the next trading day.","res":"Consent","sd":"Rockefeller & co LLC will resolve the matter through the payment of KRW 290,100,000 (approximately $200,000).","ab":"Rockefeller & Co. LLC; Rockefeller Capital","self":true,"firms":[291361,294197],"id":589},{"d":"2023-11-02","di":"2023-11-02","dr":"2023-11-02","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":900000.0,"dk":"2023-002","al":"The ICE Futures U.S. (\"IFUS\") business conduct COMMITTEE (\"COMMITTEE\") alleged that, from at least 2015 through the beginning of November 2022, Citigroup Global Markets, inc. (\"the firm\") may have violated IFUS rules 2.12 and 6.15(a) by misreporting open interest and large trader positions. IFUS also alleged that cgmi may have violated IFUS rule 4.01(a) and (b) by failing to diligently supervise the IFUS-related activities of its employees and failing to establish, administer, and enforce supervisory systems, policies, and procedures that are reasonably designed to ensure compliance with IFUS rules.","res":"Other","sm":"Without admitting or denying the rule violations, the firm agreed to pay a $900,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":590},{"d":"2023-11-02","di":"2023-11-02","dr":"2023-11-02","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"It was ordered that the firm cease and desist from committing or causing any violations and any future violations of sections","st":"Final","fine":6000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21792","al":"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.","res":"Decision & Order of Offer of Settlement","sm":"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.","ab":"Royal Bank of Canada; Royal Bank of Candada","firms":[31194,117198],"id":591},{"d":"2023-10-31","di":"2023-10-31","dr":"2023-10-31","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings","st":"Final","fine":75000.0,"dk":"2023-CDS-020","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of § 11­51­410(1)(I), C.R.S.","ab":"Raymond James Financial","firms":[705],"id":592},{"d":"2023-10-24","di":"2023-10-24","k":"Regulatory Action","dk":"2023-0243-S","ab":"Culpepper, Ryan","firms":[7691],"id":593},{"d":"2023-10-24","di":"2020-03-02","dr":"2023-10-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"BlackRock Advisors, LLC (\"BAL\") is to: a) pay a $2.5 million civil money penalty; b) cease and desist from committing or causing any violations and any future","st":"Final","fine":2500000.0,"dk":"3-21786","al":"On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC (\"BAL\") to settle findings relating to misstatements in annual and semi-annual reports of a mutual fund for which BAL serves as the registered investment adviser. The SEC found that the reports inaccurately described the interest rate and industry classification of a lending facility with a privately held entity in which the mutual fund invested. Without admitting or denying the SEC's findings, BAL agreed to the entry of an administrative order containing findings that BAL violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder and section 34(b) of the Investment Company Act of 1940.","res":"Settled","sd":"On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC (\"BAL\") to settle findings relating to misstatements in annual and semi- annual reports of a mutual fund for which BAL serves as the registered investment adviser. The SEC found that the reports inaccurately described the interest rate and industry classification of a lending facility with a privately held entity in which the mutual fund invested. Without admitting or denying the SEC's findings, BAL agreed to the entry of an administrative order containing findings that BAL violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder and section 34(b) of the Investment Company Act of 1940. BAL paid the $2.5 million civil money penalty on October 30, 2023. BAL does not expect the resolution of this matter to have a material adverse effect on its financial results or operations.","sm":"On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC (\"BAL\") to settle findings relating to misstatements in annual and semi-annual reports of a mutual fund for which BAL serves as the registered investment adviser. The SEC found that the reports inaccurately described the interest rate and industry classification of a lending facility with a privately held entity in which the mutual fund invested. Without admitting or denying the SEC's findings, BAL agreed to the entry of an administrative order containing findings that BAL violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder and section 34(8) of the Investment Company Act of 1940. BAL paid the $2.5 million civil money penalty on October 30, 2023. BAL does not expect the resolution of this matter to have a material adverse effect on its financial results or operations.","ab":"BlackRock Advisors, LLC","firms":[106614,107105,290336],"id":594},{"d":"2023-10-18","di":"2023-10-18","dr":"2023-10-18","k":"Regulatory Action","rg":"Other","reg":"Wisconsin Dept. of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"S-248331 (LX)","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation wi admin code dfi-SEC. 4.05(2).","ab":"Raymond James Financial","firms":[705],"id":595},{"d":"2023-10-17","di":"2023-10-17","dr":"2023-10-17","k":"Regulatory Action","rg":"State regulator","reg":"South Carolina Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"20232794","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to South Carolina and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain South Carolina customers in an amount of no less than $178,212.19. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of South Carolina code ann. Section 35-1-412(d)(9).","ab":"Raymond James Financial","firms":[705],"id":596},{"d":"2023-10-17","di":"2023-10-17","dr":"2023-10-17","k":"Regulatory Action","rg":"Other","reg":"National Stock Exchange of India Limited","san":"Other","os":"Monetary fine","st":"Final","fine":6502.0,"dk":"NOT APPLICABLE","al":"Nse vide its invoice dated October 17, 2023, has levied penalty of RS.5,41,850/- ($6502) as nse_MCSGFC committee-match and reversal of trade (vinod somani huf & beena somani).in one of the clients. Matter closed.","res":"Settled","ab":"JM Financial Services Limited","firms":[293667],"id":597},{"d":"2023-10-16","di":"2023-10-16","dr":"2023-10-16","k":"Regulatory Action","rg":"Other","reg":"Utah Dept. of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"SD-23-0027","al":"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.","res":"Consent","sd":"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.","sm":"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).","ab":"Raymond James Financial","firms":[705],"id":598},{"d":"2023-10-13","di":"2023-03-16","dr":"2023-10-13","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"23-CH-2312","al":"On October 12, 2023, the clearing house risk committee of the CME Group Inc. (\"CME\") determined that Goldman Sachs & co . LLC (\"GSCO\") violated CBOT rule 930. E.3 for not maintaining accurate written records for certain performance bond calls in 2022.","res":"Settled","sm":"Pursuant to an offer of settlement, in which gsco neither admitted nor denied the rule violation upon which the penalty is based, CME fined the firm $150,000 and agreed to waive the fine if no similar violation is found during the next risk based examination.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":599},{"d":"2023-10-13","di":"2023-10-13","dr":"2023-10-13","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Other","st":"Final","fine":50000.0,"dk":"23-CH-2322","al":"RBC Capital Markets, LLC neither admitted nor denied violating exchange rules, found the firm guilty of violating CME rule 980.a.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":600},{"d":"2023-10-11","di":"2023-10-11","dr":"2023-10-11","k":"Regulatory Action","rg":"Other","reg":"Puerto Rico Commissioner of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"N/A","al":"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.","res":"Consent","sd":"Raymond James & Associates, Inc. and Raymond James Financial services, inc. were ordered to pay an administrative fine of $75,000 to Puerto Rico and, in total, $4,200,000 to participating states. In addition to the administrative fine, restitution payments to certain Puerto Rico customers in an amount of no less than $2,388.73. Further, total restitution to participating states in an amount of no less than $8,383,167.46.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of prusa article 204(a)(2)(j) and regulation 6078, article 28, section 28.2.","ab":"Raymond James Financial","firms":[705],"id":601},{"d":"2023-10-09","di":"2023-09-20","dr":"2023-10-09","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"2022-009","al":"On September 20, 2023, a subcommittee of the ICE Futures U.S. business conduct committee (\"IFUS\") determined that Goldman Sachs & Co. LLC (\"GSCO\") may have violated exchange rules 6.15(a) and 4.01(b) by inaccurately reporting large trader positions in multiple instances between November 2021 and November 2022, and failing to implement supervisory systems, policies, and procedures designed to ensure compliance with exchange rules.","res":"Settled","sm":"Pursuant to an offer of settlement, in which gsco neither admitted nor denied the violations, gsco agreed to pay a monetary fine of $70,000. The fine was paid by submission of a wire on October 9, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":602},{"d":"2023-10-03","di":"2023-10-03","dr":"2023-10-03","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"S-23-0014","al":"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.","res":"Consent","sd":"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.","sm":"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).","ab":"Raymond James Financial","firms":[705],"id":603},{"d":"2023-10-03","di":"2023-10-03","dr":"2023-10-03","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Censure","os":"Compliance; administrative fine","st":"Final","fine":250000.0,"dk":"E-2022-0055","al":"Improper use of electronic signatures and failure to exercise appropriate supervision of an LPL branch office.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":604},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s)\"","st":"Final","fine":15000000.0,"dk":"CFTC DOCKET NO. 23-61","al":"On September 29, 2023, J.P. Morgan Securities LLC, JPMorgan Chase Bank, N.A., and J.P. Morgan Securities PLC (collectively, the \"respondents\") entered into a settlement with the Commodity Futures Trading Commission resulting in an administrative order (\"order\"). The respondents consented to the entry of the order, which found that they violated sections 2(a)(13) and 4r(a)(3) of the Commodity Exchange Act (\"CEA\") and CFTC regulations 43.3 and 45.3. The order found that from at least November 2017, respondents failed to report, or failed to correctly report, more than 40 million swap transactions.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"JPMorgan Chase Bank, N.A.","firms":[79],"id":605},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","st":"Final","fine":30000000.0,"dk":"23-59","al":"On September 29, 2023, the Commodity Futures Trading Commission (\"commission\" or \"CFTC\") issued an order against Goldman Sachs & Co. LLC (\"GSCO\"), accepting an offer of settlement submitted by GSCO, in which GSCO neither admitted nor denied the commission's findings. The CFTC found that from December 31, 2012 to the present, GSCO violated sections 2(a)(13)(f) and (g) and 4s(h)(1) of the Commodity Exchange Act (\"CEA\"), 7 U.S.C. §§ 2(a)(13)(f), (g), 6s(h)(1), and commission regulations 23.431(a)(3)(I), 23.602(a), 43.3(a)(1), 45.3(b)(1), 45.4(c), 45.6, 17 C.F.R. §§ 23.431(a)(3)(I), 23.602(a), 43.3(a)(1), 45.3(b)(1), 45.4(c), and 45.6 (2022) in connection with GSCO's alleged failure to report accurately and timely swap data, disclose certain PTMMMS in accordance with the CFTC's requirements, and supervise certain areas of its swap dealer business, including swap data reporting, pre-trade mid market marks (\"PTMMM\") disclosures, a personnel reporting line, clearing member risk management policy, notices regarding its initial margin model and to unsegregated clients, and disclosure of static material economic terms. GSCO has and continues to take remedial steps to address the deficiencies.","res":"Order","sm":"The CFTC ordered that gsco cease and desist from violating these provisions of the cea and commission regulations; comply with the conditions and undertakings enumerated in the offer; and pay a civil monetary penalty in the amount of $30,000,000. The fine was paid on October 5, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":606},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","st":"Final","fine":3000000.0,"dk":"23-60","al":"On September 29, 2023, the Commodity Futures Trading Commission (\"commission\" or \"CFTC\") issued an order against Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), accepting an offer of settlement submitted by gsco, in which gsco neither admitted nor denied the commission's findings. The CFTC found that gsco failed to maintain an adequate supervisory system with respect to disruptive trading, in violation of commission regulation 166.3, in connection with a single eight-minute trading episode from December 29, 2017. Additionally, the CFTC found that gsco reasonably should have known that the omission of information regarding the firm's control systems and their malfunction in connection with December 29, 2017 trading episode from a statement to the CFTC's division of enforcement was materially misleading, in violation of section 6(c)(2) of the Commodity Exchange Act.","res":"Order","sm":"The CFTC ordered that gsco cease and desist; comply with the conditions and undertakings enumerated in the offer; and pay a civil monetary penalty in the amount of $3,000,000. The fine was paid on October 5, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":607},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"Other","reg":"U.S. Securities & Exchange Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000000.0,"dk":"3-21764","al":"On September 29, 2023, William Blair & Company, L.L.C. And William Blair Investment management, LLC (collectively, William blair) entered into a settlement with the U.S. Securities & Exchange Commission (SEC) in connection with the agency's industry-wide investigation into the preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William blair to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant, following the format for all other recent electronic communications settlements. William blair cooperated with the government's inquiry and has already taken significant steps to further strengthen the firm's compliance environment as it relates to electronic communications.","res":"Order","sd":"The firm is ordered to cease and desist, is censured, shall pay a civil money fine of $10,000,000 jointly and severally, and shall comply withcertain undertakings.","ab":"William Blair Investment","firms":[1252],"id":608},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, undertaking","st":"Final","fine":8000000.0,"dk":"CFTC DOCKET NO. 23-58","al":"The Commodity Futures Trading Commission (\"CFTC\") entered into a settlement order (\"order\") with bank of america, N.A. (\"BANA\") and Merrill lynch international (\"mli\", and collectively with BANA, (\"BOFA\")). Settling an administrative action concerning BOFA's (a) failure to accurately report swap data in violation of section 2(a)(13)(f) and (g) of the Commodity Exchange Act (\"act\") and CFTC regulations (\"regulations\") 43.3, 45.3, 45.4, and 45.14 and (b) failure to diligently supervise the BANA and mli swap dealer businesses in violation of section 4s(h)(1)(b) of the act and regulation 23.602(a).","res":"Order","sm":"Bofa admitted to the facts in the settlement order, acknowledged their conduct violated the act and regulations and agreed to the following sanctions: (a) to cease and desist from violating sections 2(a)(13)(f) and (g) and 4s(h)(1)(b) of the act, and regulations 23.602(a), 43.3, 45.3, 45.4, and 45.14, (b) to pay a civil monetary penalty in the amount of $8,000,000, and (c) to comply with certain conditions and undertakings.","ab":"Bank of America, National","firms":[7691],"id":609},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":15000000.0,"dk":"3-21768","al":"The Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against Robert W. Baird & Co. Incorporated (\"respondent\" or \"baird\"). Respondent has submitted an OFFER of settlement (\"OFFER\") that the commission has determined to accept. The commission finds that the federal securities laws impose recordkeeping requirements on broker-dealers and registered investment. These proceedings arise out of the failure of baird employees throughout the firm, including at senior levels, to adhere to certain of these requirements and baird's own policies. Using their personal devices, these employees communicated both internally and externally by personal text messages (\"off-channel communications\"). From at least January 2019, baird employees sent and received off-channel communications that related to the business of the broker-dealer and registered investment adviser operated by baird. Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failure was firm-wide and involved employees at various levels of authority. As a result, baird violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder. Baird's supervisors, who were responsible for supervising junior employees, communicated off-channel using their personal devices. Baird's failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees within the meaning of section 15(b)(4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act. During the time period, baird received and responded to commission subpoenas for documents and/or records requests in numerous commission investigations. As a result, baird's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff uncovered baird's misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at broker dealers. Baird has initiated a review of its recordkeeping failures and begun a program of remediation. As a result of its conduct, from at least January 2019 through the date of this order, respondent willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder. Furthermore, baird failed to reasonably to supervise its employees with a view to preventing or detecting certain of its employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act.","res":"Order","sd":"The firm was ordered to cease and desist, is censured, shall pay a civil money penalty of $15,000,000, and shall comply with certain undertakings.","sm":"In September 2023, baird entered into an offer of settlement with the SEC (the \"settlement\"), in which it admitted that it violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder for failing to maintain records of certain business-related communications made by baird associates when they used their personal devices (\"off-channel communications\") and for failing to supervise its associates' business-related communications. The settlement was related to an SEC risk-based initiative, whereby the SEC investigated a large number of financial services firms to determine whether those firms were properly retaining business-related text and instant messages and other off-channel communications sent and received on employees' personal devices. Following the commencement of the SEC's initiative, baird cooperated with the SEC and conducted voluntary interviews of a sampling of baird supervisors to gather and review messages found on their personal devices. It was discovered that certain baird supervisors communicated off- channel using non-baird approved methods on their personal devices about baird's broker-dealer and investment adviser businesses. As part of the settlement, baird was censured and ordered to cease and desist from future violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder and to pay a civil monetary penalty of $15 million. In addition, baird agreed to certain undertakings, including retaining an independent compliance consultant to conduct a review of baird's policies and procedures, training, surveillance program, technology solutions and similar matters related to off-channel communications.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":610},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and cease and desist order.","st":"Final","fine":10000000.0,"dk":"FILE NO. 3-21775","al":"On September 29, 2023, the SEC issued a settled order finding that language in certain employment-related agreements used by d.","res":"Decision & Order of Offer of Settlement","sd":"Desco LP, without admitting or denying the findings, agreed to a censure, to cease and desist from committing or causing any violations and any future violations of rule 21F-17(a), and to pay a $10 million penalty.","sm":"The SEC entered an order on September 29, 2023 accepting the offer of settlement. Desco LP paid the penalty on October 3, 2023. No information Filed","ab":"D. E. Shaw & Co., L.P.","self":true,"firms":[108679],"id":611},{"d":"2023-09-29","di":"2023-09-29","dr":"2023-09-29","k":"Regulatory Action","san":"Cease and Desist","os":"Civil and administrative penalty/fine censure undertaking","st":"Final","fine":10000000.0,"dk":"3-21764","al":"From at least January 1, 2019 through the present, William Blair & Company, L.L.C.'S (\"William Blair & Company\") employees sent and received off-channel communications that related to the business of the broker-dealer and registered investment adviser, and William Blair Investment Management, LLC's (\"William blair\") employees sent and received off-channel communications that related to the business of the registered investment adviser including, with respect to the investment advisory business, off-channel communications related to recommendations made or proposed to be made and advice given or proposed to be given. Respondents did not maintain or preserve the substantial majority of these written communications. Respondents' failures included senior personnel at both William blair and William Blair & Company. As a result, William Blair & Company violated section 17(a) of the Exchange Act and rule 17A4(b)(4) and William blair and William Blair & Company violated section 204 of the Advisers Act and rule 204- 2(a)(7) thereunder.","res":"Order","sd":"$10000000","sm":"Within the space provided). On September 29, 2023, William Blair & Company and William blair entered into a settlement with the U.S. securities & exchange commission (SEC) in connection with the agency's industry-wide investigation into the preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William blair and William Blair & Company to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant, following the format for all other recent electronic communications settlements. William blair and William Blair & Company cooperated with the government's inquiry and have already taken significant steps to further strengthen the firm's compliance environment as it relates to electronic communications. No information Filed","ab":"William Blair & Company","firms":[173961],"id":612},{"d":"2023-09-28","di":"2023-09-28","dr":"2023-09-28","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":1975000.0,"dk":"FILE NO. 3-21753","al":"The Securities and Exchange Commission alleged that from June 30, 2020 to at least March 2021, Citigroup Global Markets Inc. (\"CGMI\") and Citi international financial services, LLC, now known as INSIGNEO international financial services, LLC (\"INSIGNEO\"), made securities recommendation to retail customers without complying with the disclosure requirements under Regulation Best Interest or the requirement to deliver the form client relationship summary, in willful violation of section 17(a)(1) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rules 15L-1(a)(1) and 17A-14(f)(3) thereunder.","res":"Order","sm":"Without admitting or denying the findings, Citi and insigneo agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a)(1) of the Exchange Act and rules 15L-1 and 17A-14 thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $1,975,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":613},{"d":"2023-09-27","di":"2023-09-27","dr":"2023-09-27","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"23-0014CA","al":"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.","res":"Consent","sd":"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.","sm":"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.","ab":"Raymond James Financial","firms":[705],"id":614},{"d":"2023-09-26","di":"2023-09-26","dr":"2023-09-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement","st":"Final","fine":833334.0,"dk":"NO. 2020066141101","al":"The financial industry regulation authority (\"FINRA\") alleged that Citigroup Global Markets, inc. (\"the firm\") over-tendered shares in 13 partial tender offers from November 2017 through August 2022, in violation of rule 14E-4 of the Securities Exchange Act of 1934 (\"Exchange Act\") and FINRA rule 2010, and failed to have a supervisory system or written supervisory procedures reasonably designed to achieve compliance with Exchange Act rule 14E-4 from November 2017 through December 2020, in violation of FINRA rules 3110(a) and (b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm entered an AWC under which it agreed to be censured, pay a $2.5 million fine, of which $833,334 was payable to FINRA, and pay disgorgement in the amount of $5,771,489, of which $1,923,829 was payable to FINRA. The fine was paid in accordance with the terms of the AWC. The AWC simultaneously resolved similar matters brought by NYSE ARCA, inc. and NYSE american LLC and the remainder of the fine and disgorgement was allocated between NYSE ARCA, inc. and NYSE american LLC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":615},{"d":"2023-09-26","di":"2023-05-26","dr":"2023-09-26","k":"Regulatory Action","rg":"Other","reg":"Korean Securities and Futures Commission (\"SFC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":165000.0,"al":"Allegation that on May 4, 2021, Point72 Hong Kong Limited placed an order to short sell shares of Korean-listed securities without corresponding ownership of the positions.","res":"Order","sd":"The Korean Securities and Futures Commission (\"SFC\") issued a fine of KRW 218,500,000 (~US$165,000) on September 4, 2023. A wire payment to satisfy such fine was initiated on September 26, 2023.","sm":"On May 26, 2023, Point72 Hong Kong Limited (\"Point72 Hong Kong\") received a notice from the Korean financial supervisory service (\"FSS\") with respect to a trade made by Point72 Hong Kong on May 4, 2021 that resulted in an uncovered short position in a company listed on the Korean exchange (the \"KRX\"). The creation of an uncovered short position was a one-off incident caused by human error by a Point72 Hong Kong trader. The uncovered short position was quickly remediated and reported to the executing broker who reported the matter to the KRX. The FSS's notice specified that a fine of KRW 218,500,000 (~ US$165,000) would be imposed, subject to the further consideration of the Korean capital market investigation and review committee, and securities and futures commission (\"SFC\"). Upon review, the SFC determined to issue the KRW 218,500,000 (~ US$165,000) fine on September 4, 2023, which, subject to Point72 Hong Kong's right to appeal, would be due by no later than November 8, 2023. In resolution of this matter, a wire payment to satisfy such fine was initiated on September 26, 2023. No information Filed","ab":"Point72 Hong Kong Limited","firms":[283077],"id":616},{"d":"2023-09-25","di":"2023-09-25","dr":"2023-09-25","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement","st":"Final","fine":833333.0,"dk":"NO. 2020066141103","al":"NYSE ARCA, Inc. (\"NYSE ARCA\") alleged that Citigroup Global Markets, inc. (\"the firm\") over-tendered shares in 13 partial tender offers from November 2017 through August 2022, in violation of rule 14E-4 of the Securities Exchange Act of 1934 (\"Exchange Act\"), and failed to have a supervisory system or written supervisory procedures reasonably designed to achieve compliance with Exchange Act rule 14E-4 from November 2017 through December 2020, in violation of NYSE ARCA rule 11.18(b) and (c).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm entered an AWC under which it agreed to be censured, pay a $2.5 million fine, of which $833,333 was payable to NYSE ARCA, and pay disgorgement in the amount of $5,771,489, of which $1,923,829 was payable to NYSE ARCA. The fine was paid in accordance with the terms of the AWC. The AWC simultaneously resolved similar matters brought by FINRA and NYSE american LLC and the remainder of the fine and disgorgement was allocated between FINRA and NYSE american LLC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":617},{"d":"2023-09-25","di":"2023-09-25","dr":"2023-09-25","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement","st":"Final","fine":833333.0,"dk":"NO. 2020066141102","al":"NYSE American LLC (\"NYSE American\") alleged that Citigroup Global Markets, inc. (\"the firm\") over-tendered shares in 13 partial tender offers from November 2017 through August 2022, in violation of rule 14E-4 of the Securities Exchange Act of 1934 (\"Exchange Act\"), and failed to have a supervisory system or written supervisory procedures reasonably designed to achieve compliance with Exchange Act rule 14E-4 from November 2017 through December 2020, in violation of NYSE American rule 320.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm entered an AWC under which it agreed to be censured, pay a $2.5 million fine, of which $833,333 was payable to NYSE American, and pay disgorgement in the amount of $5,771,489, of which $1,923,829 was payable to NYSE American. The fine was paid in accordance with the terms of the AWC. The AWC simultaneously resolved similar matters brought by NYSE ARCA, inc. and FINRA and the remainder of the fine and disgorgement was allocated between NYSE ARCA, inc. and FINRA.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":618},{"d":"2023-09-25","di":"2023-09-25","dr":"2023-09-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":19000000.0,"dk":"FILE NO. 3-21709","al":"The SEC found that DWS Investment management americas, inc. (\"DIMA\") failed to have policies and procedures in place to ensure adequate implementation of certain provisions of its global ESG integration policy as they pertain to certain of DIMA's actively managed mutual funds and retail separately managed account strategies. The SEC further found that by virtue of DIMA's failures to adopt and implement reasonably designed policies and procedures to ensure the accuracy of its public statements, certain of its public statements about DIMA's ESG integration approach contained material misstatements. The SEC did not fund that any of these public statements were intentionally false.","res":"Order","sm":"On September 25, 2023, without admitting or denying the findings therein, dima entered into a settlement with the SEC finding that dima failed to have policies and procedures in place to ensure adequate implementation of certain provisions of its global ESG integration policy as they pertain to certain of dima's actively managed mutual funds and retail separately managed account strategies. The SEC further found that by virtue of dima's failures to adopt and implement reasonably designed policies and procedures to ensure the accuracy of its public statements, certain of its public statements about dima's ESG integration approach contained material misstatements. The SEC did not find that any of these public statements were intentionally false. Dima was (I) censured, (II) ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Advisers Act and rules 206(4)-7 and 206(4)-8 thereunder, and (III) ordered to pay a civil money penalty in the amount of $19,000,000, which will be timely paid.","ab":"DWS Investment","firms":[300838],"id":619},{"d":"2023-09-22","di":"2023-09-22","dr":"2023-09-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":6000000.0,"dk":"3-21700","al":"On September 22, 2023, the Securities and Exchange Commission (\"SEC\" or \"commission\") instituted public administrative and cease- and-desist proceedings against Goldman Sachs & Co. (\"gsco\" or \"the firm\") pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 and section 203(e) of the Investment Advisers Act of 1940 (\"Advisers Act\"), based on their determination that federal securities laws were violated. Gsco admitted the SEC's jurisdiction and the facts set forth in the order and submitted an OFFER of settlement (\"OFFER\"), which the SEC accepted. The SEC found that from at least November 2012 through October 2022, at least 22,192 out of 52,147 of the electronic blue sheets (\"EBS\") submitted by gsco included inaccurate or incomplete information, resulting in the misreporting of trade data. As a result, the firm violated the recordkeeping and reporting requirements of section 17(a)(1) of the Exchange Act and rules 17A-4(j) and 17A-25. Gsco initiated a voluntary remediation program and is resubmitting corrected EBS to the commission.","res":"Order","sm":"The SEC ordered that gsco cease and desist; is censured; and pay a civil money penalty in the amount of $6,000,000. The fine was paid on October 3, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":620},{"d":"2023-09-22","di":"2023-09-22","dr":"2023-09-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6000000.0,"dk":"2019061945001","al":"On September 22, 2023, the Financial Industry Regulatory Authority (\"FINRA\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by Goldman Sachs & Co. LLC (\"gsco\" or \"the firm\") in which gsco neither admitted nor denied FINRA's findings but consented to the sanctions and to the findings that from November 2012 through March 2022, it submitted almost 25,000 electronic blue sheets (\"EBS\") to FINRA that inaccurately reported one or more of 39 separate types of transaction information and misreported at least 97 million transactions. As a result, the firm violated FINRA rules 8211, 8213, and 2010. In addition, FINRA found the firm's failure to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA and the Securities and Exchange Commission (\"SEC\") EBS requirements was in violation of FINRA rules 3110, 2010 and NASD rule 3010. Gsco currently has an ongoing remediation program to improve its EBS system and address the discovered deficiencies.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco was censured, is required to certify to FINRA within 90 days that it has remediated the issues identified in the AWC and implemented a supversory system resonably designed to achieve compliance with the relevant rules, and agreed to pay a monetary fine of $6,000,000. The fine was paid on October 3, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":621},{"d":"2023-09-20","di":"2023-04-18","dr":"2023-09-20","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"URE-201-09","al":"Tudor Investment Corporation inadvertently submitted to the exchange an incorrect customer type indicator code for one of the accounts operated by Tudor.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Tudor Investment Corporation paid a fine in the amount of $35,000 on September 22, 2023.","sm":"On September 20, 2023, the CBOE Futures Exchange, LLC (the \"exchange\"), pursuant to an offer of settlement in which Tudor Investment Corporation (\"Tudor\") neither admitted nor denied that a violation of exchange rules had been committed, found that Tudor inadvertently submitted to the exchange an incorrect customer type indicator code for one of the accounts operated by Tudor. As part of the settlement Tudor consented to the imposition of a $35,000 fine. (Exchange file no. URE-201-09.) No information Filed","ab":"Tudor Investment Corporation","self":true,"firms":[159792],"id":622},{"d":"2023-09-19","di":"2023-09-19","dr":"2023-09-19","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil money penalty","st":"Final","fine":375000.0,"dk":"3-21675","al":"The U.S. Securities and Exchange Commission (\"SEC\") alleged that Cbre, Inc.'s form separation agreement included language that the SEC considered as impeding an employee's ability to report potential concerns to regulators. The SEC indicated that it was not aware of specific instances in which a former Cbre, Inc. employee was prevented from communicating with SEC staff about potential violations of securities laws, or in which Cbre, Inc. took action against a former employee based on the relevant representations. When the SEC notified Cbre, Inc. of their concern, Cbre inc. acted swiftly to revise the language in question and also contacted former employees who signed the release to give them clarification.","res":"Order","sd":"Cbre, Inc. paid a $375,000 civil money penalty on 09/20/2023.","sm":"In September 2023, Cbre, Inc., without admitting or denying the findings, entered into a settlement order with the SEC. the order is final. The fine of $375,000 was paid pursuant to the terms of the order, and the SEC commended Cbre's cooperation and remediation efforts. No information Filed","ab":"Cbre, Inc.","firms":[106256],"id":623},{"d":"2023-09-12","di":"2023-09-12","dr":"2023-09-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1939220.0,"dk":"FILE NO. 3-21651","al":"The SEC order related to a single legacy vessel deconstruction security offering that was exposed to underlying borrower defaults. The order states that Yieldstreet failed to disclose to investors a heightened risk that it would be unable to seize the ship serving as collateral for the loan underlying the offering, in the event of a default. Although Yieldstreet reached a settlement with the SEC, Yieldstreet neither admits nor denies any wrongdoing. We fully cooperated with the SEC's inquiry and are pleased to have reached a resolution of these issues. The SEC's order acknowledges Yieldstreet's cooperation and remedial efforts.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Yieldstreet agreed to pay a fine of approximately $1.32 million which will be paid directly to investors through a fair fund. Yieldstreet deposited the money into the fair fund on September 22, 2023. Yieldstreet also agreed to waive approximately $600,000 in fees related to the securities offering at issue.","sm":"The SEC administrative order is final. The full amount of the disgorgement, prejudgment interest and civil money penalties was paid into the escrow account within 10 days of the entry of the order. Within 90 days from the date of the order, Yieldstreet must submit a disbursement calculation to the commission for review and approval. Within 30 days of the written approval of the calculation by the commission staff, Yieldstreet must submit a payment file for review and acceptance by the commission staff demonstrating the application of the methodology to each affected advisory client. Titan must disburse all amounts payable to affected advisory clients within 90 days of the date the commission staff accepts the payment file. No information Filed","ab":"Yieldstreet","firms":[282487],"id":624},{"d":"2023-09-11","di":"2023-09-11","dr":"2023-09-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":250000.0,"dk":"2019062946601","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that, from October 2016 through July 2020, Citigroup Global Markets Inc. (\"the firm\") issued approximately 37,000 inaccurate trade confirmations to customers for certain trades in connection with the firm's principal trading activity on its alternative trading system, in violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\"), Exchange Act rule 17A-3(a)(8), Exchange Act rule 10B-10, and FINRA rules 2232, 4511, and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings in the AWC, the firm agreed to be censured and pay a $250,000 fine. The fine was paid in accordance with the terms of the AWC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":625},{"d":"2023-09-08","di":"2022-05-26","dr":"2023-09-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington Office of the Insurance Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"23-0147","al":"Massachusetts Mutual Life insurance company must certify annually to the office of the insurance commissioner (\"OIC\") the insurance producers that are selling, soliciting or negotiating the company's long term care (\"LTC\") insurance products have completed LTS requirements. The certification is required to be submitted annually to the OIC or before March 31ST. Massachusetts mutuals life insurance company was granted an extension to file its 2021 annual certification report by May 31, 2022. The state of Washington OIC alleged that Massachusetts Mutual Life insurance company failed to verify that two insurance producers had received the required LTC training before they were permitted to sell, solicit, or otherwise negotiate the sale of the company's LTC insurance products. By failing to verify the training, it was alleged that the company violated RCW 48.83.130(4), justifying the imposition of a fine under RCW 48.83.160.","res":"Decision & Order of Offer of Settlement","sd":"By failing to verify that two insurance producers had received the required LTC training before permitting to sell, solicit, or otherwise negotiate the sale of the company's LTC insurance products, the company violated RCW 48.23.130(4), justifying the imposition of a fine of $10,000 against Massachusetts Mutual Life insurance company under RCW 48.83.160. The company has paid the fine.","sm":"Massachusetts Mutual Life insurance company must certify annually to the office of the insurance commissioner (\"OIC\") the insurance producers that are selling, soliciting or negotiating the company's long term care (\"LTC\") insurance products have completed LTC requirements. The certification is required to be submitted annually to the OIC or before March 31ST. Massachusetts mutuals life insurance company was granted an extension to file its 2021 annual certification report by May 31, 2022. Massachusetts Mutual Life insurance company submitted the certification on May 26, 2022, which revealed that it self- disclosed that two producers sold three LTC policies to Washington consumers on behalf of the company and the producers were not in compliance with the LTC education requirements at the time of the sales. RCW 48.83.130(4) requires issuers to obtain verification that a producer receives training before ethe producers is permitted to sell, solicit or negotiate the issuer's LTC insurance products. Wac 284-17-262(1) provides that each issuer that has LTC polices approved for sale in wa must certify annual that all of its producers have (a) completed the 8 HR. One time LTC education training course required by RCW 48.83.130(1)(a)(I) prior to selling, soliciting, or negotiating the company's LTC coverage in wa; and (b) if due, completed the required 4 hour LTC ce requirement imposed by RCS 48.83.130(2)(b). By failing to verify that two producers had received the required long-term care training prior to selling, soliciting or negotiating the sale of the company's insurance products, it was alleged that the company has violated RCW 48.83.130(4) justifying a fine under RCW 48.83.160. The insurance commissioner consented to settle the matter in consideration of the company's payment of a fine and upon such terms and conditions, including (1) the company acknowledges the duty to comply fully with the applicable laws of the state of Washington; and (2) the company consented to the entry of the order. By agreement, the insurance commissioner imposed a fine in the amount of $10,000 to be paid within 30 days.","ab":"Massachusetts Mutual Life","firms":[106006],"id":626},{"d":"2023-09-08","di":"2022-05-26","dr":"2023-09-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington Office of the Insurance Commissioner","st":"Final","fine":10000.0,"dk":"ORDER NO. 23-0147","res":"Order","sd":"The insurance commissioner consented to settle the matter in consideration of the company's payment of a fine and upon such terms and conditions, including (1) the company acknowledges the duty to comply fully with the applicable laws of the state of Washington; and (2) the company consented to the entry of the order, waived any and all hearing or other procedural rights and further administrative or judicial challenges to the order. By agreement, the insurance commissioner imposed a fine in the amount of $10,000 to be paid within 30 days.","sm":"Massachusetts Mutual Life insurance company must certify annually to the office of the insurance commissioner (\"OIC\") the insurance producers that are selling, soliciting, or negotiating the company's long term care (\"LTC\") insurance products have completed LTC education requirements. The certification is required to be submitted annually to the OIC on or before March 31ST. Massachusetts Mutual Life insurance company was granted an extension to file its 2021 annual certification report by May 31, 2022.the state of Washington OIC alleged that Massachusetts Mutual Life insurance company failed to verify that two insurance producers had received the required LTC training before they were permitted to sell, solicit, or otherwise negotiate the sale of the company's LTC insurance products. By failing to verify the training, it was alleged that the company violated RCW 48.83.130(4), justifying the imposition of a fine under RCW 48.83.160. Massachusetts Mutual Life insurance company must certify annually to the office of the nsurance commissioner (\"OIC\") insurance producers selling, soliciting, or negotiating the company's long term care (\"LTC\") insurance products have completed LTC education requirements. The certification is required to be submitted annually to the OIC on or before March 31ST. Massachusetts Mutual Life insurance company was granted an extension to file its 2021 annual certification report by May 31, 2022. Massachusetts Mutual Life insurance company submitted the certification on May 26, 2022, which revealed that it self-disclosed that two producers sold three LTC policies to Washington consumers on behalf of the company and the producers were not in compliance with the LTC education requirements at the time of the sales. RCW 48.83.130(4) requires issuers to obtain verification that a producer receives training before the producer is permitted to sell, solicit, or negotiate the issuer's LTC nsurance products. Wac 284-17-262(1) provides that each insurer that has LTC policies approved for sale in wa must certify annually that all of its producers have (a) completed the 8 HR. One time LTC education and training course required by RCW 48.83.130(1)(a)(I) prior to selling, soliciting, or negotiating the company's LTC coverage in wa; and (b) if due, completed the required 4 hour LTC ce requirement imposed by RCW 48.83.130(2)(b). By failing to verify that two producers had received the required long-term care training prior to selling, soliciting, or negotiating the sale of the company's insurance products, it was alleged that the company had violated RCW 48.83.130(4) justifying a fine under RCW 48.83.160. The insurance commissioner and the company agreed to resolve the matter without further administrative or judicial proceedings. The insurance commissioner consented to settle the matter in consideration of the company's payment of a fine and upon such terms and conditions, including (1) the company acknowledges the duty to comply fully with the applicable laws of the state of Washington; and (2) the company consented to the entry of the order, waived any and all hearing or other procedural rights and further administrative or judicial challenges to the order. By agreement, the insurance commissioner imposed a fine in the amount of $10,000 to be paid within 30 days.","ab":"Massachusetts Mutual Life","firms":[162264],"id":627},{"d":"2023-09-05","di":"2023-09-05","dr":"2023-09-05","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine, Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2023-46","al":"The allegations were that, in 2022, Wells Fargo Clearing Services, LLC inadvertently did not conduct a branch inspection of one Maine branch office (a remote location not held out to the public). The Maine securities administrator took the position that this violated Maine's order 2021-12 and Maine office of securities rule CH. 504 section (7)(4)(b) regarding the on-site branch office inspection requirement. No customer impact.","res":"Consent","sm":"Wells Fargo Clearing Services, LLC agreed to pay $5,000 to resolve the allegations of a failure to comply with Maine's order no. 2021-12, an order superseding order no. 2020-45 regarding the resumption of on-site broker-dealer inspections of branch offices in Maine (\"order 2021-12\"), and Maine office of securities rule CH. 504 section (7)(4)(b) regarding the on-site branch office inspection requirement. Specifically, the allegations were that, in 2022, Wells Fargo Clearing Services, LLC inadvertently did not conduct a branch inspection of one Maine branch office (a remote location not held out to the public). The matter was resolved by consent and with no formal findings issued by the Maine office of securities.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":628},{"d":"2023-09-04","di":"2022-09-01","dr":"2023-09-04","k":"Regulatory Action","rg":"Other","reg":"The Korean Financial Supervisory Service","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3500.0,"al":"The Korean Financial Supervisory Service concluded an action against The Putnam Advisory Company, LLC (\"PAC\") relating to an alleged violation of short sale restrictions. Due to an operational error in restricting dividend-awarded shares that had yet to be received, PAC inadvertently sold shares of a korean-domiciled company that it did not possess. On September 4, 2023, PAC was assessed a fine of approximately $3,500.","res":"Order","ab":"The Putnam Advisory Company, LLC","self":true,"firms":[106631],"id":629},{"d":"2023-08-30","di":"2023-08-16","dr":"2023-08-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":425000.0,"dk":"2020068197401","al":"On August 16, 2023, the Financial Industry Regulatory Authority (\"FINRA\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by Goldman Sachs & Co. LLC (\"gsco\" or \"the firm\"), in which gsco neither admitted nor denied FINRA's findings. FINRA found that between July 2018 and September 2021, gsco failed to report, or inaccurately reported, over-the-counter (\"OTC\") options positions to the large options positions reporting (\"LOPR\") system. The findings stated the firm's systems failed to recognize that the accounts of certain customers were under common control or acted in concert. FINRA additionally found that gsco failed to maintain and enforce a supervisory system reasonably designed to achieve compliance with FINRA rule 2360(b) (5), which is a violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco was censured and agreed to pay a monetary fine in the amount of $425,000, which was paid in full via wire on August 30, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":630},{"d":"2023-08-30","di":"2023-08-14","dr":"2023-08-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":125000.0,"dk":"FILE NO. URE-95-03/STAR NO. 20200664843","al":"On August 15, 2023, CBOE BZX Exchange (\"CBOE BZX\" or the \"exchange\") accepted a letter of consent (\"LOC\") submitted by Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\"), in which gsco neither admitted nor denied CBOE BZX's findings. CBOE BZX found that from October 2018 through February 2021, gsco failed to report or incorrectly reported certain options positions to the large options position report (\"LOPR\") and thus violated BZX rule 18.10(a). The exchange determined that BZX rule 5.1 was violated as a result of the firm's failure to establish, maintain and enforce written supervisory procedures and supervisory systems reasonably designed to prevent and detect violations of the firm's LOPR reporting obligations.","res":"Consent","sm":"Pursuant to the loc, gsco was censured and agreed to pay a monetary fine in the amount of $125,000, which was paid in full via wire on August 30, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":631},{"d":"2023-08-29","di":"2023-08-29","dr":"2023-08-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","os":"N/a","st":"Final","fine":5500000.0,"dk":"23-39","al":"On August 29, 2023, the Commodity Futures Trading Commission (\"commission\" or \"CFTC\") issued an order against Goldman Sachs & Co. LLC (\"GSCO\"), accepting an offer of settlement submitted by GSCO. The CFTC found that from at least March 2020 to November 2020 (\"relevant period\"), GSCO violated section 4s(f)(1)(c) of the Commodity Exchange Act (\"act\"), 7 U.S.C. § 6s(f)(1)(c), and commission regulations (\"regulations\") 1.31(b)(2) and 23.202(a)(1) and (b)(1), 17 C.F.R. §§ 1.31(b)(2), 23.202(a)(1), (b)(1) (2022), and violated the cease-and desist provision of a prior commission order. The commission found that GSCO used recording system components from two vendors to record certain phone calls, and due to failures in those systems, GSCO failed to make and retain a number of recordings of traders and sales personnel that contained the oral communications that led to the execution of swaps and related cash and forward transactions during the relevant period. Consequently, GSCO also violated an order that the commission had previously issued on November 26, 2019, related to other swap dealer recordkeeping violations under the same provisions. GSCO neither admitted nor denied any of CFTC's findings.","res":"Order","sm":"The CFTC ordered that gsco cease and desist, and pay a civil monetary penalty in the amount of $5,500,000. The fine was paid on September 8, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":632},{"d":"2023-08-29","di":"2023-08-29","dr":"2023-08-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":2900000.0,"dk":"FILE NO. 3-21583","al":"The Securities and Exchange Commission alleged that from at least 2009 through May 2019, Citigroup Global Markets Inc. (CGMI) failed to make and keep current books and records concerning expenses that CGMI incurred in connection with its underwriting of securities offerings, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder.","res":"Order","sm":"Without admitting or denying the findings, cgmi agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-3 thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $2,900,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":633},{"d":"2023-08-28","di":"2022-09-21","dr":"2023-08-28","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (Fse)","san":"Reprimand","st":"Final","dk":"HM 39-2022","al":"The Frankfurt stock exchange (\"FSE\") found that, from November 2021 through August 2022, Deutsche Bank AG, Frankfurt am main (\"DB AG\") failed to convert 2,039 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On September 2, 2023, DB AG received a decision from fse finding that, from November 2021 through August 2022, DB AG failed to convert 2,039 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014, and issuing a reprimand to DB AG, but not imposing a fine or other monetary sanction.","ab":"Deutsche Bank AG","firms":[300838],"id":634},{"d":"2023-08-25","di":"2023-08-25","dr":"2023-08-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure","st":"Final","fine":35000000.0,"dk":"FILE NO. 3-21580","al":"The Securities and Exchange Commission (\"SEC\") alleged that Wells Fargo Clearing Services, LLC, Wells Fargo Advisors Financial Network, LLC, and their predecessor firms (collectively, \"Wells fargo\" or the \"firm\") overcharged approximately 10,945 advisory accounts of advisory clients opened through 2014 more than $26.8 million in advisory fees from at least 2002 through December 2022 and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts.","res":"Order","sm":"On August 25, 2023, the SEC entered into a settlement order with Wells fargo to settle an administrative action which alleged that Wells fargo overcharged approximately 10,945 advisory accounts of advisory clients opened through 2014 more than $26.8 million in advisory fees from at least 2002 through December 2022 and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected accountholders. Without admitting or denying the findings, Wells fargo agreed to: (a) cease and desist from committing or causing any violations or any future violations of sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-7 thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $35,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Advisors; Wells Fargo Clearing","firms":[11025,19616],"id":635},{"d":"2023-08-22","di":"2023-08-22","k":"Regulatory Action","dk":"21-01565","ab":"Martinez, Eduardo, Andrew","firms":[7691],"id":636},{"d":"2023-08-21","di":"2023-08-21","dr":"2023-08-21","k":"Regulatory Action","rg":"CME Group","reg":"CME","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"CME DQA-23-1247","al":"Alleged violation of rule 536.f, Citigroup Global Markets Inc. , (CGMI), data entry errors exceeded the 10% threshold level from March 1, 2023 through June 30, 2023.","res":"Consent","sm":"Cgmi consented to a fine of $2,500.00.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":637},{"d":"2023-08-21","di":"2023-08-21","dr":"2023-08-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease-and-desist; censure; disgorgement","st":"Final","fine":850000.0,"dk":"3-21569","al":"The SEC order primarily covers certain legacy marketing and disclosure issues involving Titan's cryptocurrency strategy between August 2021 and October 2022. The SEC order states that Titan did not implement policies and procedures that were reasonably designed to comply with marketing regulations and made certain misleading representations. The settlement also covers policy and procedure issues, and a customer agreement issue. Although Titan reached a settlement with the SEC, Titan neither admits nor denies any wrongdoing. We fully cooperated with the SEC's inquiry and are pleased to have reached a resolution of these issues. The SEC order acknowledges Titan's cooperation and remedial efforts since July 2022, including hiring a new chief legal and chief compliance officer and additional legal and compliance staff. Titan continues to make significant investments to build and enhance its compliance program.","res":"Settled","sd":"On August 22, 2023, Titan deposited $1,051,052 into a \"fair fund\" that will be used to compensate impacted customers.","sm":"The SEC administrative order is final. The civil monetary penalty was paid into the escrow account within 10 days of the entry of the order. Within 90 days from the date of the order, Titan must submit a calculation to the commission for review and approval. Within 30 days of the written approval of the calculation by the commission staff, Titan must submit a payment file for review and acceptance by the commission staff demonstrating the application of the methodology to each affected advisory client. Titan must disburse all amounts payable to affected advisory clients within 120 days of the date the commission staff accepts the payment file. No information Filed","ab":"Titan Global Capital Management USA LLC","self":true,"firms":[290111],"id":638},{"d":"2023-08-18","di":"2023-08-18","dr":"2023-08-18","k":"Regulatory Action","rg":"Other","reg":"CBOT","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"23-CH-2317","al":"Alleged violation of CBOT rule 980.a in that Citigroup Global Markets Inc. (CGMI) failed to prepare, maintain and keep current books and records required by the rules of the exchange, the commodity Exchange Act and the regulations thereunder, on August 17, 2023.","res":"Settled","sm":"Cgmi consented to a fine of $150,000.00.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":639},{"d":"2023-08-18","di":"2017-09-29","dr":"2023-08-18","k":"Regulatory Action","rg":"Federal Reserve","reg":"Governors of the Federal Reserve System (The \"Federal Reserve\")","san":"Cease and Desist","os":"Monetary fine","st":"Final","fine":175296000.0,"dk":"17-010-B-FB; 17-010-B-HC; 17-010-CMP-FB; 17-010-CMP-HC","al":"In September 2017, following the conclusion of the US Federal Reserve board's review of the effectiveness of HSBC's FX practices during the period of October 2008 through October 2013, HSBC holdings PLC and HSBC North America holdings inc. entered into a consent order regarding certain deficiencies in HSBC's control and oversight over its FX business. HSBC through various subsidiaries of holdings, including hbeu and hbus, lacked adequate governance, risk management, compliance and audit policies and procedures to ensure that HSBC's covered FX activities complied with safe and sound banking practices and applicable internal policies. On August 18, 2023, the Federal Reserve board concluded that HSBC was in full compliance and terminated the consent order.","res":"Consent","sm":"In September 2017, following the conclusion of the US Federal Reserve board's review of the effectiveness of HSBC's FX practices during the period of October 2008 through October 2013, HSBC holdings PLC and HSBC North America holdings inc. entered into a consent order regarding certain deficiencies in HSBC's control and oversight over its FX business. HSBC through various subsidiaries of holdings, including hbeu and hbus, lacked adequate governance, risk management, compliance and audit policies and procedures to ensure that HSBC's covered FX activities complied with safe and sound banking practices and applicable internal policies. On August 18, 2023, the Federal Reserve board concluded that HSBC was infull compliance and terminated the consent order.","ab":"HSBC North America","firms":[172522,324468],"id":640},{"d":"2023-08-17","di":"2023-07-27","dr":"2023-08-17","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"NYMEX CASE-23-1655","al":"On July 27, 2023, the market regulation department of the CME Group Inc. (\"CME\") notified Goldman Sachs & Co. LLC (\"gsco\" or \"the firm\") that CME had identified reporting infractions with the firm's transfer trade reporting in violation of CME rule 853.A.6.","res":"Decision","sm":"CME imposed a summary fine in the amount of $1,000, which gsco paid by submission of a wire on August 17, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":641},{"d":"2023-08-14","di":"2023-08-14","dr":"2023-08-14","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"CONSENT AGREEMENT NO. 2023-35","al":"Without admitting or denying that its conduct violated the Maine uniform Securities Act (MUSA), Morgan Stanley Smith Barney LLC (the firm) consented to the entry of an agreement with the State of Maine Office of Securities (MOS), which alleged that by failing to conduct on-site branch inspections of all of its Maine branch offices before December 31, 2022, the firm was in violation of rule CH. 504 § (7)(4)(b) and order 2021­12, issued by the Maine securities administrator on April 26, 2021.","res":"Consent","sm":"On August 14, 2023, the firm entered into a consent agreement with the mos which alleged that by failing to conduct on-site branch inspections of all of its Maine branch offices before December 31, 2022, the firm was in violation of rule CH. 504 § (7)(4)(b) and order 2021-12, issued by the Maine securities administrator on April 26, 2021. Without the firm admitting or denying its conduct violated the musa and without adjudication of any issue of law or fact, the firm accepted and consented to a civil fine in the amount of $5,000. The fine was paid in accordance with the terms of the consent agreement.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":642},{"d":"2023-08-10","di":"2023-08-10","dr":"2023-08-10","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":190000.0,"dk":"230028","al":"Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that from January 2018 until June 2023, LPL failed to register at least one of its representatives as an investment adviser representative in Pennsylvania","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":643},{"d":"2023-08-08","di":"2023-08-08","dr":"2023-08-08","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","os":"N/a","st":"Final","fine":6000000.0,"dk":"23-37","al":"The Commodity Futures Trading Commission (the \"commission\") alleged that from at least 2018 to the present (the \"relevant period\"), applicant violated section 4g of the Commodity Exchange Act (\"act\"), 7 U.S.C. § 6g, and commission regulations (\"regulations\") 1.31, 1.35, and 166.3, 17 C.F.R. §§ 1.31, 1.35, 166.3 (2022). The commission alleged the following: Wedbush employees, including those at senior levels, communicated both internally and externally using personal text messages. These written communications were sent and received by Wedbush employees and included messages related to Wedbush's business as a commission registrant that were required to be maintained under commission-mandated recordkeeping requirements. These written business-related communications via unapproved methods generally were not maintained and preserved by Wedbush, and Wedbush generally would not have been able to furnish the communications promptly to a commission representative if and when requested. In addition, the widespread use of unauthorized communication methods by Wedbush's employees to conduct firm business violated Wedbush's own policies and procedures, which prohibited such communications. Wedbush did not maintain adequate internal controls with respect to the use of unapproved communication methods for business-related communications. Because Wedbush failed to implement a diligent supervisory system to ensure compliance with commission recordkeeping requirements and the firm's own policies and procedures, and because the widespread use of unauthorized communication methods resulted in the firm's failure to maintain commission-required records, Wedbush failed to diligently supervise matters related to its business as a commission registrant in violation of regulation 166.3, 17 C.F.R. § 166.3 (2022).","res":"Order","sd":"The firm shall cease and desist from violating section 4g of the act, 7 U.S.C. § 6g, and regulations 1.31, 1.35, and 166.3, 17 C.F.R. §§ 1.31, 1.35, 166.3 (2022), pay a civil monetary penalty in the amount of $6,000,000, and shall comply with the conditions and undertakings set forth in the offer.","sm":"Applicant entered into a settlement with the CFTC, by which the firm was ordered to: cease and desist from violating section 4g of the act, 7 U.S.C. § 6g, and regulations 1.31, 1.35, and 166.3, 17 C.F.R. §§ 1.31, 1.35, 166.3 (2022); pay a civil monetary penalty in the amount of $6,000,000; and comply with the conditions and undertakings set forth in the order.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":644},{"d":"2023-08-08","di":"2023-08-08","dr":"2023-08-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":10000000.0,"dk":"3-21550","al":"The SEC alleged that Wedbush failed to adhere to certain recordkeeping requirements and Wedbush's own policies. Using their personal devices, employees communicated both internally and externally by personal text messages, or other text messaging platforms such as whatsapp (\"off-channel communications\"). From at least January 2019, Wedbush employees sent and received off-channel communications that related to the business of the broker-dealer and registered investment adviser operated by Wedbush. Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failure was firm-wide, and involved employees at all levels of authority. Wedbush's supervisors, who were responsible for supervising junior employees, routinely communicated off-channel using their personal devices. Wedbush's widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees within the meaning of section 15(b)(4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act. During the time period that Wedbush failed to maintain and preserve off-channel communications, Wedbush received and responded to commission subpoenas for documents and records requests in numerous commission investigations. As a result, Wedbush's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff uncovered Wedbush's misconduct after commencing a risk based initiative to investigate the use of off-channel and unpreserved communications at broker dealers. Wedbush has initiated a review of its recordkeeping failures and begun a program of remediation. Wedbush will retain an independent compliance consultant to review and assess Wedbush's remedial steps relating to Wedbush's recordkeeping practices, policies and procedures, related supervisory practices, and employment actions.","res":"Order","sd":"The firm is ordered to cease and desist; is censured; shall comply with the undertakings enumerated in the order; andshall pay a civil money penalty in the amount of $10,000,000 to the SEC.","sm":"Applicant enetered into a settlement with the SEC in which it admitted to findings that it: willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder; willfully violated section 204 of the Advisers Act and rule 2042(a)(7) thereunder; failed reasonably to supervise its employees with a view to preventing or detecting certain of its employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and failed reasonably to supervise its employees with a view to preventing or detecting certain of its employees' aiding and abetting violations of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act. Pursuant to the settlement, applicant was: ordered to cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, and cease and desist from committing or causing any violations and any future violations of section 204 of the Advisers Act and rule 204-2 thereunder; censured; ordered to comply with the undertakings enumerated in the order; and fined a civil money penalty in the amount of $10,000,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":645},{"d":"2023-08-08","di":"2023-08-08","dr":"2023-08-08","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, undertaking","st":"Final","fine":75000000.0,"dk":"DOCKET NO. 23-36","al":"The Commodity Futures Trading Commission (\"CFTC\") entered into a settlement order (\"order\") with Wells fargo securities, LLC (\"WFS\") and Wells Fargo Bank NA (\"WFB\" and collectively with WFS, the \"respondents\") to settle an administrative action concerning (a) WFB's failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the Commodity Exchange Act (\"act\") and regulations 23.201(a) and 23.202(a)(1) and (b)(1); (b) WFS's failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) WFB's failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) WFS's failure to diligently supervise in violation of regulation 166.3.","res":"Order","sm":"On August 8, 2023, the CFTC entered into an order with the respondents to settle an administrative action concerning (a) WFB's failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the act and regulations 23.201(a) and 23.202(a)(1) and (b)(1); (b) WFS's failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) WFB's failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) WFS's failure to diligently supervise in violation of regulation 166.3. The respondents admitted to the facts in the settlement order, acknowledged their conduct violated the act and regulations and consented to: (a) the entry of the CFTC's findings; (b) have WFB cease and desist from violating sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the act, and regulations 1.31, 23.201(a), 23.202(a)(1) and (b)(1) and 23.602(a) and to have WFS cease and desist from violating section 4g of the act and regulations 1.31, 1.35 and 166.3, (c) pay a civil monetary penalty in the amount of $75,000,000, and (d) comply with certain conditions and undertakings. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Bank N.A.","firms":[11025,19616],"id":646},{"d":"2023-08-08","di":"2023-08-08","dr":"2023-08-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, undertaking","st":"Final","fine":125000000.0,"dk":"FILE NO. 3-21552","al":"The Securities and Exchange Commission (\"SEC\") alleged, in connection with the broker-dealer off-channel communications initiative, that Wells Fargo Securities, LLC, Wells Fargo Clearing Services, LLC, and Wells Fargo Advisors Financial Network, LLC (collectively, \"Wells fargo\") failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by Wells fargo, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"On August 8, 2023, the SEC entered into a settlement order with Wells fargo to settle an administrative action, in connection with the broker-dealer off-channel communications initiative, which alleged that Wells fargo failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by Wells fargo, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act. Wells fargo admitted to the facts in the settlement order, acknowledged their conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $125,000,000, and (d) comply with certain undertakings related to retention of electronic communications. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Wells Fargo Clearing; Wells Fargo Securities,","firms":[11025,19616],"id":647},{"d":"2023-08-08","di":"2023-08-08","dr":"2023-08-08","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000000.0,"dk":"23-24","al":"The U.S. commodity future trading commission (\"CFTC\") alleged that, from at least 2019 through the date of the order, Bank of Montreal (\"BMO\") (I) failed to keep certain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the commodity Exchange Act (\"CEA\") and CFTC regulations 23.201(a) and 23.202(a)(1) and (b)(1), (II) failed to keep records in the manner required by CFTC regulation 1.31, and (III) failed to supervise its swap dealer business activities diligently in violation of section 4s(h)(1)(b) of the CEA and CFTC regulation 23.602(a).","res":"Order","sd":"Bank of Montreal (\"BMO\") admitted to the facts in the CFTC's order, acknowledged its conduct violated the commodity Exchange Act (\"CEA\") and CFTC regulations, and agreed to (I) the entry of the CFTC's findings; (II) cease and desist from violating SECTIONS4S(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the CEA and CFTC regulations 1.31, 23.201(a), 23.202(a)","sm":"On August 8, 2023, the U.S. Commodity Futures Trading Commission (\"CFTC\") alleged that Bank of Montreal (\"BMO\") (I) failed to keep certain required records in violation of sections 4s(f)(1)(c) AND4S(g)(1) and (3) of the commodity Exchange Act (\"CEA\") and CFTC regulations 23.201(a) and 23.202(a)(1)and (b)(1), (II) failed to keep records in the manner required by CFTC regulation 1.31, and (III) failed to supervise its swap dealer business activities diligently in violation of section 4s(h)(1)(b) of the CEA and CFTC regulation 23.602(a). BMO admitted to the facts in the CFTC's order, acknowledged that its conduct violated the CEA and CFTC regulations, and agreed to (I) the service of the CFTC's order;(II) cease and desist from violating sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the CEA and CFTC regulations 1.31, 23.201(a), 23.202(a)(1) and (b)(1), and 23.602(a); (III) pay a civil monetary penalty in the amount of $35,000,000; and (IV) comply with certain undertakings. No information Filed","ab":"Bank of Montreal","firms":[114317],"id":648},{"d":"2023-08-03","di":"2023-08-30","dr":"2023-08-03","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","os":"Voluntary corrective measures on its employee","st":"Final","al":"Financial services commission alleged that Samsung asset management co., LTD. failed to identify and assess the likelihood of conflicts of interest, and control such conflicts properly between the investors of the ETF managed by it and the investment broker, which is the borrower of the securities of the ETF, by setting a fixed loan rate without considering market demand and circumstances.","res":"Other","sd":"On August 30, 2023, the financial services commission (FSC) issued a notice of its decision, finding that Samsung asset management co., LTD. is liable for the allegations listed in our answers to question 7. As a result, FSC ordered to take voluntary corrective measures on one employee of Samsung Asset Management Company, Ltd.","ab":"Samsung Asset Management Company, Ltd.","self":true,"firms":[158319],"id":649},{"d":"2023-08-02","di":"2023-08-02","dr":"2023-08-02","k":"Regulatory Action","rg":"State regulator","reg":"The State of Missouri","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist from engaging in violations of 15 CSR 30-51.171 and conduct and activities subject to discipline under sections","st":"Final","fine":150000.0,"dk":"AP-23-09","al":"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.","res":"Consent","sd":"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.","sm":"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).","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":650},{"d":"2023-07-25","di":"2023-07-25","dr":"2023-07-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, restitution, undertaking","st":"Final","fine":3000000.0,"dk":"2020067897601","al":"The Financial Industry Regulatory Authority (FINRA) alleged that LPL Financial LLC (the firm) failed to establish and maintain a system to supervise the activities of its representatives that was reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to the transmittal of customer funds by wire or check to third parties, responding reasonably to red flags of potential conversion and detecting possible instances of forgery or falsification of electronic signatures, in violation of FINRA rules 3110, 4511 and 2010, section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and Exchange Act rule 17A-3.","res":"Acceptance, Waiver & Consent(AWC)","sm":"From May 2018 to August 2020, FINRA alleged that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to the transmittal of customer funds by wire or check to third parties and responding reasonably to red flags of potential conversion by two former representatives, in violation of FINRA rules 3110 and 2010. In addition, from January 2018 to January 2022, the firm failed to have a supervisory system reasonably designed to detect possible instances of forgery or falsification by its representatives related to electronic signatures, in violation of FINRA rules 3110, 4511 and 2010, section 17(a) of the Exchange Act\" and Exchange Act rule 17A-3. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm consented to the imposition of a censure, a monetary fine in the amount of $3,000,000, payment of customer restitution in the amount of $100,000, plus interest, and an undertaking.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":651},{"d":"2023-07-21","di":"2023-07-05","dr":"2023-07-21","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"RSRH-23-6886","al":"On July 5, 2023, the market regulation department of the CME Group Inc. (\"CME\") completed a review of block trades reported by Goldman Sachs & Co. LLC (\"GSCO\") during the period January 2022 through April 2023, and found that in certain instances GSCO reported trades with inaccurate information, in violation of CME rule 526 and market regulation advisory notice RA2204-5, section 7.","res":"Decision","sm":"CME imposed a summary fine in the amount of $5,000, which gsco paid by submission of a wire on July 24, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":652},{"d":"2023-07-20","di":"2022-05-03","dr":"2023-07-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":1000000.0,"dk":"3-21533","al":"On July 20, 2023, the SEC published an order of settlement between it and the registrant relating to registrant's failure to timely file amended reports on schedule 13g related to certain special purpose acquisition company (\"SPAC\") related investments, to timely disclose conflicts of interest related to client investments in spacs, and to adopt reasonably designed policies and procedures regarding its personnel's ownership interests in SPAC sponsors. Without admitting or denying the findings, registrant consented to the entry of the SEC's order finding that registrant violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder, and violated and caused violations of section 13(d) of the Securities Exchange Act of 1934 and rule 13-D-2 thereunder, and agreed to a cease-and-desist order against future violations of these provisions, a censure and a $1 million civil penalty.","res":"Settled","sd":"Without admitting or denying the findings, registrant consented to the entry of the SEC's order finding that registrant violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder, and violated and caused violations of section 13(d) of the Securities Exchange Act of 1934 and rule 13-D-2 thereunder, and agreed to a cease- and-desist order against future violations of these provisions, a censure and a $1 million civil penalty.","sm":"The SEC matter was settled on July 20, 2023 pursuant to the order described above. No information Filed","ab":"Monroe Capital Management Advisors LLC","self":true,"firms":[157073],"id":653},{"d":"2023-07-13","di":"2023-07-13","dr":"2023-07-13","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":186392035.0,"dk":"23-012-B-FB, 23-012-B-FBR, 23-012-B-HC, 23-012-B-SM, 23-012-CMP-FB, 23-012-CMP-FBR, 23-012-CMP-HC, 23-012-CMP-SM","al":"The Board of Governors of the Federal Reserve System (\"FRB\") alleged that Deutsche bank AG, Deutsche Bank AG New York branch, DB USA corporation, Deutsche bank trust company americas and DWS USA corporation (collectively the \"settling entities\" or the \"bank\") insufficiently and tardily implemented the post-settlement sanctions and embargoes and AML control enhancement undertakings required by prior consent orders with the FRB dated November 4, 2015, and May 26, 2017, respectively.","res":"Consent","sm":"On July 13, 2023, the FRB and the settling entities entered into a consent order relating to allegations that the settling entities insufficiently and tardily implemented the post-settlement sanctions and embargoes and AML control enhancement undertakings required by prior consent orders with the FRB dated November 4, 2015, and May 26, 2017, respectively. The settling entities, without admitting or denying the allegations, agreed to a fine of $186,392,035, including $140,192,035 for the violations alleged with the respect to the post-settlement sanctions and embargoes and AML control enhancement undertakings, as well as a separate penalty of $46,000,000 for unsafe or unsound practices stemming from the bank's handling of its legacy correspondent banking relationship with danske bank estonia, which was terminated in October 2015. The fine was timely paid on July 14, 2023. In addition, the consent order includes certain post-settlement remediation and reporting undertakings.","ab":"Deutsche Bank AG New York","firms":[300838],"id":654},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":6000000.0,"dk":"2020066667001","al":"The Financial Industry Regulatory Authority alleged that between January 2009 and November 2019, Merrill Lynch, Pierce, Fenner & Smith (MLPF&s) failed to file certain suspicious activity reports (SARS) due to the application of an incorrect monetary threshold for reporting and failed to establish and implement policies and procedures reasonably designed to detect and cause the reporting of suspicious activity as required by 31 CFR § 1023.320(a)(2), in violation of NASD rule 3011(a) and FINRA rules 3310(a) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPF&s agreed to the imposition of a censure and a fine in the amount of $6,000,000. The fine will be paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":655},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Cease and Desist","st":"Final","fine":30000000.0,"dk":"FILE NO. 2023-CFPB-0007","al":"The Consumer Financial Protection Bureau (\"CFPB\") alleged that Bank of America, National association (the firm) (1) with respect to promotional bonus offers on rewards credit cards, created the deceptive net impression that bonuses linked to rewards credit cards were available to all consumers when those bonuses were only available to consumers who applied online, and denied bonuses to certain targeted consumers who applied in-person and over the phone; and (2) with respect to offering Consumer credit card accounts, in some instances, applied for and opened credit cards for consumers without their consent and obtained Consumer reports for those consumers without a permissible purpose. The CFPB alleges that these acts violated the truth in lending act, 15 U.S.C. § 1601 et seq., and its implementing regulation, regulation z, 12 C.F.R. Part 1026; the fair credit reporting act (CFPA), 15 U.S.C. § 1681b(f); and the Consumer financial protection act of 2010, 12 U.S.C. §§ 5531 and 5536.","res":"Consent","sm":"Without admitting or denying the findings of fact or conclusions of law, the firm consented to (1) the entry of the order, (2) not violate sections 1031 and 1036 of the cfpa, 12 usc §§ 5531 and 5536, (3) identify affected consumers not previously remediated to pay or provide redress, (4) certain undertakings, and (5) payment of a civil monetary penalty in the amount of $30,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bank of America, National","firms":[7691],"id":656},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Cease and Desist","st":"Final","fine":60000000.0,"dk":"FILE NO. 2023-CFPB-0006","al":"The Consumer Financial Protection Bureau (CFPB) alleged that Bank of America, National association (the firm) committed unfair acts and practices when it charged consumers repeat non-sufficient funds (NSF) fees on transactions resubmitted to the firm for payment after they were initially declined (re-presentment fees) in violation of sections 1031 and 1036 of the Consumer financial protection act of 2010 (CFPA), 12 U.S.C. §§ 5531(a) and (c)(1), 5536(a)(1)(b).","res":"Consent","sm":"Without admitting or denying the findings of fact or conclusions of law, the firm consented to (1) the entry of the order, (2) not violate sections 1031 and 1036 of the cfpa, 12 U.S.C. §§ 5531 and 5536 and not assess re­presentment NSF fees, (3) comply with certain undertakings, (4) pay redress to affected customers, and (5) pay a civil monetary penalty in the amount of $60 million. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bank of America, National","firms":[7691],"id":657},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":60000000.0,"dk":"AA-ENF-2023-19","al":"The Office of the Comptroller of the Currency (\"OCC\") alleged that Bank of America, National association (the firm) assessed multiple overdraft and insufficient funds fees against customers for a single transaction in violation of section 5 of the federal trade commission act (\"FTC act\"), 15 U.S.C. § 45(a)(1).","res":"Consent","sm":"Without admitting or denying the findings contained in the order, the firm consented to pay a civil penalty in the amount of $60 million. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bank of America, National","firms":[7691],"id":658},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":6000000.0,"dk":"FILE NO. 3-21524","al":"The Securities and Exchange Commission (SEC) alleged that from January 2009 to November 2019, (1) Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&s) failed to file certain required suspicious activity reports (SARS), in willful violation of section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and rule 17A-8 thereunder, in connection with the application of an incorrect monetary threshold for certain types of sar filings; and (2) Bac North America Holding co. (BACNAH) caused MLPF&s's violations.","res":"Order","sm":"Without admitting or denying the findings, MLPF&s and bacnah agreed to cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-8 thereunder, MLPF&s was censured, and MLPF&s agreed to pay a civil monetary penalty in the amount of $6,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bac North America Holding","firms":[7691],"id":659},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":250000.0,"dk":"2021071191801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it filed short interest reports that overreported the number of shares associated with short interest positions. The findings stated that the firm submitted short interest reports to FINRA that erroneously included short positions in accounts resulting from repurchase and pledge transactions and securities lending conducted by the firm or its affiliates, and syndicate activity of correspondent firms for which it clears securities transactions. Because these short positions did not result from \"short sales\" as defined in rule 200(a) of Regulation SHO and were not transactions that were marked long due to the firm's or the customer's net long position at the time of the transaction, they were not reportable under FINRA rule 4560. As a result, the firm overreported the number of shares associated with the short interest positions. The findings also stated that the firm failed to establish and maintain a supervisory system, including WSPS, reasonably designed to achieve compliance with short interest reporting requirements. Although the firm coded accounts as reportable or non-reportable for short interest reporting purposes, its supervisory system did not provide for testing of the coding of accounts on an ongoing basis. In addition, the firm relied on email notifications from the firm's correspondent business clearing line for reconciling the coding and inclusion or exclusion of syndicate accounts for short interest reporting purposes. However, the firm did not implement processes or procedures to monitor whether the notifications were timely received and reviewed. Subsequently, the firm amended its supervisory systems and procedures to include, among other things, additional reviews at the time of account creation and short interest reporting and a lookback review identifying changes in the last six report cycles.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":660},{"d":"2023-07-11","di":"2023-07-11","dr":"2023-07-11","k":"Regulatory Action","rg":"Other","reg":"National Bank of Hungary (NBH)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":11093.0,"dk":"H-JE-I-B-116/2023","al":"The national bank of hungary (\"NBH\") found that Deutsche Bank AG, Hungary branch (\"DBAG\") did not meet its data reporting obligations with appropriate data quality related to specific balance sheet items and cash flow reports.","res":"Order","sm":"On July 11, 2023, the NBH issued a resolution against dbag finding that dbag did not meet its data reporting obligations with appropriate data quality related to specific balance sheet items and cash flow reports. The resolution imposed a fine on dbag of 4,000,000 hungarian forints, which is approximately usd $11,093, which was timely paid on July 21, 2023.","ab":"Deutsche Bank AG, Hungary","firms":[300838],"id":661},{"d":"2023-07-10","di":"2023-07-10","dr":"2023-07-10","k":"Regulatory Action","rg":"Other","reg":"Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":100000.0,"dk":"E-2023-0041","al":"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.","res":"Consent","sd":"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.","sm":"Raymond James & Associates, Inc. neither admitted nor denied the statement of facts and violation of G.L. C. 110a, SEC. 204(a)(2)(j).","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":662},{"d":"2023-07-10","di":"2023-07-10","dr":"2023-07-10","k":"Regulatory Action","rg":"Other","reg":"California Dept. of Financial Protection and Innovation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":75000.0,"dk":"8663","al":"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.","res":"Consent","sd":"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.","sm":"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","ab":"Raymond James Financial","firms":[705],"id":663},{"d":"2023-07-10","di":"2023-07-10","k":"Regulatory Action","rg":"Other","reg":"North American Securities Administrators Association","dk":"E-2023-00041","ab":"Raymond James Financial","firms":[149018],"id":664},{"d":"2023-07-06","di":"2022-11-14","dr":"2023-07-06","k":"Regulatory Action","rg":"State regulator","reg":"Supreme Court of the State of New York Appellate Division, First Judicial Department","san":"Suspension","st":"Final","dk":"2023-02769","al":"On May 19, 2023, MS. Shandling was made aware of an order by the Supreme Court of the State of New York Appellate Division, First Judicial Department (the \"court\"), dated November 14, 2022, suspending MS. Shandling for failure to file a biennial registration as a retired attorney per judiciary law §468­a.","res":"Order","sd":"On May 19, 2023, MS. Shandling was made aware of an order by the Supreme Court of the State of New York Appellate Division, First Judicial Department (the \"court\"), dated November 14, 2022, suspending MS. Shandling for failure to file a biennial registration as a retired attorney per judiciary law §468­a, which requires that every attorney admitted to practice in the state of New York register biennially as an active attorney or a retired attorney with the chief administrator of the courts. The suspension was administrative in nature. MS. Shandling has not practiced law since before 2015, including since the expiration of her prior biennial registration. On May 22, 2023, MS. Shandling filed a corrective registration statement with the court indicating that she has retired from the practice of law, and on May 30, 2023, she filed a motion for reinstatement of her registration with the court. On July 6, 2023, the court granted MS. Shandling's motion and reinstated her as a retired attorney and counselor-at-law in the state of New York.","ab":"Shandling, Judith, Leah","firms":[283221,286067],"id":665},{"d":"2023-07-02","di":"2023-07-02","dr":"2023-07-02","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"\"Penalty subcharge : KRW 685mil / usd 531,832 (exchange rate 1,288) fine : KRW 280mil / usd 217,391 (exchange rate 1,288) voluntary","st":"Final","fine":749223.0,"al":"\"Financial services commission alleged that Samsung fire and marine co., LTD. has violated: - prohibited conducts concerning conclusion or solicitation of insurance contracts - duty to explain important matters in insurance contracts - obligations to comply with terms of the basic documents of the insurance - principles for calculating premium rates and obligation of management standards of basic documents of the insurance - duty to accumulate insurance reserve \"","res":"Other","sd":"On February 07, 2023, the financial services commission (FSC) issued a notice of its decision, finding that Samsung Fire & Marine insurance co. LTD. is liable for the allegations listed in our answers to question 7. As a result, FSC imposed a fine of KRW 965mil in aggregate, issued a warning letter to Samsung Fire & Marine insurance co. LTD., and ordered to take voluntary corrective measures.","ab":"Samsung Fire & Marine","firms":[158319],"id":666},{"d":"2023-06-27","di":"2023-06-14","dr":"2023-06-27","k":"Regulatory Action","rg":"Other","reg":"Bank of Portugal","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5649.0,"dk":"602/22/CO","al":"On June 27, 2023, the Bank of Portugal found that Deutsche Bank AG, portugal branch (\"DBAG\") violated article 71(1) of the general regime of credit institutions and financial companies by failing to register the termination of a former manager's duties within thirty days of the manager's resignation.","res":"Order","sm":"On June 27, 2023, the Bank of Portugal found that dbag violated article 71(1) of the general regime of credit institutions and financial companies by failing to register the termination of a former manager's duties within thirty days of the manager's resignation. The Bank of Portugal fined dbag 5,000 euros which is approximately $5,649 usd. The fine was timely paid on July 11, 2023.","ab":"Deutsche Bank AG","firms":[300838],"id":667},{"d":"2023-06-22","di":"2023-06-22","dr":"2023-06-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":4000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21502","al":"On June 22, 2023, J.P. Morgan Securities LLC (\"JPMS\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). JPMS consented to the entry of the order, which found that JPMS willfully violated section 17(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rule 17A-4(b)(4) thereunder. The order arose out of the deletion of approximately 47 million electronic communications, in connection with a vendor error, from the time period January 1, 2018 through April 23, 2018, certain of which were business records required to be retained pursuant to section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":668},{"d":"2023-06-22","di":"2023-05-08","dr":"2023-06-22","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":183000.0,"dk":"2023-404B-017","al":"ICE Clear Credit LLC (\"ICC\") imposed a penalty of $183,000 on Goldman Sachs international (\"GSI\") for failure to submit daily pricing information of index and single name products.","res":"Decision","sm":"After reviewing gsi's response to the finding, including corrective measures to minimize risk of future reoccurrences, icc applied waivers available once annually to the previously imposed penalty.","ab":"Goldman Sachs","firms":[361],"id":669},{"d":"2023-06-22","di":"2023-05-08","dr":"2023-06-22","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":153000.0,"dk":"2023-404B-016","al":"ICE Clear Credit LLC (\"ICC\") imposed a penalty of $153,000 on Goldman Sachs & Co. LLC (\"GSCO\") for failure to submit daily pricing information of index and single name products.","res":"Decision","sm":"After reviewing gsco's response to the finding, including corrective measures to minimize risk of future reoccurrences, icc applied waivers available once annually to the previously imposed penalty.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":670},{"d":"2023-06-20","di":"2023-06-20","dr":"2023-06-20","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, and disgorgement","st":"Final","fine":1500000.0,"dk":"3-21499","al":"The SEC found that Insight charged excess management fees to certain funds it manages due to an inaccurate application of insights permanent impairment policy, failed to disclose to investors a conflict of interest concerning that policy and did not adopt or implement written policies or procedures reasonably designed to prevent violations of the Advisers Act relating to the above practices. Insight did not admit or deny the findings.","res":"Order","sd":"Insight was ordered to pay a civil monetary penalty in the amount of $1,500,000. Insight paid $1,500,000 to the Securities and Exchange Commission on June 21, 2023. Insight was also ordered to pay disgorgement and pre-judgment interest in the amount of $864,958.17. That payment was deemed satisfied by payments Insight made in May 2023 to the relevant private funds.","sm":"On June 20, 2023, the Securities and Exchange Commission (\"SEC\") initiated a settled administrative proceeding against Insight. Insight neither admitted nor denied the SEC's findings. From August 2017 through April 2021, the limited partnership agreements (\"LPAS\") of certain of the funds Insight advised provided that Insight would charge management fees during the funds' post- ( ) commitment periods based on each investor's pro rata share of the funds' invested capital, which equaled the acquisition cost of the portfolio investments held by the funds. The LPAS for these funds also stated that should Insight determine that a portfolio investment had suffered a \"permanent impairment\" in value, Insight would remove an amount equal to the difference between the acquisition cost and the impaired value of the portfolio investment from the fund's invested capital, which would subsequently reduce the basis used to calculate the management fees paid by the respective fund to Insight. Insight developed and applied criteria to assess whether an investment was permanently impaired. In applying these criteria, however, Insight analyzed permanent impairment at the \"portfolio company\" level rather than at the \"portfolio investment\" level. As a result, the SEC found that Insight did not correctly apply the funds' LPAS in making a permanent impairment determination and, consequently, failed to accurately calculate the management fees it charged resulting in Insight charging the funds excess management fees of $773,754. Further, the SEC found that Insight failed to disclose to investors the existence of a conflict of interest in connection with its permanent impairment criteria. Finally, the SEC found that Insight did not adopt or implement written policies or procedures reasonably designed to prevent violations of the Advisers Act relating to the above practices. As a result, the SEC found that Insight violated sections 206(2) and 206(4) of the Advisers Act and rules 206(4)-7 and 206(4)-8 thereunder. The SEC ordered Insight to cease and desist from committing or causing any violations and any future violations of the referenced sections and rules, imposed a censure, required disgorgement and pre-judgment interest of $864,958, and imposed a civil monetary penalty of $1,500,000. As part of the resolution of this matter, the SEC recognized remedial efforts undertaken by Insight in May 2021 that included: adopting new and more objective permanent impairment criteria and disclosing that criteria to investors; waiving its ability going forward to reverse a permanent impairment due to changed circumstances; and applying its revised permanent impairment criteria retroactively to four portfolio companies that had been identified by the SEC, leading to reimbursement of management fees and interest in the amount of $3,821,032 to the relevant private funds. No information Filed","ab":"Insight Venture Management, LLC","self":true,"firms":[142994],"id":671},{"d":"2023-06-20","di":"2023-06-09","dr":"2023-06-20","k":"Regulatory Action","rg":"Other","reg":"Bank of Portugal","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6780.0,"dk":"261/22/CO","al":"On June 20, 2023, the Bank of Portugal found that Deutsche Bank AG, portugal branch (\"DBAG\") violated articles 103(1) and 114(1) of the general regime of credit institutions and financial companies by allowing debit transactions to a customer's account that were not authorized by the customer and failing to make timely repayment and reimbursement of such debits.","res":"Order","sm":"On June 20, 2023, the Bank of Portugal found that dbag violated article 103(1) and 114(1) of the general regime of credit institutions and financial companies by allowing debit transactions to a customer's account that were not authorized by the customer and failing to make timely repayment and reimbursement. The Bank of Portugal fined dbag 6,000 euros which is approximately $6,780 usd. The fine was timely paid on July 5, 2023.","ab":"Deutsche Bank AG","firms":[300838],"id":672},{"d":"2023-06-16","di":"2023-06-16","dr":"2023-06-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":2500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21489","al":"On June 16, 2023, PIMCO entered into a settlement agreement with the SEC relating to an error in the fee waiver calculation used by PIMCO's third-party vendor that caused certain advisory fees to be under-waived from April 2011 to November 2017 and charged to PIMCO all asset all authority fund (\"A4\"). Under the terms of the settlement, PIMCO agreed to pay to the SEC a civil monetary penalty in the amount of $2.5 million. Prior to the SEC's investigation, PIMCO had identified the error, publicly disclosed the issue and implemented a plan that reimbursed A4 and its shareholders for any losses associated with the fee waiver miscalculation. In addition, PIMCO has enhanced its policies and procedures relating to its oversight of the third-party vendor's advisory fee calculations.","res":"Settled","sd":"Pursuant to the settlement, the SEC ordered a civil monetary penalty in the amount of $2.5 million. The penalty will be paid within 10 days of the entry of the order. No portion of the penalty was waived.","sm":"On June 16, 2023, the SEC announced an agreement with PIMCO to settle the charges relating to A4. The SEC administrative order is final. The civil monetary penalty will be paid within 10 days of the entry of the order.","ab":"Pacific Investment Management Company LLC","self":true,"firms":[104559],"id":673},{"d":"2023-06-16","di":"2023-06-16","dr":"2023-06-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":6500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21490","al":"On June 16, 2023, PIMCO entered into a settlement agreement with the SEC relating to certain disclosures in the 2014 and 2015 annual shareholder reports of PIMCO global stocksplus & income fund (\"PGP\") regarding PGP's use of paired interest rate swaps in its portfolio. Under the terms of the settlement, PIMCO agreed to pay to the SEC a civil monetary penalty in the amount of $6.5 million. Prior to the SEC's investigation, PIMCO had updated the disclosures in PGP's 2016 annual shareholder report.","res":"Settled","sd":"Pursuant to the settlement, the SEC ordered a civil monetary penalty in the amount of $6.5 million. The penalty will be paid within 10 days of the entry of the order. No portion of the penalty was waived.","sm":"On June 16, 2023, the Securities and Exchange Commission (\"SEC\") announced an agreement with PIMCO to settle the charges relating to PGP. The SEC administrative order is final. The civil monetary penalty will be paid within 10 days of the entry of the order.","ab":"Pacific Investment Management Company LLC","self":true,"firms":[104559],"id":674},{"d":"2023-06-13","di":"2023-04-10","dr":"2023-06-13","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","st":"Final","fine":5000.0,"dk":"E-CASE NO. 2964","al":"The Minnesota commissioner of commerce and Mutual of America Life Insurance Company(\"life company\") entered into a consent order for violations of Minnesota insurance laws regarding failing to: act reasonably promptly in response to communications about claims arising under insurance policies; provide all necessary claim forms and instructions for processing the insurance claims; and promptly reply to all communications about insurance claims that reasonably indicate a response is requested or needed.","res":"Order","sd":"Mutual of America Life Insurance Company was ordered to pay a civil penalty of $5,000.","sm":"Mutual of America Life Insurance Company agreed to an informal disposition of this matter without a hearing. Mutual of America Life Insurance Company was ordered to pay a civil penalty of $5,000 and review it's policies and procedures. No information Filed","ab":"Mutual of America Life Insurance Company","self":true,"firms":[15356],"id":675},{"d":"2023-06-12","di":"2023-06-12","dr":"2023-06-12","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":180000.0,"dk":"2021.05.0319","al":"The Nasdaq enforcement department (the \"staff\") reviewed the firm's compliance with Nasdaq rules requiring members to input the correct capacity codes on equity orders entered into exchange systems between August 28, 2015 and November 2, 2020. As a result of its review, the staff determined that the firm input the incorrect capacity code on hundreds of millions of equity orders it entered into multiple exchanges, including over 40,485,994 orders it input into the Nasdaq system with incorrect capacity codes.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":676},{"d":"2023-06-12","di":"2023-06-12","dr":"2023-06-12","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"dk":"2021.05.0319","al":"The PHLX enforcement department reviewed the firm's compliance with PHLX rules requiring members to input the correct capacity codes on equity orders entered into exchange systems between August 28, 2015 and November 2, 2020. The entry of inaccurate capacity codes causes the audit trail to be inaccurate, which can as a result of its review, the staff determined that the firm input the incorrect capacity code on hundreds of millions of equity orders it entered into multiple exchanges, including over 11,187,701 orders it input into the PSX system with incorrect capacity codes.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":677},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Other","st":"Final","fine":10000.0,"dk":"2022-03-17-00037","al":"Without admitting or denying the findings, the firm (\"RBCCM\") consented to the sanctions and to the entry of findings that it violated: (I) NYSE American rule 7.33e by submitting over 151,000 principal orders incorrectly marked as agency orders to NYSE American from October 2019 through March 2020; and (II) NYSE American rules 3110(a) and 3110(b) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations during the period from August 2015 through November 2020. During the period from October 2019 through March 2020, the firm incorrectly entered over 151,000 orders into the NYSE American marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code due to a coding error impacting a firm trading platform (the \"oms\") that flipped the reported capacity from principal to agency. From August 2015 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE American rules requiring that orders submitted to the exchange are marked with accurate agency or principal capacity codes. Specifically, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering the oms was not correctly populated, resulting in \"null\" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months. Additionally, from August 2015 through November 2020, the firm's surveillance review failed to include data from another of its trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":678},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE Chicago, Inc.","san":"Other","st":"Final","fine":5000.0,"dk":"2022-03-17-00037","al":"Without admitting or denying the findings, the firm (\"RBCCM\") consented to the sanctions and to the entry of findings that during the period from October 2019 through March 2020, it incorrectly entered 2,384 orders into the NYSE Chicago marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code due to a coding error impacting a firm trading platform (the \"oms\") that flipped the reported capacity from principal to agency. The firm's surveillance review failed to detect that these orders were being entered with an incorrect capacity code because it was not functioning properly. Specifically, a field within the surveillance report covering the oms was not correctly populated, resulting in \"null\" values that prevented the generation of alerts for incorrect capacity codes. Additionally, from August 2015 through November 2020, the firm's surveillance review failed to include data from another of the firm's trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years. As discussed above, a coding error impacting the oms resulted in the firm incorrectly entering 2,384 orders into the NYSE Chicago marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code during the period from October 2019 through March 2020. Accordingly, the firm violated NYSE Chicago rule 7.33. From August 2015 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE Chicago rules requiring that orders submitted to the exchange are marked with accurate capacity codes. The firm's supervisory review designed to ensure compliance with its order marking obligations was not functioning properly for a period of nearly six months from October 2019 through March 2020, resulting in a failure to detect that orders submitted to the exchange were being entered with incorrect capacity codes. Additionally, the firm's supervisory review failed to include data from another firm trading platform, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years. Accordingly, the firm violated NYSE Chicago article 6, rules 5(a) and 5(c).","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":679},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Other","st":"Final","fine":75000.0,"dk":"2022-03-17-00037","al":"Without admitting or denying the findings, the firm (\"RBCCM\") consented to the sanctions and to the entry of findings that during the period between August 2015 and November 2020 (the \"relevant period\"), it violated: (I) NYSE ARCA rule 7.33-E1 by submitting over 665,000 agency orders incorrectly marked as principal orders and over 12.1 million principal orders incorrectly marked as agency orders to NYSE ARCA; and (II) NYSE ARCA rules 11.18(b) and 11.18(c) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations. During the relevant period, two distinct issues involving two different firm trading platforms resulted in RBCCM incorrectly marking certain principal orders as agency and certain agency orders as principal. First, during the period from August 2015 through November 2020, a failure to update relevant account type code settings on a firm trading platform (\"oms #1\") resulted in the firm incorrectly entering: (I) over 11.7 million orders into the NYSE ARCA marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code; and (II) over 665,000 orders into the NYSE ARCA marketplace marked with the \"principal\" capacity code when the orders should have been marked with the \"agency\" capacity code. Second, during the period from October 2019 through March 2020, the firm incorrectly entered over 398,000 orders into the NYSE ARCA marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code due to a coding error impacting a different firm trading platform (\"oms #2\") that flipped the reported capacity from principal to agency. During the relevant period, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE ARCA rules requiring that orders submitted to NYSE ARCA are marked with accurate agency or principal capacity codes. Specifically, the firm's surveillance review failed to include data from oms #1 during the entirety of the relevant period, resulting in a failure to detect the ongoing capacity code violations that impacted this trading platform for a period of more than five years. Additionally, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering oms #2 was not correctly populated, resulting in \"null\" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":680},{"d":"2023-06-05","di":"2023-06-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE National, Inc.","san":"Other","st":"Final","fine":15000.0,"dk":"2022-03-17-00037","al":"Without admitting or denying the findings, the firm (\"RBCCM\") consented to the sanctions and to the entry of findings that it violated: (I) NYSE National rule 7.33 by submitting over 401,000 principal orders incorrectly marked as agency orders to NYSE National from October 2019 through March 2020; and (II) NYSE National rules 11.3.2 and 11.5.1 by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations during the period from May 2018 through November 2020. During the period from October 2019 through March 2020, the firm incorrectly entered over 401,000 orders into the NYSE National marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code due to a coding error impacting a firm trading platform (the \"oms\") that flipped the reported capacity from principal to agency. From May 2018 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE american rules requiring that orders submitted to the exchange are marked with accurate agency or principal capacity codes. Specifically, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering the oms was not correctly populated, resulting in \"null\" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months. Additionally, from May 2018 through November 2020, the firm's surveillance review failed to include data from another of its trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of several years.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":681},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Other","st":"Final","fine":185000.0,"dk":"2022-03-17-00037","al":"Without admitting or denying the findings, the firm (\"RBCCM\") consented to the sanctions and to the entry of findings that during the period between August 2015 and November 2020 (the \"relevant period\"), it violated: (I) NYSE rule 132 (for certain orders sent before July 27, 2017) and (II) NYSE rule 7.33 (for certain orders sent on or after July 27, 2017) by submitting over 80.1 million agency orders incorrectly marked as principal orders and approximately 333,000 principal orders incorrectly marked as agency orders to the New York Stock Exchange LLC (the \"NYSE\" or the \"exchange\"); and (III) NYSE rules 3110(a) and 3110(b) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations. During the relevant period, two distinct issues involving two different firm trading platforms resulted in RBCCM incorrectly marking certain principal orders as agency and certain agency orders as principal. First, during the period from August 2015 through November 2020, a failure to update relevant account type code settings on a firm trading platform (\"oms #1\") resulted in the firm incorrectly entering: (I) over 88,000 orders into the NYSE marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code; and (II) over 80.1 million orders into the NYSE marketplace marked with the \"principal\" capacity code when the orders should have been marked with the \"agency\" capacity code. Second, during the period from October 2019 through March 2020, the firm incorrectly entered approximately 245,000 orders into the NYSE marketplace marked with the \"agency\" capacity code when the orders should have been marked with the \"principal\" capacity code due to a coding error impacting a different firm trading platform (\"oms #2\") that flipped the reported capacity from principal to agency. The findings also stated that during the relevant period, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE rules requiring that orders submitted to the NYSE are marked with accurate agency or principal capacity codes. Specifically, the firm's surveillance review failed to include data from oms #1 during the entirety of the relevant period, resulting in a failure to detect the ongoing capacity code violations that impacted this trading platform for a period of more than five years. Additionally, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering oms #2 was not correctly populated, resulting in \"null\" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":682},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":67500.0,"dk":"2020066722501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it reported to FINRA orders with an inaccurate capacity code. The finding stated that the firm reported principal orders to trade reporting facilities from, among others, three internal accounts. However, the firm incorrectly marked the transactions from these accounts due to a coding error that flipped the reported capacity from principal to agency. As a result, the firm reported orders to the trade reporting facilities with an inaccurate capacity. In addition, the firm sent orders on its own behalf as well as on behalf of certain affiliates using one of its proprietary order management systems. Whether an order should be marked as principal or agency depends on the terms of the agreement between the market center to which the order is routed and the entity on whose behalf the order was being routed. At various times during this period, updates to the relevant agreements required the firm to change the capacity it reported for certain transactions. However, the firm failed to make corresponding updates to the order management system so that the correct capacity would be reported. Because the firm's reporting logic relied on these outdated settings, the firm reported orders to the trade reporting facilities with an inaccurate capacity. The findings stated that the firm had recordkeeping violations due to the order memoranda for the above-referenced transactions including the incorrect capacity. For example, at times the order memoranda indicated that it was a principal transaction when it was an agency transaction, or vice versa. The findings also included that the firm supervised for the accuracy of the order capacities it reported with two exception reports. However, these exception reports did not include transactions from the proprietary order management system the firm used to route orders with an inaccurate capacity. As a result, the firm failed to identify these inaccuracies. The firm has since remediated this supervisory failure.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":683},{"d":"2023-06-05","di":"2023-06-05","dr":"2023-06-05","k":"Regulatory Action","rg":"Other","reg":"Investors' Exchange LLC","san":"Other","st":"Final","fine":675000.0,"dk":"2020066722502","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm routed orders to iex with an inaccurate capacity code as a result of two separate issues. The findings stated that the firm routed principal orders to iex from, among others, three internal accounts. However, the firm incorrectly marked the transactions from these three accounts due to a coding error that flipped the reported capacity from principal to agency. As a result, the firm routed orders to iex with an inaccurate capacity code. In addition, the firm sent orders on its own behalf as well as on behalf of certain affiliates using one of its proprietary order management systems. Whether an order should be marked as principal or agency depends on the terms of the agreement between the market center to which the order is routed and the entity on whose behalf the order was being routed. At various times during this period, updates to the relevant agreements required the firm to change the capacity it reported for certain transactions. The firm failed, however, to make corresponding updates to the order management system so that the correct capacity would be reported. Because the firm's reporting logic relied on these outdated settings, the firm routed orders to iex with an inaccurate capacity code. The findings also stated that the firm had recordkeeping violations due to the order memoranda for the above referenced transactions including the incorrect capacity code. For example, at times the order memoranda indicated that it was a principal transaction when it was an agency transaction, or vice versa. The findings also included that the firm supervised for the accuracy of the order capacities it reported with two exception reports. However, these exception reports did not include transactions from the order management system the firm used to route orders with an inaccurate capacity code. As a result, the firm failed to identify these inaccuracies. The firm has since remediated the supervisory failure.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":684},{"d":"2023-05-30","di":"2023-05-30","dr":"2023-05-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":1400000.0,"dk":"3-21473","al":"On May 30, 2023, the SEC issued an order finding that RTW (1) failed to disclose certain conflicts of interest regarding its personnel's co-investment with the funds in the sponsors of spacs in which RTW advised funds to invest and (2) failed to timely file accurate reports on schedule 13g concerning beneficial ownership of stock in a public company. RTW consented to the entry of the SEC's order finding that it violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rules 206(4)-7 and 206(4)-8, as well as section 13(d) of the Securities Exchange Act of 1934 and rules 13D-1 and 13D-2. Without admitting or denying the findings, RTW agreed to a cease-and-desist order, a censure, and a $1.4 million penalty to settle the charges.","res":"Settled","sd":"The applicant consented to the SEC's order finding it violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rules 206(4)-7 and 206(4)-8, as well as section 13(d) of the Securities Exchange Act of 1934 and rules 13D-1 and 13d-","sm":"The SEC matter was settled on May 30, 2023 pursuant to the order described above. No information Filed","ab":"RTW Investments LP","self":true,"firms":[153232],"id":685},{"d":"2023-05-26","di":"2023-05-26","dr":"2023-05-26","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission)","san":"Other","os":"Voluntary corrective measures, fine KRW 37.8mil / usd 29,348 (exchange rate 1,288)","st":"Final","fine":29348.0,"al":"Financial services commission alleged that Samsung Life Insurance co., LTD. failed to notify the employers or its representative of the result of reserve calculation as prescribed by the act on the guarantee of employees' retirement benefits in korea.","res":"Other","sd":"On May 26, 2023, the financial services commission (FSC) issued a notice of its decision, finding that Samsung securities co., LTD. is liable for the allegations listed in our answers to question 7. As a result, FSC imposed a fine of KRW 37.8mil, issued a warning to its employee, and ordered to take voluntary corrective measures.","ab":"Samsung Life Insurance","firms":[158319],"id":686},{"d":"2023-05-25","di":"2023-05-25","dr":"2023-05-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":800000.0,"dk":"2020068469601","al":"FINRA found that from November 2019 to September 2020, VMC overstated projected yield and projected annual income for nine money market funds on certain brokerage account statements. FINRA also found that from at least October 2019 to June 2021, certain account statements inaccurately presented market appreciation/depreciation and investment returns. The aforementioned errors did not affect the actual market yield paid to customers or holdings information displayed on customer statements and have been resolved. FINRA also found that the firm failed to reasonably supervise its account statements by failing to timely address customer reports of inaccuracies. Therefore, FINRA found that VMC violated FINRA rules 2210, 3110, 4511 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $800,000. VMC paid the fine by wire on June 1, 2023.","sm":"Without admitting or denying the allegations or findings, VMC agreed to the imposition of a censure and a fine in the amount of $800,000, VMC's letter of acceptance, waiver and consent was accepted by FINRA on May 25, 2023.","ab":"Vanguard Marketing","firms":[105958],"id":687},{"d":"2023-05-22","di":"2023-05-22","dr":"2023-05-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":562500.0,"dk":"2018058111302","al":"JPMS consented to sanctions and to entry of findings that, from January 2019 to July 2022, JPMS' financial risk management controls and supervisory procedures were not reasonably designed to prevent certain erroneous orders that exceeded appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicated duplicative orders, in violation of section 15(c)(3) of the Securities Exchange Act of 1934, rule 15C3-5(b) and (c)(1)(II) thereunder, Nasdaq rules 3010, 2010a, and general 9, sections 20 and 1(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":688},{"d":"2023-05-22","di":"2023-05-22","dr":"2023-05-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":187500.0,"dk":"2018058111301","al":"Without admitting or denying the findings, J.P. Morgan Securities (the \"firm\") consented to sanctions and to the entry of findings that, from January 2019 to July 2022, the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent certain erroneous orders that exceeded appropriate price or size parameters, on an order-by- order basis or over a short period of time, or that indicated duplicative orders, in violation of section 15(c)(3) of the Securities Exchange Act of 1934, rule 15C3-5(b) and (c)(1)(II) thereunder, and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":689},{"d":"2023-05-22","di":"2023-02-27","dr":"2023-05-22","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":175000.0,"dk":"CASE NO. 2022-4","al":"Bloomberg SEF LLC (\"BSEF\") found that Deutsche Bank AG (\"Dbag\") failed to report error trades in a timely manner in accordance with BSEF rules, and that DBAG failed to administer supervisory procedures to ensure that error trades were properly reported and corrected on BSEF despite numerous previous violations.","res":"Settled","sm":"On May 22, 2023, dbag, without admitting or denying the findings contained therein, entered into a settlement with BSEF, in which BSEF found that dbag failed to report error trades in a timely manner in accordance with BSEF rules, and that dbag failed to administer supervisory procedures to ensure that error trades were properly reported and corrected on BSEF despite numerous prevous violations. Dbag agreed to a fine of usd $175,000, which was timely paid on June 7, 2023.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":690},{"d":"2023-05-06","di":"2023-05-26","dr":"2023-05-06","k":"Regulatory Action","rg":"State regulator","reg":"Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Penalty and cost of investigation","st":"Final","fine":10000.0,"dk":"SEC-2023-00009","al":"Federallly covered investment advisor firm RBC Capital Markets, LLC allegedly employed an investment advisor representative in the commonwealth of Virginia without that person being duly registered with the division of securities and retail franchising of the state corporation commission of Virginia, in violation of § 13.1­504 c (II) of the Virginia Securities Act. The representative was registered in another state but moved offices with RBC.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":691},{"d":"2023-05-02","di":"2023-05-02","dr":"2023-05-02","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Department of State Bureau of Securities Regulation","san":"Cease and Desist","st":"Final","fine":650000.0,"dk":"I-2022000023","al":"The State of New Hampshire Department of State Bureau of Securities Regulation (NHBSR) alleged that certain representatives of Merrill Lynch, Pierce, Fenner & Smith (the firm) who were enrolled in the firm's financial advisor development program as trainees did not properly employ firm-provided technology to pre-screen potential unsolicited telemarketing calls and/or did not comply with screening results that identified prohibited numbers on the national do not call registry or the firm's internal do not call list thereby resulting violations of certain FINRA rules, in violation of New Hampshire revised statutes annotated (N.H. Rsa) 421-b:4-406(k).","res":"Order","sm":"Without admitting or denying the findings, the firm agreed to: (a) cease and desist from further violations of N.H. Rsa 421-b:4- 406(k) through failure to reasonably supervise its registered agents pertaining to telemarketing practices, (b) pay a fine in the amount of $650,000, and (c) pay the NHBSR's costs of investigation in the amount of $50,000. The fine and costs of investigation will be paid in accordance with the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":692},{"d":"2023-05-01","di":"2023-05-01","dr":"2023-05-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":700000.0,"dk":"2019062900001","al":"The Financial Industry Regulatory Authority alleged that between January 2018 and January 2020 representatives of Merrill Lynch, Pierce, Fenner & Smith (the firm) who were enrolled in the firm's financial advisor development program as trainees placed thousands of telemarketing calls to telephone numbers that appeared on the national do-not-call registry as well as the firm's do-not-call list, in violation of FINRA rule 3230 and 2010; and the firm failed to establish and maintain a supervisory system reasonably designed to ensure that trainees did not place unsolicited telemarketing calls to individuals on the national do- not-call registry and the firm's do-not-call list, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to the imposition of a censure and a fine in the amount of $700,000. The fine will be paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":693},{"d":"2023-04-28","di":"2023-04-28","dr":"2023-04-28","k":"Regulatory Action","rg":"Other","reg":"Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure; cease and desist; and undertakings.","st":"Final","fine":2500000.0,"dk":"E-2022-0052; E-2023-0004","al":"Stifel failed to supervise its agents: (1) Stifel did not reasonably supervise Massachusetts registered agent's (a former employee) trading in customer accounts; (2) Stifel did not reasonably monitor use of off-channel electronic devices by agents to conduct Stifel business; (3) Stifel did not reasonably review and approve retail communications prior to distribution.","res":"Consent","sm":"Without admitting or denying the violation of law contained in the consent order, Stifel agreed to the above described sanctions. In addition, the division and Stifel agreed that the consent order is not intended to form the basis of any disqualifications under section 3(a)(39) of the Securities Exchange Act of 1934; rules 504(b)(3) and 506(d)(1) of regulation d, rule 262(a) of regulation a and rule 503(a) of regulation CF under the Securities Act of 1933; section 204(a)(2) of the uniform Securities Act of 1956 or section 412(d) of the uniform Securities Act of 2002. Furthermore, the division and Stifel agreed that the consent order is not intended to form the basis of disqualification under the FINRA rules prohibiting continuance in membership absent the filing of a MC-400A application or disqualification under sro rules prohibiting continuance in membership. Finally, the consent order is not intended to be a final order based upon violations of any Massachusetts statute, rule, or regulation that prohibit fraudulent, manipulative, or deceptive conduct.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":694},{"d":"2023-04-26","di":"2022-04-12","dr":"2023-04-26","k":"Regulatory Action","rg":"Other","reg":"Maryland Insurance Administration","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"MIA-2023-04-018","al":"In 2003 the insured purchased a flexible premium adjustable life insurance policy with a face amount $500,000. It was alleged that massmutual raised the premiums and changed and cancelled the policy without notifying the insured. The insured further alledged that the agent did not explain that the premium would be adjusted annually and that the agent misrepresented the product.","res":"Other","sd":"The Maryland insurance commission entered an order against massmutual, and within 30 dats of the date of order, massmutual will pay an administrative penalty of $1,000.","sm":"The state of Maryland determined that Massachusetts Mutual Life insurance company (\"massmutual\") violated the code of Maryland regulations (\"COMAR\") 31.09.15.11 and therefore subsection 4-113 of the insurance article by failing to send annual reports to an insured in 2020 and 2021. The administration did not find a violation by massmutual in its other actions complained by complainant. The Maryland insurance commission entered an order against massmutual, and within 30 days of the date of the order, massmutual will pay an administrative penalty of $1,000.","ab":"Massachusetts Mutual Life","firms":[106006],"id":695},{"d":"2023-04-26","di":"2022-04-12","dr":"2023-04-26","k":"Regulatory Action","rg":"Other","reg":"Maryland Insurance Administration","st":"Final","fine":10000.0,"dk":"MIA-2023-04-018","res":"Order","sd":"The Maryland insurance commission entered an order against massmutual, and within 30 days of the date of the order, massmutual will pay an administrative penalty of $1,000.","sm":"In 2003, the insured purchased a flexible premium adjustable life insurance policy with a face amount of $500,000. It was alleged that massmutual raised the premiums and changed and cancelled the policy without notifying the insured. The insured further alleged that the agent did not explain that the premium would be adjsuted annually and that the agent misrepresented the product. The state of Maryland determined that Massachusetts Mutual Life insurance company (\"massmutual\") violated code of Maryland regulations (\"COMAR\") 31.09.15.11 and therefore subsection 4-113 of the insurance article by failing to send annual reports to an insured in 2020 and 2021. The administration did not find a violation by massmutual in its other actions complained of by the complainant. The Maryland insurance commission entered an order against massmutual, and within 30 days of the date of the order, massmutual will pay an administrative penalty of $1,000. No information Filed","ab":"Massachusetts Mutual Life","firms":[162264],"id":696},{"d":"2023-04-14","di":"2023-04-14","dr":"2023-04-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":300000.0,"dk":"2019061442501","al":"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 reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock. The findings stated that while the firm's procedures called for supervisors to closely examine representatives' short-term trading of preferred stocks, the firm's electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Registered representatives at the firm recommended a number of the firm's retail customers purchase syndicate preferred stocks, and then sell the positions within 180 days, and the customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from the syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. While the firm's procedures called for supervisors to closely examine whether brokers were engaging in short-term trading of preferred stocks, the firm did not implement a supervisory system reasonably designed to monitor for that trading activity. The firm used its automated surveillance system to monitor trading, but employed no alerts specific to preferred stocks, and its more general alerts were not sufficiently reasonably tailored to monitor for potentially unsuitable short-term trading of preferred stock.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":697},{"d":"2023-04-14","di":"2023-04-14","dr":"2023-04-14","k":"Regulatory Action","rg":"Other","reg":"United States Securities & Exchange Commission","san":"Cease and Desist","os":"Censure and civil money penalty.","st":"Final","fine":1000000.0,"dk":"SEC AP FILE NO. 3-21369; SEC RELEASE NO. IA-6284","al":"On April 14, 2023, the SEC announced an order settling charges against Corvex, according to the SEC order, for failing to disclose conflicts of interest regarding its personnel's ownership of sponsors of three special purpose acquisition companies into which Corvex advised its client funds to invest. Without admitting or denying the findings, Corvex consented to the entry of the SEC's order finding that the firm violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder, and agreed to a cease and desist order, a censure, and a $1 million civil penalty to settle the charges.","res":"Settled","sd":"$1,000,000 civil monetary penalty was paid on 4/20/2023.","ab":"Corvex Management LP","self":true,"firms":[158197],"id":698},{"d":"2023-04-12","di":"2023-04-12","dr":"2023-04-12","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1750.0,"dk":"N/A","al":"Bloomberg SEF LLC (\"Bloomberg SEF\") alleged that Bank of America, National association (\"the firm\") failed to notify Bloomberg SEF of an error trade and failed to use Bloomberg SEF's offset and correct functionality, in violation of rule 516.","res":"Other","sm":"Without admitting or denying the rule violation upon which the notice of fine is based, the firm was ordered to pay a $1,750 fine. The payment was made in accordance with the terms of the notice of fine.","ab":"Bank of America, National","firms":[7691],"id":699},{"d":"2023-04-12","di":"2023-04-12","dr":"2023-04-12","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1250.0,"dk":"N/A","al":"Bloomberg SEF LLC (\"Bloomberg SEF\") alleged that Bank of America, National association (\"the firm\") failed to notify Bloomberg SEF of an error trade and failed to use Bloomberg SEF's offset and correct functionality, in violation of rule 516.","res":"Other","sm":"Without admitting or denying the rule violation upon which the notice of fine is based, the firm was ordered to pay a $1,250 fine. The payment was made in accordance with the terms of the notice of fine.","ab":"Bank of America, National","firms":[7691],"id":700},{"d":"2023-04-12","di":"2023-04-12","dr":"2023-04-12","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"N/A","al":"Bloomberg SEF LLC (\"Bloomberg SEF\") alleged that Bank of America, National association (\"the firm\") failed to notify Bloomberg SEF of an error trade and failed to use Bloomberg SEF's offset and correct functionality, in violation of rule 516.","res":"Other","sm":"Without admitting or denying the rule violation upon which the notice of fine is based, the firm was ordered to pay a $2,000 fine. The payment was made in accordance with the terms of the notice of fine.","ab":"Bank of America, National","firms":[7691],"id":701},{"d":"2023-04-10","di":"2023-04-10","dr":"2023-04-10","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","os":"N/a","st":"Final","fine":15000000.0,"dk":"23-09","al":"On April 10, 2023, the Commodity Futures Trading Commission (\"commission\" or \"CFTC\") issued an order against Goldman Sachs & Co. LLC (\"GSCO\"), accepting an offer of settlement submitted by GSCO. The CFTC found that from in or about April 2015 to at least September 2016 (\"relevant period\"), GSCO violated section 4s(h)(1) of the Commodity Exchange Act (\"act\"), 7 U.S.C. § 6s(h)(1), and sections 23.431 and 23.433, 17 C.F.R. §§ 23.431, 23.433, of the commission regulations (\"regulations\") in connection with certain swap transactions by failing to provide or providing inaccurate pre-trade-mid-market-marks (\"PTMMM\") to US-based counterparties and by failing to communicate in a fair and balanced manner based on principles of fair dealing and good faith. The swaps in question were equity-index swaps in which the equity leg of the swap was struck on the same day as the other material terms of the swap were agreed upon (\"same-day swaps\"), rather than the day after the date of agreement. GSCO admitted that for nearly all same-day swaps executed in 2015 and 2016 it either failed to disclose a PTMMM or failed to disclose an accurate PTMMM. GSCO netiher admitted nor denied the rest of the CFTC's findings.","res":"Order","sm":"The CFTC ordered that gsco cease and desist and pay a civil monetary penalty in the amount of $15,000,000. The fine was paid on April 20, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":702},{"d":"2023-04-10","di":"2023-05-16","dr":"2023-04-10","k":"Regulatory Action","rg":"Other","reg":"Canadian Investment Regulatory Organization (Formerly Investment Industry Regulatory Organization of Canada (IIROC).","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":21000.0,"al":"Between October 2019 and November 2019, the respondent entered orders for the shares of citation growth corp., that he ought reasonably to have known would create, or could reasonably be expected to create, a false or misleading appearance of trading activity or interest in the purchase or sale of the security, contrary to umir 2.2(2); and (b) between October 2019 and November 2019, the respondent failed to comply with his dealer member's policies and procedures by communicating with his client by way of text messages using unapproved third-party communication applications, contrary to investment dealer rule 1400","res":"Settled","sd":"2 month suspension $105 disgorgement","sm":"In 2023, martin was found guilty by ciro's enforcement division of: a) entering orders for a security that he ought reasonably to have known would create, or could reasonably be expected to create, a false or misleading appearance of trading activity or interest in the purchase or sale of the security, contrary to Canadian securities regulations, and b) using off-channel communication (text messaging) to communicate with clients, contrary to the policies and procedures of the broker-dealer that he was registered with at the time. Both aforementioned offenses occurred in oct to nov 2019. As such, martin was sanctioned by ciro with a fine of cad $21,000 ($15,000+ usd), a two-month suspension from the Canadian marketplace, disgorgement of commissions and paying back costs.","ab":"Danielak, Martin, Dominik","firms":[25853],"id":703},{"d":"2023-04-10","di":"2023-05-16","dr":"2023-04-10","k":"Regulatory Action","rg":"Other","reg":"Canadian Investment Regulatory Organization (Ciro), Formerly, Investment Industry Regulatory Organization of Canada (IIROC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15468.0,"al":"Between October 2019 and November 2019, the respondent entered orders for the shares of citation growth corp., that he ought reasonably to have known would create, or could reasonably be expected to create, a false or misleading appearance of trading activity or interest in the purchase or sale of the security, contrary to umir 2.2(2); and (b) between October 2019 and November 2019, the respondent failed to comply with his dealer member's policies and procedures by communicating with his client by way of text messages using unapproved third-party communication applications, contrary to investment dealer rule 1400","res":"Settled","sd":"Two months","sm":"In 2023, martin was found guilty by ciro's enforcement division of: a) entering orders for a security that he ought reasonably to have known would create, or could reasonably be expected to create, a false or misleading appearance of trading activity or interest in the purchase or sale of the security, contrary to Canadian securities regulations, and b) using off-channel communication (text messaging) to communicate with clients, contrary to the policies and procedures of the broker-dealer that he was registered with at the time. Both aforementioned offenses occurred in oct to nov 2019. As such, martin was sanctioned by ciro with a fine of cad $21,000 ($15,000+ usd), a two-month suspension from the Canadian marketplace, disgorgement of commissions and paying back costs.","ab":"Danielak, Martin, Dominik","firms":[25853],"id":704},{"d":"2023-04-04","di":"2022-04-22","dr":"2023-04-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1147500.0,"dk":"2018059146501","al":"On April 4, 2023, the Financial Industry Regulatory Authority (\"FINRA\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by goldmans Sachs & co. LLC (\"GSCO\"), in which GSCO neither admitted nor denied FINRA's findings. FINRA and 11 exchanges found, among other things, that GSCO incorrectly marked 59,981,252 short sale orders as long over a 3-year period from October 2015 to April 2018. The mismarked orders were caused by GSCO's implementation of an upgrade to relevant automated trading software that was intended to simplify certain order flow. According to the AWC, these mismarked orders violated rule 200(g) of the Exchange Act. The findings differ among the different exchanges and FINRA, but also generally allege trade reporting and recordkeeping violations as described in the AWC (no. 2018059146501). The firm corrected the coding and logic issues causing the mismarked orders upon notification of the same, has enhanced its order marking surveillance report, and also added an additional control designed to detect and prevent the routing of inaccurately marked short sale orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco agreed to pay a total monetary fine in the amount of $3,000,000. The allocation amount payable to FINRA is $1,147,500, which was paid in full via wire on April 19, 2023. The remainder of the fine will be allocated to CBOE byx exchange, inc., CBOE BZX exchange, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., investors exchange LLC, Nasdaq stock market LLC, Nasdaq BX, inc., Nasdaq PHLX LLC, New York Stock Exchange LLC, NYSE american LLC, and NYSE ARCA, inc. for similar violations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":705},{"d":"2023-04-04","di":"2022-04-22","dr":"2023-04-04","k":"Regulatory Action","rg":"Other","reg":"Investors Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":141100.0,"dk":"2018059146512","al":"On April 4, 2023, Investors Exchange LLC (\"iex\" or the \"exchange\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by goldmans Sachs & co. LLC (\"GSCO\"), in which GSCO neither admitted nor denied the exchange's findings. FINRA and 11 exchanges found, among other things, that GSCO incorrectly marked 59,981,252 short sale orders as long over a 3-year period from October 2015 to April 2018. The mismarked orders were caused by GSCO's implementation of an upgrade to relevant automated trading software that was intended to simplify certain order flow. According to the AWC, these mismarked orders violated rule 200(g) of the Exchange Act. The findings differ among the different exchanges and FINRA, but also generally allege trade reporting and recordkeeping violations as described in the AWC (no. 2018059146512). The firm corrected the coding and logic issues causing the mismarked orders upon notification of the same, has enhanced its order marking surveillance report, and also added an additional control designed to detect and prevent the routing of inaccurately marked short sale orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco agreed to pay a total monetary fine in the amount of $3,000,000. The allocation amount payable to iex is $141,100, which was paid in full via wire on April 20, 2023. The remainder of the fine will be allocated to CBOE byx exchange, inc., CBOE BZX exchange, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., Nasdaq stock market LLC, Nasdaq PHLX LLC, Nasdaq BX, inc., New York Stock Exchange LLC, NYSE american LLC, NYSE ARCA, inc. and the Financial Industry Regulatory Authority for similar violations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":706},{"d":"2023-04-04","di":"2022-04-22","dr":"2023-04-04","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":381400.0,"dk":"2018059146502","al":"On April 4, 2023, The Nasdaq Stock Market LLC (\"NASDAQ\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by goldmans Sachs & co. LLC (\"GSCO\"), in which GSCO neither admitted nor denied NASDAQ's findings. FINRA and 11 exchanges found, among other things, that GSCO incorrectly marked 59,981,252 short sale orders as long over a 3-year period from October 2015 to April 2018. The mismarked orders were caused by GSCO's implementation of an upgrade to relevant automated trading software that was intended to simplify certain order flow. According to the AWC, these mismarked orders violated rule 200(g) of the Exchange Act. The findings differ among the different exchanges and FINRA, but also generally allege trade reporting and recordkeeping violations as described in the AWC (no. 2018059146502). The firm corrected the coding and logic issues causing the mismarked orders upon notification of the same, has enhanced its order marking surveillance report, and also added an additional control designed to detect and prevent the routing of inaccurately marked short sale orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco agreed to pay a total monetary fine in the amount of $3,000,000. The allocation amount payable to Nasdaq is $381,400, which will be auto-debited. The remainder of the fine will be allocated to CBOE byx exchange, inc., CBOE BZX exchange, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., investors exchange LLC, Nasdaq PHLX LLC, Nasdaq BX, inc., New York Stock Exchange LLC, NYSE american LLC, NYSE ARCA, inc. and the Financial Industry Regulatory Authority for similar violations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":707},{"d":"2023-04-03","di":"2022-04-22","dr":"2023-04-03","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":92500.0,"dk":"2018059146507","al":"On March 21, 2023, the New York Stock Exchange LLC (\"NYSE\" or the \"exchange\") accepted a letter of acceptance, waiver, and consent (\"AWC\") submitted by goldmans Sachs & co. LLC (\"GSCO\"), in which GSCO neither admitted nor denied the exchange's findings. FINRA and 11 exchanges found, among other things, that GSCO incorrectly marked 59,981,252 short sale orders as long over a 3-year period from October 2015 to April 2018. The mismarked orders were caused by GSCO's implementation of an upgrade to relevant automated trading software that was intended to simplify certain order flow. According to the AWC, these mismarked orders violated rule 200(g) of the Exchange Act. The findings differ among the different exchanges and FINRA, but also generally allege trade reporting and recordkeeping violations as described in the AWC (no. 2018059146507). The firm corrected the coding and logic issues causing the mismarked orders upon notification of the same, has enhanced its order marking surveillance report, and also added an additional control designed to detect and prevent the routing of inaccurately marked short sale orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Pursuant to the AWC, gsco agreed to pay a total monetary fine in the amount of $3,000,000. The allocation amount payable to NYSE is $92,500, which was paid in full via wire on April 20, 2023. The remainder of the fine will be allocated to CBOE byx exchange, inc., CBOE BZX exchange, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., Nasdaq stock market LLC, Nasdaq PHLX LLC, Nasdaq BX, inc., NYSE american LLC, NYSE ARCA, inc, investors exchange LLC and the Financial Industry Regulatory Authority for similar violations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":708},{"d":"2023-04-03","di":"2023-04-03","dr":"2023-04-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":4800000.0,"dk":"FILE NO. 3-21356","al":"The Securities and Exchange Commission (\"SEC\") alleged, that from May 12, 2016 to June 29, 2020 (1) certain client agreements and ADV brochures for certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPF&s\") advisory programs contained material misstatements because while disclosing that MLPF&s charged a markup or markdown on foreign currency exchanges, the disclosures did not also state that an additional fee referred to as a production credit was also charged, in willful violation of sections 206(2) and (4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and Advisers Act rule 206(4)-7 thereunder and (2) MLPF&s failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients.","res":"Order","sm":"Without admitting or denying the findings, MLPF&s agreed to: (a) cease and desist from committing or causing any violations or any future violations of sections 206(2) and (4) of the Advisers Act and Advisers Act rule 206(4)-7 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $4,800,000, and (d) pay disgorgement in the amount of $4,134,610 and prejudgment interest in the amount of $760,104. The civil monetary penalty, disgorgement, and prejudgment interest were paid in accordance with the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":709},{"d":"2023-04-03","di":"2023-04-03","dr":"2023-04-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure; monetary fine and disgorgement; prohibition from serving or acting as an employee,officer, director, member of an","st":"Final","fine":5000000.0,"dk":"3-21355","al":"The order states that Chatham Asset Management, LLC (\"Chatham\") and Chatham's advisory affiliate anthony Melchiorre, on behalf of certain of Chatham's advisory clients, engaged in rebalancing trades in violation of section 206(2) of the Investment Advisers Act of 1940, as amended, (the \"Advisers Act\") and sections 17(a)(1) and 17(a)(2) of the Investment Company Act of 1940, as amended, (the \"Investment Company Act\") because the prices for those trades were not \"independently derived from price discovery in the broader market\".","res":"Settled","sd":"Civil penalty in respect of Chatham, $4,400,000. Civil penalty in respect of MR. Melchiorre, $600,000. Each of Chatham and MR. Melchiorre was censured and agreed to: (I) be prohibited from serving or acting as an employee, officer, director, member of an advisory board, investment adviser or depositor of, or principal underwriter for, a registered investment company or affiliated person of such investment adviser, depositor or principal underwriter; and (II) pay disgorgement of profits in the aggregate amount of $11,000,000 and pre-judgement interest in the aggregate amount of $3,375,072.","sm":"Without admitting or denying the SEC's findings, each of Chatham and MR. Melchiorre consented to the entry of an order by which each of them agreed to: (I) cease and desist from committing or causing any violations and any future violations of section 206(2) of the Advisers Act or section 17(a) of the Investment Company Act; (II) be censured; (III) pay the civil penalty, disgorgement and pre-judgement interest described above; and (IV) be prohibited from serving in certain capacities for a registered investment company described above. No information Filed","ab":"Melchiorre, Anthony,","firms":[157517],"id":710},{"d":"2023-03-31","di":"2023-03-17","dr":"2023-03-31","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"23-CH-2308","al":"On January 19, 2023, the clearing house risk committee of the CME Group Inc. (\"CME\") reviewed Goldman Sachs & Co. LLC's (\"GSCO\") response, and issued a charge letter dated January 20, 2023, which alleges that GSCO violated CME customer gross margining technical overview requirements and CME rule 980.g.","res":"Settled","sm":"Pursuant to an offer of settlement, in which gsco neither admitted nor denied the rule violation upon which the penalty was based, gsco agreed to pay a fine in the amount of $50,000. The fine was paid in full via gsco's CME clearing firm bank account on March 31, 2023.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":711},{"d":"2023-03-30","di":"2023-03-30","dr":"2023-03-30","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":90000.0,"dk":"2022.03.0378","al":"Exchange found that respondent improperly hedged its anticipated facilitation of customer orders prior to disclosure to the trading crowd of all material terms and conditions of the customer order, and that the respondent's supervisory system was not reasonably designed to ensure compliance with applicable sro anticipatory hedging rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The AWC was executed on March 30, 2023.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":712},{"d":"2023-03-30","di":"2023-03-30","dr":"2023-03-30","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":67762500.0,"dk":"22-011-CMP-HC","al":"On March 30TH, 2023, the Board of Governors of the Federal Reserve System (the \"Board of Governors\") issued an order of assessment of civil money penalty issued upon consent pursuant to the federal deposit insurance act, as amended (the \"order\") imposing a civil money penalty on Wells Fargo & Company (\"WFC\"), the applicant's parent entity, for unsafe and unsound practices relating to failures in WFC's risk-management and oversight framework for identifying and addressing legal and compliance risks. Specifically, WFC's subsidiary bank, Wells fargo bank, N.A., (the \"bank\"), provided a trade finance software platform to a non-US bank, which, during the period of December 2011 to December 2015, the non-US bank used to process non-US dollar trade finance instruments outside the US financial system involving parties in jurisdictions subject at the time to sanctions regulations. The order provides that WFC's risk-management and oversight framework failure to identify and address the legal and compliance risks with respect to the bank's provision of the software to a nonus bank constitutes unsafe and unsound practices.","res":"Order","sm":"The Board of Governors assessed a civil money penalty on Wells Fargo & Company for unsafe and unsound practices in respect of failures in its riskmanagement and oversight framework that enabled Wells Fargo & Company's subsidiary bank to provide a trading platform to a non-US bank that allowed that bank to process certain non-US dollar transactions involving parties in jurisdictions subject to OFAC regulations.","ab":"Wells Fargo & Company","firms":[11025,19616],"id":713},{"d":"2023-03-27","di":"2023-03-27","dr":"2023-03-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":45000.0,"dk":"NO. 2022-06-30-00019","al":"NYSE American LLC (\"NYSE American\") found that Citigroup Global Markets, inc. (\"the firm\") violated NYSE American rule 16 in connection with the handling of a customer options order.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm had previously offered restitution to its customer in the amount of $34,895, which the customer accepted, and also took certain remedial measures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":714},{"d":"2023-03-27","di":"2023-03-03","dr":"2023-03-27","k":"Regulatory Action","rg":"Other","reg":"Financial Markets Authority (Fma), New Zealand","san":"Reprimand","st":"Final","dk":"NA","al":"The fma issued a warning to Vanguard Investments Australia limited (VIA) for failing to comply with its financial markets conduct regulations 2014 requiring disclosure of three ASIC infringement notices \"as soon as practicable after the action is taken or the power is exercised and no later than 5 working days after the day on which the action is taken or the power is exercised.\"","res":"Other","sd":"A formal warning was issued.","sm":"The fma issued a formal warning to via for failing to lodge the required notice on the new zealand companies office disclose register within the required five-day timeframe regarding the three infringement notices issued by ASIC.","ab":"Vanguard Investments","firms":[105958],"id":715},{"d":"2023-03-22","di":"2022-04-22","dr":"2023-03-22","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":89758.0,"dk":"STAR NO. 20180591465-09/FILE NO. URE-40-06","al":"On March 24, 2023, CBOE Byx Exchange, Inc. (\"byx\" or the \"exchange\") accepted a letter of consent (\"LOC\") submitted by goldmans Sachs & co. LLC (\"GSCO\"), in which GSCO neither admitted nor denied the exchange's findings. FINRA and 11 exchanges found, among other things, that GSCO incorrectly marked 59,981,252 short sale orders as long over a 3-year period from October 2015 to April 2018. The mismarked orders were caused by GSCO's implementation of an upgrade to relevant automated trading software that was intended to simplify certain order flow. According to the LOC, these mismarked orders violated rule 200(g) of the Exchange Act. The findings differ among the different exchanges and FINRA, but also generally allege trade reporting and recordkeeping violations as described in the LOC. The firm corrected the coding and logic issues causing the mismarked orders upon notification of the same, has enhanced its order marking surveillance report, and also added an additional control designed to detect and prevent the routing of inaccurately marked short sale orders.","res":"Consent","sm":"Pursuant to the loc, gsco agreed to pay a total monetary fine in the amount of $3,000,000. The allocation amount payable to byx is $89,758, which was paid in full via wire on April 05, 2023. The remainder of the fine will be allocated to CBOE BZX exchange, inc., CBOE edga exchange, inc., CBOE edgx exchange, inc., Nasdaq stock market LLC, Nasdaq PHLX LLC, Nasdaq BX, inc., investors exchange LLC, New York Stock Exchange LLC, NYSE american LLC, NYSE ARCA, inc. and the Financial Industry Regulatory Authority for similar violations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":716},{"d":"2023-03-21","di":"2023-03-21","dr":"2023-03-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":65000.0,"dk":"2020-10-00074","al":"Exchange found that respondent improperly hedged its anticipated facilitation of customer orders prior to disclosure to the trading crowd of all material terms and conditions of the customer order, and that the respondent's supervisory system was not reasonably designed to ensure compliance with applicable sro anticipatory hedging rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The AWC was executed on March 21, 2023.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":717},{"d":"2023-03-21","di":"2023-03-21","dr":"2023-03-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":75000.0,"dk":"2020-10-00074","al":"Exchange found that respondent improperly hedged its anticipated facilitation of customer orders prior to disclosure to the trading crowd of all material terms and conditions of the customer order, and that the respondent's supervisory system was not reasonably designed to ensure compliance with applicable sro anticipatory hedging rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The AWC was executed on March 21, 2023.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":718},{"d":"2023-03-21","di":"2023-01-03","dr":"2023-03-21","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":200000.0,"dk":"ZRC 6-GW 2212-100003-2022/0001","al":"On March 21, 2023, German federal financial supervisory authority (\"BAFIN\") found that, from July 5, 2021 to September 6, 2021, Deutsche Bank AG (\"DBAG\") failed to timely file suspicious activity reports (\"SARS\") related to certain transactions in a client account as required by the German money laundering act.","res":"Order","sm":"On March 21, 2023, BAFIN found that, from July 5, 2021 to September 6, 2021, dbag failed to timely file sars related to certain transactions in a client account as required by the German money laundering act. Dbag was fined eur 177,503, which is approximately usd $200,000, which was timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":719},{"d":"2023-03-17","di":"2023-03-02","dr":"2023-03-17","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2022-014","al":"On March 2, 2023, the ICE Futures U.S. (\"ifus\" or \"exchange\") market regulation department completed a review of block trades submitted by j. Aron & co. LLC (\"j. Aron\") between July 2021 and November 2021, and found that on multiple instances, j. Aron submitted block trades to the exchange beyond the required reporting window thereby violating ifus rule 4.07(c).","res":"Decision","sm":"Pursuant to ifus rule 21.02, j. Aron was issued a summary fine in the amount of $5,000 for the violations. The fine was paid in full by submission of a wire on March 17, 2023.","ab":"J. Aron & Company LLC","firms":[361],"id":720},{"d":"2023-03-16","di":"2023-03-16","dr":"2023-03-16","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000000.0,"dk":"22-CH-2208","al":"The Chicago Mercantile Exchange Inc. (\"CME\") clearing house risk COMMITTEE (\"COMMITTEE\") found that Citigroup Global Markets, inc. (\"the firm\") violated customer gross margining technical overview requirements and CME rule 980.g. The firm neither admitted nor denied the rule violation upon which the penalty was based.","res":"Other","sm":"Without admitting or denying the findings, the firm agreed to a settlement under which it paid a $1,000,000 fine. The fine was paid in accordance with the terms of the disciplinary notice.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":721},{"d":"2023-03-16","di":"2023-03-16","dr":"2023-03-16","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":121723.0,"dk":"REF. NO DSA-2023-01-0230F_DSA-L-BA; DTS NO. DSA-2023-01-0230","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for non-compliance with the mandatory credit allocation for agrarian reform credit/other agricultural credit (agri- agra) for the quarters ended 3-31-2022 through 6-30-2022.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP6,701,462.54 (approximately USD121,723) on bana. The payment will be made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":722},{"d":"2023-03-13","di":"2023-03-13","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Other","os":"Pending","st":"Pending","dk":"2023-401I-001","al":"On March 13, 2023, ICE Clear Credit LLC (\"ICC\") alleged that a Goldman Sachs & Co. LLC (\"GSCO\") margin call payment was received six minutes after the required deadline resulting in a technical default in violation of ICE Clear Credit rule 401(I).","sm":"Gsco is in the process of responding to the allegations and detailing the circumstances relating to the subject margin payment. The matter is pending subject to review by icc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":723},{"d":"2023-03-10","di":"2022-09-26","dr":"2023-03-10","k":"Civil Judicial Action","san":"Injunction","os":"N/a","st":"Final","al":"The verbraucherzentrale baden­wÜrttemberg E.V. (\"VZBW\") alleged that DWS Investment GMBH (\"DWS\") made misleading statements in violation of the german act against unfair competition (\"UWG\") in two marketing documents for a fund entitled \"DWS invest ESG climate tech\" used vis­À­vis consumers in Germany.","res":"Settled","sd":"Pursuant to the out-of-court settlement (the \"settlement\") DWS and VZBW agreed that, beginning March 22, 2023, DWS would no longer use the two marketing documents for the fund DWS ESG climate tech vis­À­vis consumers in Germany without making certain changes to the marketing documents and issuing a corresponding declaration.","ab":"DWS Investment GMBH","firms":[300838],"id":724},{"d":"2023-03-08","di":"2021-12-23","dr":"2023-03-08","k":"Regulatory Action","rg":"Other","reg":"Swiss Financial Market Supervisory Authority and Swiss Federal Department of Finance","san":"Other","os":"Fine","st":"Final","fine":11050.0,"al":"On December 23, 2021, the firm received a letter from the Swiss financial market supervisory authority (\"FINMA\"), notifying the firm that FINMA was reviewing whether the firm or its controlling persons failed to timely meet disclosure obligations under the financial market infrastructure act (the \"fmia\") with regard to an investment made by York distressed asset fund IV (\"ydaf IV\") in ULTIMA capital AG (\"ULTIMA\"). The firm had timely notified ULTIMA and BX Swiss AG of the acquisition of an aggregate 7.27% interest in ULTIMA and the entry into a call and put option agreement with ULTIMA's two co-founders pursuant to which such co- founders were entitled to purchase voting shares. The call and put option agreement was terminated on October 15, 2020, and ULTIMA issued a press release noting the termination of the agreement and disclosing that York maintained its 7.27% position in ULTIMA. The firm did not make its own disclosure notification under the fmia act with regard to the termination of the call and put option agreement at that time. FINMA referred the matter to the Swiss federal department of finance (\"FDF\") as an administrative criminal matter to determine whether the firm or its controlling persons failed to timely meet disclosure obligations under the fmia. The FDF issued a final determination that the firm failed to timely meet its disclosure obligations with regard to the termination of the call and put option agreement and imposed a fine of CHF 10,000, which was at the lower end of the applicable penalty range, and procedural costs of CHF 1,050. The FDF decision was dated February 2, 2023, and became effective on March 8, 2023, upon the firm's determination to not appeal the FDF decision. To avoid the distraction and expense of litigation, York elected to accept the determination instead of seeking an appeal of the decision.","res":"Order","sd":"We are awaiting an invoice for the fine and the firm will pay the CHF 11,050 fine promptly upon receipt. No portion of the fine will be allocated to ydaf IV.","ab":"York Capital Management Global Advisors, LLC","self":true,"firms":[140336],"id":725},{"d":"2023-02-28","di":"2023-02-28","k":"Regulatory Action","dk":"112042-SR","ab":"Kelso, Jason, P","firms":[7691],"id":726},{"d":"2023-02-28","di":"2023-02-17","dr":"2023-02-28","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Disgorgement","st":"Final","fine":103591.0,"al":"The SEC alleged Hite purchased securities in a secondary offering when it sold short shares of the same security during the rule 105 (Regulation M) period.","res":"Consent","sd":"Hite Hedge Asset Management LLC paid a civil penalty in the amount of $103,591. As part of this action, Hite hedge LP was required to disgorge $19,042.63. Hite hedge II LP was required to disgorge $41,744.06. Hite hedge offshore LTD was required to disgorge $55,780.07","ab":"Hite Hedge Asset Management LLC","self":true,"firms":[160173],"id":727},{"d":"2023-02-27","di":"2022-03-31","dr":"2023-02-27","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"CASE NO. 2022-1, 2022-2, 2022-3","al":"Bloomberg SEF LLC (\"BSEF\") found that Deutsche bank AG (\"DBAG\") failed to report error trades in a timely manner in accordance with BSEF rules, and that DBAG failed to administer supervisory procedures to ensure that error trades were properly reported and corrected on BSEF despite numerous previous violations.","res":"Settled","sm":"On February 27, 2023, dbag, without admitting or denying the findings contained therein, entered into a settlement with BSEF, in which BSEF found that dbag failed to administer supervisory procedures to ensure that error trades were properly reported and corrected on BSEF despite numerous previous violations. Dbag agreed to a fine of usd $75,000, which was timely paid on March 14, 2023.","ab":"Deutsche Bank AG (\"DB AG\")","firms":[300838],"id":728},{"d":"2023-02-22","di":"2023-02-22","dr":"2023-02-22","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Public Prosecutor","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1965000.0,"dk":"7550 JS-OWI 255016/22","al":"The Frankfurt Public Prosecutor (\"FPP\") found that, from 2017 to 2022, Deutsche Bank AG (\"DB AG\") failed to timely file certain suspicious activity reports (\"SARS\") as required by the german money laundering act.","res":"Order","sm":"On February 22, 2023, the FPP issued a fine notice finding that, from 2017 to 2022, dbag failed to timely file certain sars as required by the german money laundering act. DB AG agreed to a fine of 1,830.000 euros, which is approximately usd 1,965,000, which will be timley paid.","ab":"Deutsche Bank AG (\"DB AG\")","firms":[300838],"id":729},{"d":"2023-02-21","di":"2023-02-21","dr":"2023-02-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","dk":"AP FILE NO: 3-21308","al":"The SEC alleged Hite Hedge Asset Management purchased securities in a secondary offering when it sold short shares of the same security within the rule 105 (Regulation M) restricted period.","res":"Decision & Order of Offer of Settlement","sd":"N/a","sm":"In February 2023, the SEC and Hite entered into a settlement to resolve a single violation of rule 105 of Regulation M. The SEC found that Hite violated rule 105 by participating in one secondary offering in 2021 while also selling short during the restricted period. Hite has resolved this matter without admitting or denying the SEC's findings. As part of this resolution, Hite agreed to cease and desist from violating and any future violations of rule 105. Hite also agreed to pay a one-time civil money penalty of $103,591. The funds that participated in the secondary offering were required to disgorge $111,629.52 and to pay prejudgment interest of $4,937.24; Hite has reimbursed the funds for this disgorgement and prejudgment interest to ensure that there would be no financial loss for investors as a result of this settlement. Hite has always taken rule 105 very seriously, and this event occurred despite our team following the appropriate compliance practices based in part on incorrect information from the underwriter about the nature of the offering. Since this occurrence, we have further enhanced our documentation and procedures based on the knowledge gained from this experience.","ab":"Hite Hedge Asset Management LLC","self":true,"firms":[160173],"id":730},{"d":"2023-02-17","di":"2022-06-14","dr":"2023-02-17","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":141000.0,"dk":"N.A.","al":"The indian regulator, securities & exchange board of india had issued a show cause notice dated 14 June 2022 to ltiml, an advisory affiliate and certain employees of ltiml alleging certain deficiencies and non-compliances with respect to certain provisions of sebi (mutual funds) regulations, 1996 in relation to the thematic inspection of inter-scheme transfers of the ltiml in the period from 01 April 2017 to 30 June 2018.","res":"Settled","sm":"HSBC Asset Management (India) Private Limited acquired the entire share capital of l&t investment management limited (\"LTIML\"), the asset management company of erstwhile l&t mutual fund, on 25 November 2022 (\"LTMF acquisition\"). Sebi had issued a show cause notice dated 14 June 2022 to LTIML and certain employees of LTIML alleging certain deficiencies and non-compliances with respect to certain provisions of sebi (mutual funds) regulations, 1996 in relation to the thematic inspection of inter-scheme transfers of the LTIML in the period from 01 April 2017 to 30 June 2018. LTIML along with the said employees had filed their response to the show cause notice on 21 September 2022. LTIML and the said employees had also filed a settlement application dated 29 July 2022 on 02 August 2022 under the sebi (settlement proceedings) regulations, 2018. Which was subsequently revised on 08 December 2022. Sebi has accepted the settlement terms and payment of the settlement amount was made, which was about usd 141,000. Subsequently, sebi issued the settlement order on 17 February 2023 and disposed off the show cause notice.","ab":"Shah, Jalpan, NMN","firms":[324468],"id":731},{"d":"2023-02-09","di":"2020-05-22","dr":"2023-02-09","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Market Commission","st":"Final","dk":"1052","al":"On May 22, 2023, FMR LLC, the registrant's ultimate parent company, received notice from the Hellenic Capital Market Commission (\"HCMC\") that FMR LLC failed to notify the HCMC and the issuing company of a change in shareholdings in a greek company in a timely manner. The notification was made three working days late. The late notification was a technical breach as a result of the corporate restructuring of the issuer.","res":"Decision","sd":"FMR LLC was ordered by the HCMC not to repeat the conduct constituting the noted infringement and no monetary penalties or fines were assessed.","ab":"FMR, LLC","firms":[104555,301896,315088],"id":732},{"d":"2023-02-08","di":"2022-05-30","dr":"2023-02-08","k":"Regulatory Action","rg":"Other","reg":"Bourse de Montreal Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Costs","st":"Final","fine":86347.75,"dk":"FILE NO. EN-DC-22001","al":"The Bourse de Montreal Inc. (\"Bourse\") alleged that Citigroup Global Markets Inc. provided access to certain of its employees to the electronic trading system of the Bourse without having obtained the prior approval of the Bourse and did not establish and maintain a system to supervise the activities of each employee that is reasonably designed to achieve compliance with the Bourse rules.","res":"Decision","sm":"Cgmi consented to a fine in the amount of cad 115,000 (approximately usd 86,347.75) and costs in the amount of cad 6085 (approximately usd 4568.92)","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":733},{"d":"2023-01-30","di":"2023-01-30","dr":"2023-01-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine","st":"Final","fine":300000.0,"dk":"2019061061201","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $300,000.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":734},{"d":"2023-01-09","di":"2022-09-29","dr":"2023-01-09","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":48797.47,"al":"The allegation is that on March 19, 2021 the fund sold securities that were not in custody in violation of korean regulatory prohibitions on short sales.","res":"Decision","sd":"In December 2022, the Securities and Futures Commission of Korea has fined Invesco Capital management LLC KRW 60 million ($48,797.47 usd) for the violation of short sale restrictions on March 19, 2021. Invesco Capital management LLC paid the fine on January 9, 2023.","sm":"In December 2022, the Securities and Futures Commission of Korea imposed a fine of against Invesco Capital management LLC for KRW 60 million ($48,797.47 usd) for the violation of short sale restrictions on March 19, 2021. Invesco Capital management LLC paid the fine on January 9, 2023.","ab":"Invesco Capital","firms":[104983],"id":735},{"d":"2022-12-31","di":"2021-05-03","dr":"2022-12-31","k":"Regulatory Action","rg":"Other","reg":"Bank of Italy","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3110540.0,"dk":"BANK OF ITALY NO.698152/2021","al":"Shortcomings in transparency and fairness in customer relations and incorrect application of commissions. The shortcomings have been remedied.","res":"Settled","sd":"In 2021 Banca Monte Dei Paschi Di siena S.P.A. Was fined by the Bank of Italy by eur 2,9 million for failure to act transparently and treat customers fairly. The shortcomings have been remedied and customers refunded by eur 40 million approximately.","sm":"Shortcomings have been remedied and customers have been refunded. The monetary fine has been paid in 2022 by Banca Monte Dei Paschi Di siena S.P.A. Without challenging it before the court of appeal. In 2025 there was another inspection of Bank of Italy on the same topic concluded with a positive score.","ab":"Banca Monte Dei Paschi Di","firms":[139138],"id":736},{"d":"2022-12-22","di":"2022-12-22","dr":"2022-12-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restituion","st":"Final","dk":"2021069495301","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that, between January 2015 and December 2021, its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 22, 2022, the firm became subject to a letter of acceptance, waiver and consent issued by FINRA regarding allegations that between January 2015 and December 2021, its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, in violation of FINRA rules 3110 and 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and restitution to affected customers totaling $802,483.47, plus interest. FINRA credited the firm for its extraordinary cooperation in the matter and did not impose a fine.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":737},{"d":"2022-12-20","di":"2022-12-20","dr":"2022-12-20","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Remediation, process changes","st":"Final","fine":1700000000.0,"dk":"2022-CFPB-0011","al":"The CFPB alleged that certain of the bank's auto loan servicing, mortgage loan servicing, and Consumer deposit account practices were unfair, and that one Consumer deposit account practice was deceptive, as further described in the consent order.","res":"Stipulation and Consent","sm":"The order is final and the penalty has been paid.","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":738},{"d":"2022-12-15","di":"2022-12-15","dr":"2022-12-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":1500000.0,"dk":"2018057494001","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that Citigroup Global Markets Inc. (\"CGMI\") violated rule 200(f) of Regulation SHO and FINRA rule 2010 by improperly including securities positions of non-broker-dealer affiliates in two of its aggregation units when calculating the net positions of the aggregation units when calculating the net positions of the aggregation units and failed to establish, maintain, and enforce, a supervisory system reasonably designed to achieve compliance with rule 200(f), in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, cgmi agreed to be censured, to pay a monetary penalty of $1,500,000 and to comply with certain undertakings related to remediation of the issues in the AWC and implementation of a supervisory system related to the issues in the AWC.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":739},{"d":"2022-12-15","di":"2022-11-21","dr":"2022-12-15","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"NYMEX 19-1204-BC","al":"The CME alleged that registrant violated NYMEX rules 432.q and 432.w (act detrimental to exchange/supervision) with respect to sending two separate futures orders to a third party FCM's trading execution algorithm (which then placed multiple orders for the registrant on the futures exchange), which, in one case, resulted in a trading halt.","res":"Settled","sd":"A fine of $90,000 was paid by registrant on December 22, 2022.","sm":"Without admitting or denying the violations or factual findings, on December 15, 2022 registrant agreed to pay a fine of $90,000.","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":740},{"d":"2022-12-13","di":"2022-12-13","dr":"2022-12-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, undertaking","st":"Final","fine":1100000.0,"dk":"2020066649301","al":"FINRA alleged that Edward jones violated FINRA rules 8210(a)(1) and 2010 by failing to timely, completely, and accurately produce certain call detail records in response to certain FINRA document requests between May 2017 and March 2021. Call detail records are not required broker-dealer books and records. FINRA alleged that Edward jones represented to FINRA that call detail records older than 18 months were not available, but failed to search one storage location used by certain employees with an analytics tool and failed to promptly notify FINRA upon discovering the issue. FINRA further alleged that Edward jones failed to preserve and produce to FINRA certain call detail records that were deleted pursuant to the company's document purge protocol.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 13, 2022, Edward jones entered into an AWC with FINRA without admitting or denying the findings. Edward jones agreed to a censure, to certify that it has established and implemented policies, procedures, processes and internal controls reasonably designed to address and remediate the issues identified in the AWC, and to pay a monetary fine of $1.1 million.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":741},{"d":"2022-12-13","di":"2022-11-24","dr":"2022-12-13","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":44500.0,"al":"On November 24, 2022, the Securities and Futures Commission of Korea imposed a KRW 60 million (~$44.5k) administrative fine on Calvert Research and management for violation of short sale restrictions as stipulated in article 180(1) of the financial investment services and capital markets act, pursuant to article 449 of the act, article 390 of the enforcement decree of the act, article 26 of the regulation on investigation of capital markets.","res":"Decision","sd":"Morgan stanley made payment of KRW 48 million (~$36,700) usd by wire transfer on 12/13/2022. While the FSS imposed KRW 60 million (~$44,500 usd), a 20% discount was granted for voluntary payment by December 13, 2022. As Calvert paid the cash fine voluntarily by December 13, 2022, a 20% discount was given, and KRW 48 million was paid accordingly.","sm":"On November 24, 2022, Calvert management & research (CRM) was informed that the Securities and Futures Commission of Korea issued a decision that commended a proceeding asserting that on January 6, 2021, CRM placed a naked short sell order for the sale of 26 common shares of celltrion and 19 common shares of celltrionhealthcare which CRM did not hold at that time. CRM did not challenge the summary decision and fine, which became final on December 13, 2022 when CRM paid the summary fine. No information Filed","ab":"Calvert Research and","firms":[104859],"id":742},{"d":"2022-12-12","di":"2021-09-07","dr":"2022-12-12","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":550000.0,"dk":"CFTC DOCKET NO. 23-04","al":"During December 2018 and May 2019, a trader who was at the time employed by Walleye Capital entered orders in certain soybean complex futures contracts with the intent to cancel those orders before their execution-specifically, soybean futures, soybean meal futures, and soybean oil futures contracts traded on the chicago board of trade. The trader's conduct violated section 4c(a)(5)(c) of the Commodity Exchange Act.","res":"Settled","sd":"$550,000 paid on 01/11/2023","sm":"Walleye was found to be derivatively (STRICTLY) liable for the trader's misconduct. In accepting Walleye's settlement offer, the CFTC recognized the cooperation of Walleye Capital with the division of enforcement's investigation of the matter. The CFTC also acknowledged Walleye Capital's proposed remediation steps in connection with the matter. No information Filed","ab":"Walleye Capital LLC","self":true,"firms":[161413,330606],"id":743},{"d":"2022-12-08","di":"2022-12-08","dr":"2022-12-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":200000.0,"dk":"2021-02-23-00034","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $200,000.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":744},{"d":"2022-12-07","di":"2022-12-07","dr":"2022-12-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":150000.0,"dk":"2020067764002","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to investigate red flags related to a registered representative's undisclosed outside business activities (OBAS). The findings stated that the firm failed to reasonably supervise transfers of funds by the representative's firm customers to third parties. In total, the representative caused five firm customers to transfer over $650,000 to a purported investment advisory firm or to accounts held at a third-party custodian for which the purported investment advisory firm was the advisor, after which the funds were converted by a third party.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":745},{"d":"2022-12-02","di":"2022-11-11","dr":"2022-12-02","k":"Regulatory Action","rg":"Other","reg":"Australian Securities and Investments Commission (ASIC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27116.0,"dk":"S02553190, S02553191, S02553192","al":"ASIC alleged that via issued a product disclosure statement (PDS) for three funds that stated that the index tracked by the funds excluded certain securities which were not in fact excluded by the index methodology. ASIC has acknowledged that the misstatements were an inadvertent error and not intentional.","res":"Other","sd":"Via received three infringement notices from ASIC for an inadvertent misdescription in the PDS documents.","sm":"Via self-identified an error in the PDS to ASIC for the Vanguard international shares select exclusions index funds and issued a supplementary PDS for each of the affected funds, correcting the error, and communicated the update to investors. The notices resulted in a total fine of ~$27,116 usd ($39,960 aud). The notices were paid in full on or before 12/2/2022.","ab":"Vanguard Investments","firms":[105958],"id":746},{"d":"2022-11-25","di":"2022-11-22","dr":"2022-11-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":4000000.0,"dk":"3-21245","al":"On November 22, 2022, Goldman Sachs Asset management, L.P. (\"GSAMLP\") entered into a settlement with The Securities and Exchange Commission (\"SEC\") regarding GSAMLP's policies and procedures with respect to environmental, social and governance investments. The SEC found that GSAMLP did not adopt written policies and procedures governing the evaluation of ESG factors until sometime after two ESG mutual funds were introduced and a socially-responsible separate account strategy was rebranded as ESG, and that, once such policies and procedures were adopted, they were not consistently followed prior to February 2020.","res":"Order","sm":"Gsamlp was censured and ordered to cease and desist from violating section 206(4) of the Advisers Act and rule 206(4)-7 promulgated thereunder. Gsamlp agreed to pay a penalty of $4 million.","ab":"Goldman Sachs Asset","firms":[361],"id":747},{"d":"2022-11-21","di":"2022-11-21","dr":"2022-11-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cenusre, restitution","st":"Final","fine":200000.0,"dk":"2016051634802","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that it failed to reasonably supervise violations of the firm's plan of solicitation policy by certain registered representatives, in violation of NASD rule 3010 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On November 21, 2022, the firm became subject to a letter of acceptance, waiver and consent (AWC) issued by FINRA regarding allegations that it failed to reasonably supervise violations of the firm's plan of solicitation policy by certain registered representatives, in violation of NASD rule 3010 and FINRA rules 3110 and 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to: (a) the imposition of a censure (b) a fine in the amount of $200,000, and (c) restitution to affected customers totaling $497,897, plus interest. The firm will make all required payments in accordance with the terms of the AWC.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":748},{"d":"2022-11-17","di":"2022-11-17","dr":"2022-11-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12135.0,"dk":"URE-7-03","al":"CBOE BZX Exchange, Inc. (\"BZX\") alleged that Citigroup Global Markets Inc. (\"CGMI\") marked options orders on behalf of its client and non-broker-dealer affiliate in a non-customer capacity of the firm where such orders should have been marked in a customer capacity and did not reflect the correct capacity code for such trades in the firm's books and records, in violation of BZX rules 18.1, 18.2, 20.7 and 24.1, as well as section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder. BZX also alleged that CGMI failed to establish, maintain and enforce its written supervisory procedures to reasonably prevent and detect violations of BZX rules with regard to accurately marking and executing its orders with the correct capacity codes, in violation of BZX rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of BZX rules or the Exchange Act have been committed, cgmi agreed to be censured and to pay a monetary penalty of $75,000, $12,135 of which is payable to BZX.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":749},{"d":"2022-11-17","di":"2022-11-17","dr":"2022-11-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE C2 Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10315.0,"dk":"URE-7-02","al":"CBOE C2 Exchange, Inc. (\"C2\") alleged that Citigroup Global Markets Inc. (\"CGMI\") marked options orders on behalf of its client and non-broker-dealer affiliate in a non-customer capacity of the firm where such orders should have been marked in a customer capacity and did not reflect the correct capacity code for such trades in the firm's books and records, in violation of C2 rules 4.2, 4.22, 6.9 and 7.1, as well as section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder. C2 also alleged that CGMI failed to establish, maintain and enforce its written supervisory procedures to reasonably prevent and detect violations of C2 rules with regard to accurately marking and executing its orders with the correct capacity codes, in violation of C2 rule 4.24.","res":"Consent","sm":"Without admitting or denying that violations of C2 rules or the Exchange Act have been committed, cgmi agreed to be censured and to pay a monetary penalty of $75,000, $10,315 of which is payable to C2.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":750},{"d":"2022-11-17","di":"2022-11-17","dr":"2022-11-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":42200.0,"dk":"URE-7-01","al":"CBOE Exchange, Inc. (\"CBOE\") alleged that Citigroup Global Markets Inc. (\"CGMI\") marked options orders on behalf of its client and non-broker-dealer affiliate in a non-customer capacity of the firm where such orders should have been marked in a customer capacity and did not reflect the correct capacity code for such trades in the firm's books and records, in violation of CBOE rules 6.1, 7.1, 8.2 and 8.14, as well as section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder. CBOE also alleged that CGMI failed to establish, maintain and enforce its written supervisory procedures to reasonably prevent and detect violations of CBOE rules with regard to accurately marking and executing its orders with the correct capacity codes, in violation of CBOE rule 8.16.","res":"Consent","sm":"Without admitting or denying that violations of CBOE rules or the Exchange Act have been committed, cgmi agreed to be censured and to pay a monetary penalty of $75,000, $42,200 of which is payable to CBOE.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":751},{"d":"2022-11-17","di":"2022-11-17","dr":"2022-11-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10350.0,"dk":"URE-7-04","al":"CBOE Edgx Exchange, Inc. (\"EDGX\") alleged that Citigroup Global Markets Inc. (\"CGMI\") marked options orders on behalf of its client and non-broker-dealer affiliate in a non-customer capacity of the firm where such orders should have been marked in a customer capacity and did not reflect the correct capacity code for such trades in the firm's books and records, in violation of EDGX rules 18.1, 18.2, 20.7 and 24.1, as well as section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder. EDGX also alleged that CGMI failed to establish, maintain and enforce its written supervisory procedures to reasonably prevent and detect violations of EDGX rules with regard to accurately marking and executing its orders with the correct capacity codes, in violation of EDGX rule 5.1.","res":"Consent","sm":"Without admitting or denying that violations of edgx rules or the Exchange Act have been committed, cgmi agreed to be censured and to pay a monetary penalty of $75,000, $10,350 of which is payable to edgx.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":752},{"d":"2022-11-17","di":"2022-11-17","dr":"2022-11-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"2019063024201","al":"The Financial Industry Regulatory Authority (\"FINRA\") alleged that Citigroup Global Markets Inc.'s (\"CGMI\") rule 606 reports inaccurately reported and omitted required information in violation of regulation NMS rule 606 and FINRA rule 2010 and failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to comply with regulation NMS rule 606 in violation of NASD rule 3010 and FINRA rules 3110 and 2010","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, cgmi agreed to be censured and to pay a monetary penalty of $100,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":753},{"d":"2022-11-17","di":"2022-11-17","k":"Regulatory Action","dk":"2022-04014","ab":"Nicholas, Stefan","firms":[7691],"id":754},{"d":"2022-11-14","di":"2022-11-14","dr":"2022-11-14","k":"Regulatory Action","rg":"State regulator","reg":"Washington State Department of Financial Institutions, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"ORDER NUMBER S-21-3243-22-CO01","al":"The Washington State Department of Financial Institutions, Securities Division (the \"division\") alleged that between 2017 and 2021, Edward jones violated RCW 21.20.110(1)(j) by failing to supervise a former financial advisor, who the division alleged received payments of gifts and loans totaling approximately $550,000.00 from an elderly client without disclosing the payments to Edward jones. The division further alleged that Edward jones failed to detect the financial advisor's undisclosed outside business.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":755},{"d":"2022-11-11","dr":"2022-11-11","k":"Regulatory Action","rg":"Other","reg":"South Korea Financial Supervisory/Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":34200.0,"al":"In April 2022 Principal Global Investors, LLC (PGI) had an unintentional short sale of a security due to a corporate action in potential breach of local regulations. In September 2022, PGI received an email regarding \"notice of action to be taken\" regarding the breach of local restriction provisions in the financial investment services and capital markets act of korea. The final disposition involved a final order issued on 11/11/22 ordering principal am to pay a fine in the amount of 45,000,000 south korean wan, or roughly 34,200 US dollars to the south korean securities and futures commission.","res":"Order","sd":"Order resulted in a fine of 45,000,000 south korean wan, 9,000,000 was waived for early payment and the amount was paid on 11/14/22","sm":"In April 2022, Principal Global Investors, LLC (PGI) had an unintentional short sale of a security due to a corporate action in potential breach of local regulations. In September 2022, PGI received an email regarding \"notice of action to be taken\" regarding the breach of local restriciton provisions in the financial investment services and capital markets act of korea. The final dispositon involved a final order issued on 11/11/2022 ordering principal am to pay a find in the amount of 45,000,000 south korean wan, or roughly 34,200 US dollars to the south korean securities and futures commission. No information Filed","ab":"Principal Asset; Principal Global Investors, LLC","self":true,"firms":[109002,109008],"id":756},{"d":"2022-11-08","di":"2022-11-08","dr":"2022-11-08","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"R-2022-0075","al":"Commonwealth failed to register its investment adviser representative who has a place of business in Massachusetts and ensure that its investment adviser representative was properly registered in Massachusetts prior to providing investment advisory services.","res":"Consent","sd":"Commonwealth shall permanently cease and desist from violations of mass. Gen. Laws c. 110a, §§ 201(c) and 201(d). Commonwealth shall also register and maintain registration of its investment adviser representatives who provide investment advisory services and have a place of business in Massachusetts prior to them providing investment advisory services.","sm":"No Information Filed","ab":"Commonwealth Equity Services, LLC","self":true,"firms":[8032],"id":757},{"d":"2022-11-08","di":"2021-05-10","dr":"2022-11-08","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Settlement","st":"Final","fine":10000.0,"dk":"442.2-403/FRD","al":"On May 10, 2021, the Swiss Federal Department of Finance (\"FDF\") opened an investigation against george Loening in his capacity as deemed controller of certain U.S. investment funds advised by Select Equity Group, L.P. for a suspected violation of the Swiss rules concerning the disclosure of significant shareholdings in listed companies. The proceedings were initiated pursuant to articles 120 and 151 of the financial market infrastructure act (the \"fmia\"). Article 120 fmia provides that whoever holds a disclosable interest in a Swiss-listed issuer must notify the relevant issuer and the Swiss stock exchange on which the issuer's equity securities are listed within a specified period of time (generally four trading days) if the positions held in the relevant Swiss-listed issuer reach, exceed ,or fall below certain thresholds. Pursuant to article 151 fmia, non-compliance with these disclosure obligations is may result in the imposition of a fine of up to CHF 10 million in the case of an intentional breach, and of up to CHF 100,000 in the case of negligence. On May 19, 2021, the FDF notified MR. Loening that it had determined that he had negligently breached the disclosure obligations referred to above between August 16, 2016 and January 27, 2017, and that the FDF is considering imposing a fine. On November 8, 2022, MR. Loening admitted having erroneously filed a disclosure notification regarding crossing of the 5% voting rights of an issuer and upon determining that the harm caused has been righted and receiving the payment, the FDF has agreed to discontinue the proceedings.","res":"Settled","sm":"On November 8, 2022, MR. Loening admitted having erroneously filed a disclosure notification regarding crossing of the 5% voting rights of an issuer and upon determining that the harm caused has been righted and receiving the payment, the FDF has agreed to discontinue the proceedings. No information Filed","ab":"Loening, George, Stabler","firms":[168496],"id":758},{"d":"2022-11-04","di":"2022-11-04","dr":"2022-11-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"2020066956001","al":"FINRA alleges that Vanguard Marketing corporation (\"VMC\") violated FINRA rules 2360(b)(23)(a) and 2010 by accepting a client's options exercise instructions on May 22, 2020, after the 5:30 PM cutoff time, and FINRA rules 3110 and 2010 by failing to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with the requirements for handling option exercise instructions after the exercise cut-off time.","res":"Acceptance, Waiver & Consent(AWC)","sd":"FINRA assessed a fine of $50,000.00 against VMC (the applicant). VMC paid the fine by wire on November 16, 2022.","sm":"Without admitting or denying FINRA's allegations or findings, VMC agreed to the imposition of a censure and a fine in the amount of $50,000.00.","ab":"Vanguard Marketing","firms":[105958],"id":759},{"d":"2022-11-03","di":"2022-11-03","dr":"2022-11-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":850000.0,"dk":"2019062118301","al":"Without admitting or denying the findings, Wedbush Securities Inc. (\"WS\") consented to the sanctions and to the entry of findings that WS negligently misrepresented the default status of bonds on customer account statements. The findings stated that WS generated and distributed more than 19,600 monthly account statements to customers that inaccurately represented that municipal or corporate bonds held by customers were making interest or principal payments, when, in fact, the bonds were in default. In each instance, WS received notice that the bonds in question were in default, but WS did not provide such information to the vendor WS used to maintain information about securities held by customers. By making negligent misrepresentations and making and preserving inaccurate account statements, WS violated municipal securities rulemaking board (MSRB) rules G-17 and G-8. The findings stated that WS failed to establish and maintain a supervisory system reasonably designed to review the accuracy of account statements it sent to customers. Although WS received notice when bonds held by customers had defaulted, WS did not have any system to verify that such information was reflected in the system the firm used to maintain information about securities held by customers. WS also did not have a system to review account statements to determine whether WS accurately reported the default status of bonds. WS failed to develop such systems even though WS was aware of red flags that WS may have been reporting such information incorrectly. WS did not take steps to verify that account statements sent to customers accurately reported the default status of bods and continued to misreport such information on customer account statements until it began to revise procedures conferring the accurate reporting of the default status of bonds on account statements. As a result, WS violated MSRB rule G-27. The findings also included that WS failed to deliver required annual privacy notices, margin disclosures, and order execution disclosures. WS used a third-party vendor to provide account statements to customers via mail or electronic delivery through WS's online platform. WS was responsible for providing the vendor with required notices and disclosures to include with account statements delivered to customers. However, WS failed to instruct the vendor to append the required notices and disclosures to the account statements sent electronically to WS's customers, and as a result, WS failed to deliver more than 400,000 required notices and disclosures to approximately 14,900 customers. FINRA found that WS did not have a supervisory system reasonably designed to achieve compliance with its obligation to deliver annual privacy notices, margin disclosures, and order execution disclosures. WS's written supervisory procedures (WSPS) required WS to deliver the annual privacy notices, margin disclosures, and order execution disclosures described above to customers on an annual basis. However, WS did not have any system to verify that such notices were sent to customers who elected to receive materials from WS via its online platform. Instead, WS relied on the vendor to deliver the required annual notices and disclosures to customers, but WS did not take any steps to verify that the vendor had appended the required notices and disclosure to the account statements sent electronically to customers. WS later identified that customers had not been receiving the required notices and disclosures, implemented changes to the delivery","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $850,000, and required to certify that the firm's WSPS and supervisory system are reasonably designed to review the accuracy of account statements sent to customers and to achieve compliance with its obligation to deliver to customers annual privacy notices, margin disclosures, and order execution disclosures.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":760},{"d":"2022-11-02","di":"2022-11-02","dr":"2022-11-02","k":"Regulatory Action","rg":"State regulator","reg":"State of Delaware","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":72255.0,"dk":"20-0026","al":"In November 2022, without admitting or denying the allegations, Janney Montgomery Scott LLC voluntarily entered into a consent order with the State of Delaware related to failure to supervise the suitability of certain activities by a financial advisor.","res":"Consent","sd":"See sanctions above","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":761},{"d":"2022-10-31","di":"2022-10-31","dr":"2022-10-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":360000.0,"dk":"2020067000501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to have in place a supervisory system, including WSPS, reasonably designed to timely review paper statements from employees' outside brokerage accounts. The findings stated that the firm had no prescribed timeframe to track, reconcile, and review statements. Due to the manual nature of the paper statement review process, personnel turnover, and outdated technology systems, the firm had a backlog of approximately 8,950 unreviewed account statements. In addition, the firm manually tracked receipt of paper statements, had no system in place to notify the firm or employees that statements were missing, and had no procedure for following up on missing statements. In some instances, the firm did not receive paper statements for review. In addition, the firm's process to review paper statements was not reasonably designed. As a result, the firm failed to timely or reasonably monitor thousands of employee outside brokerage account statements for compliance with the firm's trading restrictions, including pre-clearance, holding period, and watch and restricted list policies.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":762},{"d":"2022-10-20","di":"2022-10-20","dr":"2022-10-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":300000.0,"dk":"2018058633501","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $300,000.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":763},{"d":"2022-10-19","di":"2022-10-19","dr":"2022-10-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":100000.0,"dk":"2016051156903","al":"From December 2013 through December 2016, Janney failed to reasonably supervise two former registered representatives who recommended that their customers invest an unsuitably high percentage of their assets in energy-sector securities in violation of NASD rule 3010 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $100,000, and ordered to pay $145,019, plus interest, in restitution to customers.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":764},{"d":"2022-10-14","di":"2022-10-06","dr":"2022-10-14","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"RSRH-22-6737","al":"On October 6, 2022, the market regulation department of the CME Group inc. (\"CME\") notified Goldman Sachs & Co. LLC (\"GSCO\") that CME's 512 committee found that GSCO violated CME rule 561 for late adjustments to large trader reporting of certain listed futures and options positions on five trade dates in September 2022.","res":"Decision","sm":"CME imposed a fine in the amount of $10,000, which gsco paid by submission of a wire on October 14, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":765},{"d":"2022-10-12","di":"2022-10-12","dr":"2022-10-12","k":"Regulatory Action","rg":"Other","reg":"ICE Futures US","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"2021-012","al":"Alleged violation of exchange rule 6.15(a) and 4.01(a), in that Citigroup Global Markets Inc., may have been in violation by failing to submit to the exchange accurate daily trader reports on reportable customer positions and failing to supervise its employees on accurate position reporting in certain instances between January 2020 and November 2021.","res":"Settled","sm":"Without admitting or denying the alleged rule violations, cgmi agreed to pay a monetary penalty of $90,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":766},{"d":"2022-10-05","di":"2022-10-05","dr":"2022-10-05","k":"Regulatory Action","rg":"Other","reg":"Commissione Nazionale Per Le Societa E la Borsa (Consob)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14582.0,"dk":"DECISION NO. 22460","al":"Commissione Nazionale Per Le Societa E la Borsa (Consob) issued a decision imposing an administrative fine on Bank of America corporation (BAC) for in connection with the late communication to the public of inside information concerning the decision to exercise the call of a bond issued by BAC because the press release was issued too close in time to the date of the early redemption in violation of article 17, paragraph 1 of the council of 16 April 2014 on market abuse.","res":"Other","sm":"Consob imposed a penalty in the amount of EUR15,000 (approximately USD14,582) on bac. The payment was made in accordance with the terms of the decision.","ab":"Bank of America","firms":[7691],"id":767},{"d":"2022-10-04","di":"2022-10-04","dr":"2022-10-04","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority (Financial Services Commission).","san":"Other","os":"Money penalty","st":"Final","fine":3534818.0,"al":"Financial services commission alleged that Samsung Securities Co., LTD. failed to comply with (1) the restriction on providing loans to the officers or employees of its affiliates, (2) the obligation to submit its business report in accordance with the laws, (3) the restriction on unsound activities in connection with underwriting of securities, (4) the procedures in relation to investment advertisements, (5) the limitation on the amount of discretionary investment on the securities issued by its affiliates","res":"Decision","sm":"On October 4, 2022, financial services commission issued a notice of its decision, finding Samsung Securities Co., LTD. is liable for the allegations listed in our answer to question 7. As a result, a fine of KRW 4,507,600,000 has been imposed on Samsung Securities Co., LTD.","ab":"Samsung Securities Co.,","firms":[158319],"id":768},{"d":"2022-09-28","di":"2022-09-28","dr":"2022-09-28","k":"Regulatory Action","rg":"State regulator","reg":"South Carolina Securities Division","san":"Censure","os":"Civil penalty","st":"Final","fine":50000.0,"dk":"20186982","al":"Failure to supervise 2 South Carolina agents.","res":"Consent","sd":"Fine paid in full on 10/14/2022.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":769},{"d":"2022-09-28","di":"2022-09-28","dr":"2022-09-28","k":"Regulatory Action","rg":"State regulator","reg":"State of Texas","san":"Other","os":"Consent order, fine, and restitution offer","st":"Final","fine":125000.0,"dk":"IC22-CAF-02","al":"During the period 2016 through 2019, respondent failed to enforce its written supervisory procedures relating to its prohibition on retail communications regarding structured notes because respondent's e-mail surveillance tool was not designed to flag e-mails sent to more than twenty-five individuals in a thirty-day period when those individuals were included only by blind carbon copy (BCC). Accordingly, a former agent of respondent solicited sales of over $65,000,000 in structured notes using blast e-mails to generate interest in the product. Respondent also failed to enforce its written supervisory procedures that sales of products be suitable, since certain investors had limited investment experience and invested over 40% of their investable assets in the notes.","res":"Settled","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":770},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","st":"Final","fine":75000000.0,"dk":"22-40","al":"On September 27, 2022, the Commodity Futures Trading Commission (\"CFTC\") alleged they had reason to believe that from at least January 2016 to the present (\"relevant period\"), Goldman Sachs & Co. LLC (\"GSCO\" ) violated sections 4g, 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the Commodity Exchange Act (\"act\"), 7 U.S.C. §§ 6g, 6s(f)(1)(c), 6s(g)(1), (3), 6s(h)(1)(b), and CFTC regulations (\"regulations\") 1.31, 1.35, 23.201(a), 23.202(a)(1) and (b)(1), 23.602(a), and 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.201(a), 23.202(a)(1), (b)(1), 23.602(a), 166.3 (2021). As a result, the CFTC deemed it appropriate to institute public administrative proceedings to determine whether GSCO engaged in the listed violations and determine whether any order should be issued imposing remedial sanctions. GSCO admitted and acknowledged their conduct violated the act and submitted an OFFER of settlement (\"OFFER\") which the CFTC accepted. The CFTC became aware of GSCO employee use of unapproved communication methods for business conversations during the course of an investigation into certain of GSCO's trading. As a result, the CFTC subpoenaed the records of four GSCO traders. The communications produced by the traders in response to those subpoenas indicated that the traders frequently used non- GSCO-approved methods of communication, including text and whatsapp (\"off-channel communications\"), to communicate with other GSCO traders and with brokers. The communications also revealed that employees at all levels of authority were involved in the use of these off-channel communications, which were sent and received by GSCO employees relating to GSCO's business as a CFTC registrant, which were required to be maintained under CFTC-mandated recordkeeping requirements. These records were generally not maintained and preserved by GSCO, and GSCO would not have been able to furnish such communications promptly to a CFTC representative if and when requested, which violates the act. In addition, the widespread use of unauthorized off- channel communications by GSCO's employees to conduct firm business violated GSCO's own policies and procedures, which prohibited such communications. Therefore, the CFTC found GSCO also failed to implement a diligent supervisory system to ensure compliance with the CFTC's recordkeeping requirements and the firm's own policies and procedures, and because the firm failed to maintain CFTC-required records, GSCO failed to diligently supervise matters related to its business as a CFTC registrant, in violation of the act.","res":"Order","sm":"The CFTC ordered that gsco cease and desist; is censured; complies with the undertakings enumerated in the offer; and pay a civil money penalty in the amount of $75,000,000. The fine was paid on October 14, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":771},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":125000000.0,"dk":"3-21167","al":"On September 27, 2022, the SEC instituted public administrative and cease-and-desist proceedings against Goldman Sachs & Co. (\"GSCO\") pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 (\"Exchange Act\"), based on their determination that federal securities laws were violated. GSCO admitted and accepted the SEC's jurisdiction and the subject matter of these proceedings and submitted an OFFER of settlement (\"OFFER\") which the SEC accepted. The SEC found that from January 2018 to September 2021, GSCO employees used their personal devices to communicate both internally and externally by personal text messages or other text messaging platforms such as whatsapp (\"off-channel communications\"), in relation to the business of the broker-dealer operated by GSCO. GSCO's failure to maintain or preserve the substantial majority of these written communications was firm-wide, and involved employees at all levels of authority. As a result, GSCO violated section 17(a) of the Exchange Act and rule 17A-4(b)(4). The SEC found GSCO's failure to implement its policies and procedures that prohibit such off-channel communications led to its failure to supervise its employees within the meaning of section 15(b)(4)(e) of the Exchange Act. The SEC uncovered GSCO's misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at broker-dealers. As a result, GSCO has initiated a review of its recordkeeping failures and begun a program of remediation.","res":"Order","sm":"The SEC ordered that gsco cease and desist; is censured; complies with the undertakings enumerated in the offer; and pay a civil money penalty in the amount of $125,000,000. The fine was paid on October 14, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":772},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil monetary penalty; censure; undertaking","st":"Final","fine":125000000.0,"dk":"FILE NO. 3-21165","al":"The Securities and Exchange Commission alleged, in connection with the broker-dealer off-channel communications initiative, that Citigroup Global Markets Inc. (CGMI) failed to (1) maintain and preserve personal text messages and messages sent on other text messaging platforms related to the business of the broker-dealer operated by CGMI, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise its employees with a view to preventing or detecting certain of its employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"Cgmi admitted to the facts in the settlement order, acknowledged its conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $125,000,000, and (d) comply with certain undertakings related to retention of electronic communications.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":773},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil monetary penalty; undertaking","st":"Final","fine":75000000.0,"dk":"22-46","al":"The commodities futures trading commission (\"CFTC\") entered into a settlement order (\"order\") with Citigroup Global Markets Inc. (\"CGMI\"), Citibank, N.A. and Citigroup Energy Inc. (collectively the \"respondents\") settling an administrative action concerning (a) respondents' failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the Commodity Exchange Act (\"act\") and regulations 23.201(a) and 23.202(a)(1) and (b)(1); (b) CGMI's failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) respondents' failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) CGMI's failure to diligently supervise in violation of regulation 166.3.","res":"Order","sm":"The respondents admitted to the facts in the settlement order, acknowledged their conduct violated the act and regulations and agreed to: (a) the entry of the CFTC's findings; (b) cease and desist from violating sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the act, and regulations 1.31, 23.201(a), 23.202(a)(1) and (b)(1) and 23.602(a) and cgmi to cease and desist from violating section 4g of the act and regulations 1.35 and 166.3, (c) pay a civil monetary penalty in the amount of $75,000,000, and (d) comply with certain conditions and undertakings.","ab":"Citigroup Energy Inc.","firms":[7059],"id":774},{"d":"2022-09-27","di":"2022-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","st":"Final","fine":100000000.0,"dk":"22-38","al":"The commodities futures trading commission (\"CFTC\") entered into a settlement order (\"order\") with BOFAS securities, inc. (\"BOFAS\"), Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPFS\"), and bank of america, N.A. (\"bana\", and collectively with BOFAS and MLPFS, the \"respondents\") settling an administrative action concerning (a) bana's failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the Commodity Exchange Act (\"act\") and CFTC regulations (\"regulations\") 23.201(a) and 23.202(a)(1) and (b)(1); (b) BOFAS and MLPFS' failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) bana's failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) BOFAS and MLPFS' failure to diligently supervise in violation of regulation 166.3.","res":"Order","sm":"The respondents admitted to the facts in the settlement order, except as to sections II.A.2 and II.C.2 of the order, which facts they neither admitted nor denied, acknowledged their conduct violated the act and regulations and agreed to the following sanctions: (a) bana to cease and desist from violating sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the act, and regulations 1.31, 23.201, 23.202(a)(1) and (b)(1) and 23.602(a) and bofas and MLPFS to cease and desist from violating section 4g of the act and regulations 1.31, 1.35 and 166.3, (b) to pay a civil monetary penalty in the amount of $100,000,000, and (c) to comply with certain conditions and undertakings.","ab":"Bank of America, National","firms":[7691],"id":775},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":125000000.0,"dk":"FILE NO. 3-21166","al":"The Securities and Exchange Commission alleged, in connection with the broker-dealer off-channel communications initiative, that Bofa Securities, Inc. and Merrill Lynch, Pierce, Fenner & Smith Incorporated (collectively, baml) failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by baml, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"Baml admitted to the facts in the settlement order, acknowledged their conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $125,000,000, and (d) comply with certain undertakings related to retention of electronic communications.","ab":"Bofa Securities, Inc.","firms":[7691],"id":776},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; undertaking","st":"Final","fine":125000000.0,"dk":"FILE NO. 3-21169","al":"The Securities and Exchange Commission alleged, in connection with the broker-dealer off-channel communications initiative, that Morgan Stanley Smith Barney and Morgan Stanley & Co. LLC (collectively, Morgan stanley) failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by respondents, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"On September 27, 2022, the Securities and Exchange Commission alleged that Morgan stanley failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by respondents, in willful violation of section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act. Morgan stanley admitted to the facts in the settlement order, acknowledged their conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $125,000,000, and (d) comply with certain undertakings related to retention of electronic communications.","ab":"Morgan Stanley & Co. LLC","firms":[149777],"id":777},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"The order required Deutsche bank AG (\"DBAG\") and Deutsche Bank Securities, inc. (\"DBSI\") to retain a compliance consultant.","st":"Final","fine":75000000.0,"dk":"CFTC DOCKET NO. 22-48.","al":"The Commodity Futures Trading Commission (\"CFTC\") found that, from at least January 2018 to September 2022, dbag and dbsi employees sent and received off-channel communications that related to the business of swap dealers and futures commission merchants, and that dbag and dbsi did not maintain or preserve these written communications, resulting in violations of the requirements to preserve certain business-related communications in the Commodity Exchange Act (the \"cea\"), and that dbag and dbsi failed to diligently supervise their employees in relation to these requirements.","res":"Order","sm":"On September 27, 2022, dbag and dbsi entered into a settlement with the CFTC, which the CFTC approved in its order of the same date. The order found that from at least January 2018 to September 2022, dbag and dbsi employees sent and received off-channel communications that related to the business of swap dealers and futures commission merchants, and that dbag and dbsi did not maintain or preserve these written communications, resulting in violations of the requirements to preserve certain business- related communications in the cea, and that dbag and dbsi failed to diligently supervise their employees in relation to these requirements. Dbag and dbsi agreed to a fine of $75,000,000, which was timely paid on October 7, 2022, and to retain a compliance consultant and adopt the compliance consultant's recommendations related to the preservation of business-related communications.","ab":"Deutsche Bank Securities","firms":[300838],"id":778},{"d":"2022-09-27","di":"2022-09-27","dr":"2022-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"The order required Deutsche Bank Securities, inc. (\"DBSI\"), DWS distributors, inc. (\"DDI\") and DWS investment management americas,","st":"Final","fine":125000000.0,"dk":"FILE NO. 3-21173.","al":"The securities exchange commission (\"SEC\") found that, from at least January 2018 to September 2021, dbsi, ddi and dima employees sent and received off-channel communications that related to the business of broker-dealers and investment advisers, and that dbsi, ddi and dima did not maintain or preserve the substantial majority of these written communications, resulting in violations of the requirements to preserve certain business-related communications in the Securities Exchange Act of 1934 (the \"Exchange Act\") and the Investment Advisers Act of 1940 (the \"Advisers Act\"), and that dbsi, ddi and dima failed to reasonably supervise their employees in relation to these requirements.","res":"Order","sm":"On September 27, 2022, dbsi, ddi and dima entered into a settlement with the SEC, which the SEC approved in its order of the same date. The order found that, from at least January 2018 to September 2021, dbsi, ddi and dima employees sent and received off- channel communications that related to the business of broker-dealers and investment advisers, and that dbsi, ddi and dima did not maintain or preserve the substantial majority of these written communications, resulting in violations of the requirements to preserve certain business-related communications in the Exchange Act and the Advisers Act, and that dbsi, ddi and dima failed to reasonably supervise their employees in relation to these requirements. Dbsi, ddi and dima agreed to a fine of $125,000,000, which was timely paid on October 7, 2022, and to retain a compliance consultant and adopt the compliance consultant's recommendations related to the preservation of business-related communications.","ab":"Deutsche Bank Securities","firms":[300838],"id":779},{"d":"2022-09-23","di":"2022-09-23","k":"Regulatory Action","dk":"L21000192570","ab":"Stukes, Vaughn, Maurice","firms":[7691],"id":780},{"d":"2022-09-22","di":"2022-09-22","dr":"2022-09-22","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Commission","san":"Other","os":"N/a","st":"Final","fine":500000.0,"dk":"3-21133","al":"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.","res":"Order","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":781},{"d":"2022-09-20","di":"2022-09-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":35000000.0,"dk":"FILE NO. 3-21112","al":"Without admitting or denying the findings, Morgan Stanley Smith Barney LLC (the firm) consented to sanctions and to the entry of findings that it failed to adopt written policies and procedures that identified the high level of risk associated with the decommissioning of data-bearing firm devices; failed to reasonably design written policies and procedures for employment and monitoring of vendors and sub-vendors to protect the security and confidentiality of customer records and information; and failed to take reasonable measures to protect customer personal identifying information (PII) or consumer report information in connection with decommissioning data-bearing devices, in willful violation of rules 30(a) and (b) of Regulation S-P.","res":"Order","sm":"On September 20, 2022, the firm consented to sanctions and to the entry of findings that it failed to adopt written policies and procedures that identified the high level of risk associated with the decommissioning of data-bearing firm devices; failed to reasonably design written policies and procedures for employment and monitoring of vendors and sub-vendors to protect the security and confidentiality of customer records and information; and failed to take reasonable measures to protect customer personal identifying information (PII) or consumer report information in connection with decommissioning data-bearing devices, in willful violation of rules 30(a) and (b) of Regulation S-P. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented: (a) cease and desist from committing or causing any violations or any future violations of rules 30(a) and (b) of Regulation S-P, (b) be censured, and (c) pay a civil monetary penalty in the amount of $35,000,000. The fine was paid in accordance with the terms of the order.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":782},{"d":"2022-09-15","di":"2022-09-15","dr":"2022-09-15","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":45000.0,"al":"On 9/15/22, the Securities and Exchange Commission (\"SEC\"), acting pursuant to an offer by the registrant which consented to the entry of an order making certain findings and imposing certain remedies, instituted administrative proceedings finding that the registrant had violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-5 thereunder when the registrant provided investment advisory services for compensation for two years following a contribution by a covered associate to an incumbent candidate for governor, which position appoints people who could influence the hiring of investment advisers by a government entity. The SEC noted that rule 206(4)-5 does not require a showing of quid pro quo or actual intent to influence an elected official.","res":"Order","sd":"The asset management group of Bank of Hawaii (\"AMG\") paid a civil monetary penalty in the amount of $45,000 within 10 days of the entry of the order.","sm":"The action was resolved pursuant to an SEC order dated 9/15/22; in the matter of asset management group of Bank of Hawaii, administrative proceeding file no. 3-21080. Without admitting or denying the findings except as to the commission's jurisdiction over it and the subject matter of these proceedings, AMG consented to the entry of the order that AMG (I) 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)-5 ( ) ( ) thereunder; (II) is censured; (III) pay a civil money penalty of $45,000 to the SEC. No information Filed","ab":"Bank of Hawaii","self":true,"firms":[112324],"id":783},{"d":"2022-09-15","di":"2022-02-15","dr":"2022-09-15","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":95000.0,"dk":"3-21079","al":"The U.S. Securities and Exchange Commission (\"SEC\") alleged that a covered associate of the registrant violated rule 206(4)-5 under the Investment Advisers Act of 1940, the SEC's \"pay-to-play\" rule (the \"rule\"), which prohibits an exempt reporting adviser from providing compensated advisory services within two years after a covered associate makes certain political contributions. The alleged violation of the rule was based on a $1,000 campaign contribution that one of the registrant's covered associates made in 2018 to the campaign of a candidate for governor of California. The governor serves on, and appoints other members to, the board of a government entity that selects investment advisers for a California state university system. That government entity had previously, between 7 and 13 years prior to the 2018 contribution at issue, invested in three closed-end funds advised by the registrant.","res":"Settled","sm":"The registrant and the SEC agreed to settle the matter on terms outlined by the SEC staff, pursuant to which, without admitting or denying liability, the registrant agreed to pay a $95,000 penalty. The order noted that the rule does not require a showing of actual intent to influence a candidate for elected office, and thus there is no such finding, and that the SEC is not required to show that the registrant was aware that it was violating any rule. The registrant paid the $95,000 penalty on September 19, 2022. No information Filed","ab":"Canaan Management, LLC","self":true,"firms":[161180],"id":784},{"d":"2022-09-15","di":"2022-02-15","dr":"2022-09-15","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure","st":"Final","fine":95000.0,"dk":"3-21081","al":"The SEC alleged that a principal of registrant made a campaign contribution to an unsuccessful candidate for governor of Massachusetts, a state whose public pension plan had invested in venture capital funds advised by registrant. After the contribution registrant continued to provide advisory services for compensation to the venture capital funds. The public pension plan had already invested in funds at the time of the contribution, and the principal later sought and obtained a return of the contribution. Pursuant to an offer of settlement, the SEC found, and the registrant neither admitted nor denied, that the registrant violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-5 thereunder.","res":"Settled","sm":"MONETARY FINE WAS PAID ON 9/19/22. No Information Filed","ab":"Highland Capital Partners LLC","self":true,"firms":[161205],"id":785},{"d":"2022-09-12","di":"2022-09-12","dr":"2022-09-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":11200000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-21062","al":"The SEC alleged that with respect to certain private equity funds, Lone star global acquisitions, LTD. (\"LSGA\") and HUDSON advisors L.P. (\"HUDSON\") did not fully disclose the methodology used to calculate and charge ancillary and underwriting fees paid by such funds to HUDSON prior to 2018. The SEC also alleged that LSGA and HUDSON did not adopt and implement written compliance policies or procedures regarding the foregoing.","res":"Settled","sd":"Lsga and hudson are jointly and severally liable for the above referenced civil penalty.","sm":"Without admitting or denying any wrongdoing, lsga and hudson made an offer of settlement which the SEC accepted. The order is final. No information Filed","ab":"Lone Star Americas Acquisitions, Inc.","self":true,"firms":[160000],"id":786},{"d":"2022-09-08","di":"2022-09-08","dr":"2022-09-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and monetary penalty","st":"Final","fine":100000.0,"dk":"3-21042","al":"Firm failed to obtain an independent verification of assets of a private fund client, or, alternatively, distribute annual audited financial statements prepared in accordance with generally accepted accounting principles (\"GAAP\") to the investors in one private fund that it advised for each fiscal year from 2010 through 2018. For fiscal years 2019 and 2020, the annual audited financial statements for the fund were distributed to investors 481 days late and 222 days late, respectively. Respondent also failed to obtain the requisite independent verification of client assets from an independent public accountant for 465 discretionary client accounts that it advised for each year from 2010 through 2020. As a result of the foregoing, the firm violated section 206(4) of the Advisers Act and rule 206(4)-2 thereunder, commonly referred to as the \"custody rule.\" The firm also failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder, a violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","res":"Order","sd":"$100,000 penalty","sm":"SEC accepted the firm's offer and ordered the sanctions listed above. No information Filed","ab":"Charles Pratt & Company, L.L.C.","self":true,"firms":[104864],"id":787},{"d":"2022-09-07","di":"2020-05-13","dr":"2022-09-07","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Injunction, disgorgement and civil penalty","st":"Final","fine":2034446.0,"al":"The complaint alleges that ambassador advisors, LLC and its principals were negligent because they did not adequately disclose a conflict of interest, provide best execution, or have written policies or procedures, in connection with the selection of mutual funds that paid 12B-1 fees. The alleged claims were made under section 206(2), section 206(4) and rule 206(4)-7 of the Investment Advisers Act of 1940.","res":"Judgment Rendered","sd":"On September 7, 2022, the court entered final judgments against ambassador and its principals. The judgments ordered: (1) MR. bostwick to pay $136,620 in disgorgement, $35,273 in prejudgment interest, and a $136,620 civil penalty; (2) MR. Kauffman to pay $349,395 in disgorgement, $95,972 in prejudgment interest, and a $349,395 civil penalty; (3) MR. young to pay $136,627 in disgorgement, $35,275 in prejudgment interest, and a $136,627 civil penalty; and (4) ambassador to pay a $622,642 civil penalty. In addition, the judgments ordered ambassador and its principals to correct and remove misleading statements from the firm's website and form ADV materials, as well as to send a corrective notice about the case to the firm's advisory clients","ab":"Kauffman, Robert, Ernest","firms":[116978],"id":788},{"d":"2022-09-06","di":"2022-09-06","dr":"2022-09-06","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2800000.0,"dk":"22-23","al":"The Commodity Futures Trading Commission issued an order filing and settling charges against Natixis, a global bank and swap dealer, for failure to diligently supervise two traders on the bank's New York-based interest rate derivatives desk (ird desk) and its equity derivatives flow and solution trading desk (fast desk). The traders on the ird desk and fast desk separately engaged in misconduct by mismarking their positions for the purpose of either inflating profits and minimizing losses, or to \"smooth\" out returns, respectively. The order requires Natixis to pay a $2.8 million civil monetary penalty, cease and desist from violating applicable provisions of the Commodity Exchange Act (CEA) and CFTC regulations, and comply with certain conditions and undertakings. Case background: between January 2015 and at least April 2018, a trader on the bank's ird desk submitted false or misleading entries in the bank's internal recordkeeping and accounting system relating to the marking of the end-of-day usd LIBOR forward curve (closing curve), for the purpose of inflating the unrealized profit and loss (p&l) of the desk he managed and disguising significant trading losses. Specifically, the trader engaged in a pattern of marking the closing curve in a manner that varied from observed broker mid prices and in a manner that aligned with the risk positions of the ird desk, while generally staying within the limits of internal controls designed to detect mismarking. Although Natixis maintained certain controls relating to the marking of the closing curve, those controls were insufficient to detect the trader's misconduct for over three years. At its peak in early 2018, the trader's mismarking of the closing curve overstated the p&l of the ird desk by approximately $25 million. In addition, the order further finds that Natixis failed to diligently supervise the activities of its fast desk. Specifically, between February 2017 and November 2019, traders on the fast desk made certain manual adjustments to the bank's internal trade booking systems for the purpose of \"smoothing\" or hiding the fast desk's p&l and later releasing the p&l during difficult market conditions. At its peak, the p&l smoothing understated the unrealized p&l of the fast desk by over $6 million. This misconduct rendered the bank's books and records inaccurate. In accepting the bank's offer of settlement, the CFTC recognized its substantial cooperation during the division of enforcement's investigation of this matter. The CFTC noted that the bank's substantial cooperation and remediation are recognized in the form of a reduced civil monetary penalty.","res":"Settled","sd":"N/a","sm":"See response to question 7. Also see: HTTPS://www.cftc.gov/pressroom/pressreleases/8581-22 No information Filed","ab":"Natixis SA","firms":[105377,106975,108633],"id":789},{"d":"2022-09-06","di":"2022-09-06","dr":"2022-09-06","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease desist, censure","st":"Final","fine":1500000.0,"dk":"3-21031","al":"SEC alleged the applicant failed (1) to disclose certain conflicts of interest regarding its personnel's co-investment with certain of the applicant's funds in the sponsors of spacs in which the applicant advised its clients to invest and (2) failed to timely file a required report on schedule 13d concerning its beneficial ownership of stock in a public company.","res":"Consent","sd":"The applicant consented to the SEC's order finding it violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rules 206(4)-7 and 206(4)-8, as well as section 13(d) of the Securities Exchange Act of 1934 and rule 13D-1. Without admitting or denying the findings the applicant agreed to a cease-and-desist order, a censure and $1.5 million penalty paid by the applicant on [date] to settle the charges.","sm":"The SEC matter was settled on September 6, 2022 pursuant to the order described above. No information Filed","ab":"Perceptive Advisors LLC.","self":true,"firms":[154703],"id":790},{"d":"2022-08-31","di":"2022-08-31","dr":"2022-08-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":150000.0,"dk":"2020065107401","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it used a published commission schedule pursuant to which it charged commissions on low-principal transactions that were not fair and reasonable. The findings stated that for all equity transactions, the firm imposed a minimum commission of $100, in addition to a handling fee. As a result of the minimum commission, the firm charged a total of at least $266,481 in unfair commissions of transactions on behalf of customers. The commissions charged ranged from over five percent to 93 percent of the transactions' principal value. The findings also stated that the firm's supervisory system was unreasonable because in establishing its commission schedule and in setting commissions on transactions, the firm did not appropriately consider the factors set forth in FINRA rule 2121.01 for transactions when the minimum $100 commission was imposed. Specifically, while the firm generally flagged transactions where customers were charged over five percent of principal and reviewed those transactions for excessive commissions, the firm's supervisory system did not flag for review transactions when the firm charged the minimum $100 commission.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $150,000.00 and ordered to pay $266,481, plus interest, in restitution to customers.","sm":"The firm accepted and consented without admitting or denying the findings and the imposition of a $150,000 fine. After FINRA discussed the $100 minimum equity commission with Robert W. Baird & Co., incorporated (\"BAIRD\") during the 2020 routine examination, BAIRD promptly modified its published commission schedule to eliminate the minimum commission amount and updated its written supervisory procedures to align with the new published schedule. BAIRD also took steps to make payments to the affected customers, which on average amount to $36.62 per trade and $57.64 per customer. BAIRD will continue to make efforts to ensure that it charges fair prices and commissions on all securities transactions with its customers.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":791},{"d":"2022-08-29","di":"2022-08-29","dr":"2022-08-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO.","al":"On August 29, 2022, Lend Academy Investments entered into an order (\"2022 order\") with the SEC. without admitting or denying the findings in the 2022 order, the SEC found that, in 2017, 2018, 2019, 2020 and 2021, lai violated federal securities laws in connection with financial statement audits of private funds advised by lai. Lai failed to timely distribute annual audited financial statements prepared in accordance with US gaap to investors in the P2P fund and the series. Additionally, lai did not promptly update and amend the custody section of its part 1a form ADV filings as required by the form ADV general instructions. As a result, the 2022 order states lai willfully violated sections 204(a) and 206(4) of the Advisers Act and rules 204-1(a) and 206(4)-2 thereunder.","res":"Decision & Order of Offer of Settlement","sd":"On August 29, 2022, the adviser paid a civil penalty in the amount of $75,000 to the SEC.","sm":"The adviser agreed to the terms of the settlement and paid a civil money penalty in the amount of $75,000. Further details are provided in the response to question 7, above. No information Filed","ab":"Lend Academy Investments, LLC","self":true,"firms":[169878],"id":792},{"d":"2022-08-22","di":"2022-08-22","dr":"2022-08-22","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt Fur Finanzdienstleistungsaufsicht (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5071950.0,"dk":"WA 15-WP 3121-2020/0001; WA 15-WP 3121-2020/0002; WA 15=WP 3121-2020/0003; WA 15-WP 3120-2020/0012","al":"The Bundesanstalt Fur Finanzdienstleistungsaufsicht (BAFIN) approved the imposition of an administrative fine on Bank of America corporation for failure to take the supervisory and organisational measures that would have been required in order to ensure the correct and complete submission of voting rights notifications within the prescribed period, in breach of section 130(1) of the german act on breaches of administrative regulations in conjunction with sections 33 (1) sentence 1, section 38(1) sentence 1 and 39 (1) of the german securities trading act.","res":"Other","sm":"BAFIN imposed a penalty in the amount of EUR5,100,000 (approximately USD5,071,950) on bac and costs of the proceeding in the amount of EUR7,500 (approximately usd 7,479). The payments were made in accordance with the terms of the order.","ab":"Bank of America","firms":[7691,142558],"id":793},{"d":"2022-08-16","di":"2022-08-16","dr":"2022-08-16","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":223827.0,"dk":"REF. NO DSA-202207-0124_CMD-L-KB-BA; DTS NO. DSA-2022-07-0126","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for non-compliance with the mandatory credit allocation for agrarian reform credit/other agricultural credit (agri- agra) for the quarters ended 3-31-2021 through 12-31-2021.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP12,588,039.11 (approximately USD223,827) on bana. The payment was made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":794},{"d":"2022-08-11","di":"2022-08-11","dr":"2022-08-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":300000.0,"dk":"2020068870301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to accurately calculate its customer reserve requirement and failed to maintain a sufficient customer reserve. The findings stated that the firm's customer reserve calculations excluded customer checks that the firm had received but not yet processed for deposit. As a result, the firm failed to make sufficient deposits in its customer reserve account, causing two hindsight deficiencies that totaled approximately $162 million. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with the Securities Exchange Act of 1934 and FINRA rules concerning the customer reserve requirement. First, the firm's written procedures were not reasonably designed to ensure that undeposited customer checks would be included in the firm's customer reserve calculations. The procedures failed to specify how to handle customer checks that had been received but had not yet been processed for deposit. They also lacked any information about the requirement to include undeposited customer checks in the reserve calculation on the date the checks are received. Second, the firm's supervision of its employees' handling of undeposited customer checks was unreasonably designed to exclude undeposited customer checks from its customer reserve calculation on the date the checks were received. The business unit within the firm that received and processed customer checks prepared a daily report that the firm used to calculate its customer reserve requirement. However, that report did not include customer checks that the firm had received but not yet processed for deposit. The firm did not take any other steps to ensure that those checks were included in the customer reserve calculation on the date they were received. Two months after the firm discovered the hindsight deficiencies, it commenced steps to revise its relevant supervisory procedures. The findings also included that the firm failed to maintain accurate books and records and filed inaccurate financial and operational combined uniform single (FOCUS) reports. By improperly calculating its customer reserve requirements, the firm created and maintained inaccurate books and records concerning its customer reserve. In addition, the firm filed at least 17 monthly FOCUS reports that did not accurately reflect the amount of the firm's customer reserve obligation.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":795},{"d":"2022-08-08","di":"2022-07-20","dr":"2022-08-08","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000.0,"dk":"RSRH-22-6644","al":"On July 20, 2022, the market regulation department of the CME Group Inc. (\"CME\") notified Goldman Sachs & Co. LLC (\"GSCO\") that CME's 512 committee found that GSCO violated CME rule 561 for late adjustments to large trader reporting of certain listed futures and options positions on six trade dates between June and July 2022.","res":"Decision","sm":"CME imposed a fine in the amount of $7,000, which gsco paid by submission of a wire on August 8, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":796},{"d":"2022-08-04","di":"2022-08-04","dr":"2022-08-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":200000.0,"dk":"2019063430402","al":"JPMS consented to sanctions and to entry of findings that, from March 2014 through March 2019,JPMS failed to reasonably supervise a former registered representative who engaged in unsuitable and unauthorized trading in the account of a senior customer in violation of NASD rule 3010 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":797},{"d":"2022-08-03","di":"2022-08-03","dr":"2022-08-03","k":"Regulatory Action","rg":"Other","reg":"Securities & Exchange Commission","san":"Cease and Desist","os":"Remedial sanction (undertaking)","st":"Final","fine":1639501.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-20944","al":"The order included findings that Deccan breached its fiduciary duties. Without admitting or denying the findings therein, Deccan and its principal owner, vinit Bodas, consented to the entry of an order instituting administrative and cease-and-desist proceedings by the Securities and Exchange Commission on August 3, 2022 (the \"order\"), which included findings that Deccan violated sections 204(a), 206(2) and 206(4) and rules 204-2(a)(7), 206(4)-7 and 206(4)-8 of the Investment Advisers Act of 1940 (\"Advisers Act\"). The order included findings relating to Deccan's breach of fiduciary duties in violation of the Advisers Act when handling redemptions for two investors and when unreasonably failing to timely disclose Deccan's intent to declare a side-pocket to one redeeming investor. In addition, the order found that Deccan failed to adopt and implement policies and procedures reasonably designed to prevent violations of Deccan's fiduciary duties with respect to client or investor redemptions as well as its recordkeeping obligations. The order found that MR. Bodas had secondary responsibility for Deccan's violations as a result of acts or omissions that he knew or should have known would contribute to the violations.","res":"Decision & Order of Offer of Settlement","sd":"On August 15, 2022, Deccan and Bodas each completed payment of their civil monetary penalty (respectively $1,139,501 and $500,000)","sm":"The SEC issued an administrative proceedings finding violations described above under item 7 of this DRP. As noted in the order, Deccan engaged an independent compliance consultant to review its compliance, policies and procedures with respect to books and records and investors and client redemptions, in accordance with the order. On August 15, 2022, Deccan and Bodas each completed payment of their civil monetary penalty (respectively $1,139,501 and $500,000). No information Filed","ab":"Bodas, Vinit, Manohar","firms":[158187],"id":798},{"d":"2022-08-01","di":"2022-08-01","k":"Regulatory Action","dk":"CSB-2021-01395558","ab":"Gatto, John, Christopher","firms":[7691],"id":799},{"d":"2022-07-27","di":"2022-07-27","dr":"2022-07-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":1200000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-20936","al":"JPMS consented to the entry of an order, in which SEC found that, from at least January 1, 2017 through December 31, 2019, JPMS willfully violated rule 201 of regulation s-id because its written identity theft prevention programs (\"programs\") for the applicable lines of business failed to include certain reasonable policies and procedures and did not provide for the continued administration of its programs by failing to (I) exercise appropriate and effective oversight of al service provider arrangements; and (II) train staff under one line of business, as necessary, to effectively implement the program in 2017.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":800},{"d":"2022-07-25","di":"2022-03-18","dr":"2022-07-25","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"22-CH-2203","al":"On March 17, 2022, the clearing house risk committee of the CME Group Inc. (\"CME\") reviewed Goldman Sachs & Co. LLC's (\"GSCO\") risk based examination report and the firm's response, and issued a charge letter dated March 18, 2022, which alleges that GSCO violated CBOT rule 930.E.3 in regards to maintaining sufficient written performance bond records.","res":"Settled","sm":"Pursuant to an offer of settlement, in which gsco neither admitted nor denied the rule violation upon which the penalty is based, gsco agreed to pay a fine in the amount of $75,000. The fine was paid in full via gsco's CME clearing firm bank account on July 25, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":801},{"d":"2022-07-21","di":"2021-06-10","dr":"2022-07-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5800000.0,"dk":"HO-13906","al":"Registrant allegedly failed to provide full and fair disclosure regarding the conflicts associated with share classes with no transaction fees, or NTF shares, in wrap accounts, and allegedly did not fulfill its duty of care and other obligations in connection with the conflict.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-7 promulgated thereunder; censured; pay a civil penalty of $5,800,000,","sm":"On July 21, 2022, pursuant to a settlement, in which the registrant neither admitted or denied to the findings, the SEC issued an administrative order (\"the order\") that found, among other things, the registrant failed to provide full and fair disclosure regarding the conflicts associated with share classes with no transaction fees, or NTF shares, in wrap accounts. The order found that the registrant did not fulfill its duty of care and other obligations in connection with the conflict. The order also found that the registrant had not adopted and implemented written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund selection practices in its wrap program and the related disclosures of its associated conflicts of interest. The order includes findings that registrant violated section 206(2) of the Advisers Act, as well as section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. These are not scienter-based violations. As part of the settlement, the registrant agreed to pay a civil penalty of $5.8 million, to be disbursed to affected investors, along with other undertakings. As further highlighted in the order, in 2017 the registrant proactively instituted a policy as a remedial measure that mitigated the conflict. No information Filed","ab":"Private Advisor Group, LLC","self":true,"firms":[155216],"id":802},{"d":"2022-07-21","di":"2022-05-31","dr":"2022-07-21","k":"Regulatory Action","rg":"State regulator","reg":"State Bank of Pakistan (SBP)","san":"Other","os":"Warning letter","st":"Final","dk":"NO. BSD-I/BANK/DB/274234/2022","al":"The state bank of pakistan (\"SBP\") found that Deutsche Bank AG (\"Dbag\"), through its karachi branch, repatriated dividends to a foreign company from 2012 to 2019 without authorization from the SBP in violation of para 16(I), chapter 14 of the pakistan foreign exchange manual under the foreign exchange regulation act.","res":"Order","sm":"In a warning letter dated July 21, 2022, the SBP found that dbag, through its karachi branch, repatriated dividends to a foreign company from 2012 to 2019 without authorization from the SBP in violation of para 16(I), chapter 14 of the pakistan foreign exchange manual under the foreign exchange regulation act, but did not impose any monetary penalty, restrictions or limitations on DB AG's business or undertakings, or any other sanctions.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":803},{"d":"2022-07-14","di":"2022-07-14","dr":"2022-07-14","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000000.0,"dk":"FILE NO. 2022-CFPB-0004","al":"The Consumer Financial Protection Bureau (\"CFPB\") alleged that Bank of America, National association (the firm) (1) engaged in unfair acts or practices by determining no error had occurred and freezing cardholder accounts based solely on the results of its automated fraud filter, in violation of sections 1031 and 1036 of the Consumer financial protection act of 2010 (CFPA), 12 U.S.C. §§ 5531(a) and (c), 5536(a)(1)(b); (2) failed to conduct reasonable investigations of unemployment insurance benefit prepaid debit cardholders' notices of error, in violation of sections 908 and 909 of the electronic fund transfer act (EFTA), 15 U.S.C. §§ 1693f and 1693g, and section 1005.11 of regulation e; (3) engaged in abusive acts or practices by retroactively applying its automated fraud filter to reverse permanent credits for unemployment insurance benefit prepaid debit cardholders whose notices of error it had previously investigated and paid, in violation of sections 1031 and 1036 of the CFPA, 12 U.S.C. §§ 5531(a) and (d)(2)(b), 5536(a)(1)(b); (4) engaged in unfair acts or practices by impeding unemployment insurance benefit prepaid debit cardholders' efforts to file notices of error and seek liability protection from unauthorized efts, in violation of sections 1031 and 1036 of the CFPA, 12 U.S.C. §§ 5531(a) and (c), 5536(a)(1)(b); and (5) failed to timely investigate and resolve unemployment insurance benefit prepaid debit cardholders' notices of error concerning alleged unauthorized efts, in violation of EFTA, 15 U.S.C. § 1693f(a), (c), and section 1005.11(c)(2)­(3) of regulation e.","res":"Consent","sm":"Without admitting or denying the findings of fat of conclusions of law contained within the order, the firm consented to (a) cease and desist from committing or causing any violations and any future violations of the provisions detailed above, (b) certain undertakings, (c) payment of redress to affected customers, and (d) payment of a civil monetary penalty in the amount of $100 million.","ab":"Bank of America, National","firms":[7691],"id":804},{"d":"2022-07-14","di":"2022-07-14","dr":"2022-07-14","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":125000000.0,"dk":"AA_ENF-2022-22","al":"The Office of the Comptroller of the Currency (\"OCC\") alleged that Bank of America, National association (the firm) (1) in connection with the firm's administration of prepaid cards for unemployment benefits, engaged in (I) unsafe or unsound practice(s), including deficiencies in its risk management, operational processes and controls, internal audit, and investigation and resolution of consumer claims of unauthorized transactions; and (II) unfair and deceptive practices in violation(s) of section 5 of the federal trade commission act (\"FTC act\"), 15 U.S.C. § 45(a)(1); and (2) engaged in unsafe or unsound practices related to deficiencies in its enterprise-wide complaints risk management framework.","res":"Consent","sm":"Without admitting or denying the findings contained in the order, the firm consented to a civil monetary penalty of $125,000,000.","ab":"Bank of America, National","firms":[7691],"id":805},{"d":"2022-07-05","di":"2022-07-05","dr":"2022-07-05","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Undertakings, civil penalty","st":"Final","fine":850000.0,"dk":"CFTC DOCKET NO. 22-20","al":"On July 5, 2022, J.P. Morgan Securities LLC, JPMorgan chase bank, N.A., and J.P. Morgan Securities, PLC (collectively \"JPM\") consented to the entry of an order, in which CFTC found that, from at least September 22, 2015 through at least February 14, 2020, JPM violated sections 2(a)(13)(g) and 4r(a)(3) of the commodities Exchange Act and CFTC regulation 45.3 because it failed to report certain short-dated foreign exchange swap transactions.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","firms":[79],"id":806},{"d":"2022-07-01","di":"2021-11-25","dr":"2022-07-01","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Public Prosecutor","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7890000.0,"dk":"7500 JS-OWI 249132/21","al":"On July 1, 2022, the Frankfurt Public Prosecutor (\"FPP\") found that, from 2017 to 2021, Deutsche Bank AG (\"DBAG\") failed to timely file certain suspicious activity reports (\"SARS\") related to activities undertaken by a correspondent bank as required by the german money laundering act.","res":"Order","sm":"On July 1, 2022, the FPP found that, from 2017 to 2021, dbag failed to timely file certain sars related to activities undertaken by a correspondent bank as required by the german money laundering act. Dbag was fined eur 7,010,000 (which is approximately usd $7,890,000), which was timely paid.","ab":"Deutsche Bank AG","firms":[300838],"id":807},{"d":"2022-06-29","di":"2022-04-21","dr":"2022-06-29","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland (Eurex)","san":"Reprimand","st":"Final","dk":"M 2021/159","al":"Eurex deutschland (\"Eurex\") found that, from July 2021 through October 2021, Deutsche Bank AG, frankfurt am main (\"DB AG\") failed to convert 7,257 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On June 29, 2022, DB AG received a decision from Eurex finding that, from July 2021 through October 2021, DB AG failed to convert 7,257 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014, and issuing a reprimand to DB AG, but not imposing a fine or other monetary sanction.","ab":"Deutsche Bank AG","firms":[300838],"id":808},{"d":"2022-06-27","di":"2022-03-17","dr":"2022-06-27","k":"Regulatory Action","rg":"Other","reg":"The Office of Insurance Commissioner of Puerto Rico","san":"Restitution","os":"Massachusetts Mutual Life insurance company was ordered to rescind the policy in dispute and return to the applicant","st":"Final","fine":1500.0,"dk":"CM-2022-17","al":"On March 17, 2022, the commissioner of insurance of Puerto Rico issued an order against Massachusetts Mutual Life insurance company stating that the company had violated articles 11.230 and 27.160 of the puerto insurance code, 26 lpra sections 1123 and 2716, for which an administrative fine of $3,000 was imposed. Massachusetts Mutual Life insurance company was ordered to rescind the policy in dispute and return to the applicant (complainant) the amount of $65,000, corresponding to the unduly collected premium. Massachusetts Mutual Life insurance company also was ordered to cease and desist from the practices described in the order. Given the acceptance and commitment of Massachusetts Mutual Life insurance company to take the necessary measures to avoid similar matters in the future, the insurance commissioner of Puerto Rico agreed to modify the administrative fine to $1,500.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Massachusetts Mutual Life insurance company did not intend to fail to comply with the provisions of articles 11,230 and 27, 160 of the Puerto Rico insurance code, and the facts indicated in the order arose as an exceptional situation that does not constitute the normal or internal policy of Massachusetts Mutual Life insurance company's insurance business. Massachusetts Mutual Life insurance company alleged that the facts of the order were the result of actions and/or omissions of parties involved in the order which ended in a misunderstanding. Given that Massachusetts Mutual Life insurance company accepted and committed to take the necessary measures to avoid similar situations in the future, the commissioner of insurance of Puerto Rico agreed to modify the administrative fine to $1,500. Massachusetts Mutual Life insurance company proceeded to rescind the policy that was subject of the controversy and to reimburse the applicant (complainant) the sum of $65,000, as provided in the order.","ab":"Massachusetts Mutual Life","firms":[162264],"id":809},{"d":"2022-06-14","di":"2022-06-14","dr":"2022-06-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":62500.0,"dk":"2015045823202","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial risks of its market access business activity. The findings stated that the firm implemented within one of its order management systems (OMSS) a hard block control to prevent the entry of orders exceeding 200 percent of the 20-day average daily volume (ADV) in a security. The firm was unable to provide a reasonable basis for the 200 percent threshold or provide documentation to demonstrate that the ADV control was set at a reasonable level to prevent the entry of erroneous orders. The firm later lowered its ADV control, but did not provide documentation demonstrating that the control was set at a reasonable level to prevent the entry of erroneous orders. In addition, within its OMSS, the firm employed single order volume (SOV) controls and single order maximum notional value controls but did not sufficiently document that they accounted for the trading characteristics of individual securities or the trading history of its customers. The firm also had an order rate limit control in its OMSS that blocked orders that breached the firm's ADV, SOV or max notional controls noted above, but over a 30- second window. Because of the deficiencies with the firm's ADV, SOV and max notional controls, the order rate limit control was similarly not reasonably designed. The findings also stated that the firm's written supervisory procedures regarding credit control blocks were not reasonably designed because they did not account for trading on more than one oms. The firm later amended its procedures to specifically address setting customer credit limits across multiple OMSS. As a result of the foregoing, the firm failed to establish and maintain financial risk management controls and supervisory procedures that were reasonably designed to prevent the entry of orders that exceed appropriate pre-set credit or capital thresholds in the aggregate for each customer and the broker or dealer. The findings also included that the firm did not have controls to prevent the entry of orders solicited from institutional customers in restricted securities. As a result of the forgoing, the firm failed to establish and maintain a system of risk management controls and supervisory procedures that were reasonably designed to prevent the entry of orders that did not comply with regulatory requirements. Therefore, the firm violated Exchange Act § 15(c) (3), rules 15C3-5(b), 15C3-5(c)(1)(I), 15C3-5(c)(1)(II), 15C3-5(c)(2) thereunder, and Nasdaq rules 3010(a), 2010a, and Nasdaq general rule 9, sections 1(a) and 20(a).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":810},{"d":"2022-06-14","di":"2022-06-14","dr":"2022-06-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement; prejudgment interest; civil money penalty","st":"Final","fine":200000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-20899","al":"This regulatory action is related to Weiss Asset Management identifying and self-reporting seven violations of rule 105 of Regulation M under the Securities Exchange Act of 1934. Rule 105 generally prohibits buying an equity security in an underwritten secondary public offering if the buyer sold short the same security during the restricted period specified in the rule (generally five business days before the pricing of the offering).","res":"Settled","sd":"Penalty: $200,000; disgorgement: $6,508,792.81; prejudgment interest: $190,210.84; total: $6,899,003.65, which was paid on June 15, 2022.","sm":"Weiss Asset Management entered into an offer of settlement with the Securities and Exchange Commission to resolve the matter, and it was filed as a settled regulatory proceeding. No information Filed","ab":"Weiss Asset Management LP","self":true,"firms":[155564],"id":811},{"d":"2022-06-13","di":"2022-06-13","dr":"2022-06-13","k":"Regulatory Action","rg":"NYSE","reg":"NYSE","st":"Final","fine":62500.0,"dk":"2015045823201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial risks of its market access business activity. The findings stated that the firm implemented within one of its order management systems (OMSS) a hard block control to prevent the entry of orders exceeding 200 percent of the 20-day average daily volume (ADV) in a security. The firm was unable to provide a reasonable basis for the 200 percent threshold or provide documentation to demonstrate that the ADV control was set at a reasonable level to prevent the entry of erroneous orders. The firm later lowered its ADV control, but did not provide documentation demonstrating that the control was set at a reasonable level to prevent the entry of erroneous orders. In addition, within its OMSS, the firm employed single order volume (SOV) controls and single order maximum notional value controls but did not sufficiently document that they accounted for the trading characteristics of individual securities or the trading history of its customers. The firm also had an order rate limit control in its OMSS that blocked orders that breached the firm's ADV, SOV or max notional controls noted above, but over a 30- second window. Because of the deficiencies with the firm's ADV, SOV and max notional controls, the order rate limit control was similarly not reasonably designed. The findings also stated that the firm's written supervisory procedures regarding credit control blocks were not reasonably designed because they did not account for trading on more than one oms. The firm later amended its procedures to specifically address setting customer credit limits across multiple OMSS. As a result of the foregoing, the firm failed to establish and maintain financial risk management controls and supervisory procedures that were reasonably designed to prevent the entry of orders that exceed appropriate pre-set credit or capital thresholds in the aggregate for each customer and the broker or dealer. The findings also included that the firm did not have controls to prevent the entry of orders solicited from institutional customers in restricted securities. As a result of the forgoing, the firm failed to establish and maintain a system of risk management controls and supervisory procedures that were reasonably designed to prevent the entry of orders that did not comply with regulatory requirements. Therefore, the firm violated Exchange Act § 15(c) (3), rules 15C3-5(b), 15C3-5(c)(1)(I), 15C3-5(c)(1)(II), 15C3-5(c)(2) thereunder, and NYSE rule 3110(a) and (b).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":812},{"d":"2022-06-12","di":"2022-05-13","dr":"2022-06-12","k":"Regulatory Action","rg":"Other","reg":"California Department of Insurance","san":"Denial","st":"Final","dk":"PLBS 13370-A","al":"Default order indicating firm had violated sections 1668(b), 1668(e), 1668(h), and 1668(j) of California insurance code.","res":"Order","sm":"Agp inadvertently failed to separately notify the California insurance department (the \"department\") of certain regulatory events, all of which had been fully disclosed on the firm's publicly available record as maintained by the central registration depository (CRD), in connection with an application to act as a life only agent with variable contract authority. Documents from the department requesting information in relation to that application were mishandled by an assistant in agp's chicago office and a default order denying agp's application for the insurance license was entered. The firm is exploring possible options to vacate the default order.","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":813},{"d":"2022-06-07","di":"2022-06-07","dr":"2022-06-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"FILE NO. USRI-9504-01/URE-27-01/STAR NO. 20190639291-01","al":"RBC Capital Markets, LLC violated CBOE rules 4.1 and 6.9 in that the firm by and through its associated person entered an order in the same options class prior to the public disclosure of the original customer order's terms and conditions.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":814},{"d":"2022-06-07","di":"2022-06-07","dr":"2022-06-07","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Censure","os":"None","st":"Final","al":"The CBOE alleged that MR. Egan engaged in anticipatory hedging on behalf of his then current employer, RBC capital markets LLC, on September 17, 2019, in violation of CBOE rules 8.1 and 5.86 (which were rules 4.1 and 6.9 respectively in 2019).","res":"Consent","sd":"Not applicable","sm":"The CBOE initiated an investigation that MR. Egan violated certain CBOE rules as described in item 7 above. MR. Egan accepted a letter of consent that was effective on June 7, 2022, agreeing to a censure to resolve the allegations, without admitting or denying the allegations. No other sanctions were ordered in the letter of consent. No information Filed","ab":"Egan, Justin, Adam","firms":[158143],"id":815},{"d":"2022-06-03","dr":"2022-06-03","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Xchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"COMEX RSRH-22-6630, EFRP ID 2112MTL002 AND EFRP ID 2201MTL001","al":"CME group exchange (\"CME\") alleged that Deutsche bank AG (\"DB AG\") failed to report certain exchange for related position (\"EFRP\") trades in a timely manner in accordance with CME rule 538.I.","res":"Decision","sm":"On May 19, 2022, dbag received a preliminary decision from CME, which alleged that dbag failed to report certain efrp trades in a timely manner in accordance with CME rules. Dbag did not admit or deny the findings in the preliminary decision, which became final on June 3, 2022, and imposed a fine of $2,000, which will be timely paid.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":816},{"d":"2022-06-02","di":"2022-05-17","dr":"2022-06-02","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement","st":"Final","fine":135825.0,"dk":"19-1158-BC","al":"On May 17, 2022, a panel of the commodity exchange (COMEX) business conduct committee found that, on several occasions in May 2020 and July 2020, J. Aron & Company LLC (\"j. Aron\"), prior to engaging in any pre-hedging activity, failed to make clear to its counterparty that it was trading principally thereby violating COMEX rule 526.","res":"Settled","sm":"Pursuant to an offer of settlement, in which j. Aron neither admitted nor denied the rule violations upon which the penalty is based, j. Aron agreed to pay a fine in the amount of $125,000 and to disgorge profits in the amount of $10,825. The fine was paid in full by submission of a wire on June 2, 2022.","ab":"J. Aron & Company LLC","firms":[361],"id":817},{"d":"2022-06-01","di":"2022-06-01","dr":"2022-06-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution","st":"Final","dk":"2020068535401","al":"The Financial Industry Regulatory Authority found that Merrill Lynch, Pierce, Fenner & Smith (the firm) failed to establish and maintain a supervisory system reasonably designed to supervise sales of mutual fund class c shares between January 2015 and January 2021, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to pay restitution to affected customers totaling approximately $13.4 million, plus interest totaling approximately $1.8 million. The firm will make these payments in accordance with the written plan of remediation provided to FINRA for this matter.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":818},{"d":"2022-05-30","di":"2022-05-30","k":"Regulatory Action","rg":"Other","reg":"Bourse de Montreal Inc.","st":"Pending","dk":"FILE NO. EN-DC-22001","al":"The Bourse de Montreal Inc. (\"Bourse\") alleged that Citigroup Global Markets Inc. provided access to certain of its employees to the electronic trading system of the Bourse without having obtained the prior approval of the Bourse and did not establish and maintain a system to supervise the activities of each employee that is reasonably designed to achieve compliance with the Bourse rules.","sm":"Please remove this duplicate DRP regulatory action. Correct DRP #2257070 was filed on 2/09/23.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":819},{"d":"2022-05-27","di":"2021-12-09","dr":"2022-05-27","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange (\"Fse\")","san":"Reprimand","st":"Final","dk":"H 53-2021","al":"The Frankfurt Stock Exchange (\"Fse\") found that, from June 2021 through October 2021, Deutsche bank AG, Frankfurt am main (\"DB AG\") failed to convert 366 short codes into long codes as required by section 114 of the FSE rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On April 25, 2022, DB AG received a decision from fse finding that, from June 2021 through October 2021, DB AG failed to convert 366 short codes into long codes as required by section 114 of the fse rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014, and issuing a reprimand to DB AG, but not imposing a fine or other monetary sanction. The decision became final on May 27, 2022.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":820},{"d":"2022-05-24","di":"2022-03-23","dr":"2022-05-24","k":"Regulatory Action","rg":"Other","reg":"Box Exchange LLC.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061102","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of box exchange LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":821},{"d":"2022-05-23","di":"2022-05-23","dr":"2022-05-23","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and civil monetary penalty.","st":"Final","fine":1500000.0,"dk":"SEC ADMINISTRATIVE PROCEEDING FILE NO. 3-20867","al":"On May 23, 2022, the Securities and Exchange Commission (\"SEC\") entered a settlement order, relating to alleged material misstatements and omissions by BNY Mellon Investment Adviser, Inc. (\"BNYMIA\") concerning the consideration of environmental, social, and governance (\"ESG\") principles to make investment decisions for certain mutual funds advised by BNYMIA. The SEC alleged that BNYMIA made these representations to mutual fund investors (in prospectuses) and the funds boards, as well as in written responses to requests for proposals from other investment firms. A copy of the settlement order is available on the SEC's website at HTTPS://www.sec.gov.","res":"Order","sd":"As specified in section 12.a above and in section 13 below, bnymia agreed to pay a civil penalty in the amount of $1.5 million, which was paid on May 26, 2022.","sm":"Under the May 23, 2022 settlement order, without admitting or denying the SEC's findings, bnymia was censured and ordered to cease and desist from committing or causing violations of certain statutory provisions of the Investment Advisers Act of 1940 (and certain rules thereunder) and the Investment Company Act of 1940, and agreed to pay a civil penalty of $1.5 million to the SEC within 10 days of the entry of the order. The settlement order references that, in accepting the order, the commission considered remedial acts promptly undertaken by respondent and cooperation afforded the commission staff, including that, throughout the staff's investigation, bnymia provided detailed factual summaries and made substantive presentations on key topics which advanced the quality and efficiency of the staff's investigation and conserved commission resources. The settlement order does not affect bnymia's ability to manage the implicated mutual funds (or any other funds). A copy of the settlement order is available on the SEC's website at HTTPS://www.sec.gov.","ab":"BNY Mellon Investment Adviser,; BNY Mellon Investment Adviser, Inc.","self":true,"firms":[231,105642],"id":822},{"d":"2022-05-23","di":"2021-06-15","dr":"2022-05-23","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":82515.0,"dk":"442.2-398/665","al":"In May 2022, Yorkville Advisors Global, LP settled an investigation by the Swiss Federal Department of Finance regarding non- compliance with certain shareholder disclosure obligations of derivative holdings in three Swiss-listed companies. In the settlement, Yorkville Advisors Global agreed to a settlement amount of CHF 80,000, plus CHF 1,560 related to the cost of the proceedings. In return the Swiss Federal Department of Finance agreed to close the matter.","res":"Other","sd":"N/a","ab":"Yorkville Advisors Global, LP","self":true,"firms":[165390],"id":823},{"d":"2022-05-20","di":"2022-05-20","dr":"2022-05-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":7000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE 3-20866","al":"The Securities and Exchange Commission (SEC) alleged that Wells Fargo Clearing Services, LLC (the firm), in connection with the firm's failure to timely file certain suspicious activity reports (\"SARS\"), willfully violated section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-8 thereunder.","res":"Order","sm":"On May 20, 2022, the SEC announced that the firm agreed to a settlement of allegations that, in connection with the firm's failure to timely file certain sars between April 2017 and October 2021, it willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder. Without admitting or denying the findings contained in the order, with the exception of the SEC's jurisdiction over it and the subject matter of the proceedings, the firm consented to: (a) cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-8 promulgated thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $7,000,000. The firm paid the civil penalty on or about June 2, 2022","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":824},{"d":"2022-05-19","di":"2022-02-23","dr":"2022-05-19","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Other","os":"Matter was finalized with a warning letter and is no longer reportable. Please move DRP to archive.","st":"Final","dk":"2022-401I-001","al":"Matter was finalized with a warning letter and is no longer reportable. Please move DRP to archive. On February 23, 2022, ICE Clear Credit LLC (\"ICE\") alleged that a Goldman Sachs & Co. LLC (\"GSCO\") margin call payment was received nine minutes after the required deadline resulting in a technical default in violation of ICE Clear Credit rule 401(I).4","res":"Other","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":825},{"d":"2022-05-17","di":"2022-05-17","dr":"2022-05-17","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":244002.0,"dk":"REF. NO DSA-202207-0027_CMD-L-KB-BA","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on Bank of America, National association (BANA) for non-compliance with the mandatory credit allocation for agrarian reform credit/other agricultural credit (agri- agra) for the quarters ended 3-31-2020 through 12-31-2020.","res":"Other","sm":"The BSP imposed a penalty in the amount of PHP12,785,711.62 (approximately USD244,002) on bana. The payment was made in accordance with the terms of the letter.","ab":"Bank of America, National","firms":[7691],"id":826},{"d":"2022-05-04","di":"2022-05-04","dr":"2022-05-04","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, restitution, undertaking","st":"Final","fine":10000000.0,"dk":"FILE NO. 2022-CFPB-0002","al":"The Consumer Financial Protection Bureau (\"CFPB\") alleged that Bank of America, National association (the firm) (1) engaged in unfair acts and practices by responding to and processing garnishment notices against out-of-state bank accounts in violation of certain garnishment-issuing states' prohibitions against out-of-state garnishment; (2) engaged in unfair acts and practices by failing to apply the appropriate state exemptions to certain consumers' deposit accounts after receiving garnishment notices; (3) engaged in deceptive acts and practices by misrepresenting to consumers, by implication, the applicable state exemption rights for garnishment by applying the issuing state's exemptions instead of the exemptions of the Consumer's state of residence, where the states of issuance and residence differ; (4) engaged in unfair acts and practices by using a deposit agreement that required consumers to direct the firm not to contest legal process and waive the firm's liability for its unlawful garnishment conduct; and (5) engaged in deceptive acts and practices by suggesting consumers could not bring legal claims misrepresenting consumers' legal rights against the firm regarding garnishment proceedings. The CFPB alleges that these acts violated sections 1031(a) and 1036(a)(1)(b) of the Consumer financial protection act of 2010 (\"CFPA\"), 12 usc §§ 5531(a) and (c)(1) and 5536(a)(1)(b).","res":"Consent","sm":"Without admitting or denying the findings, the firm consented to (1) the entry of the order, (2) not violate sections 1031(a) and 1036(a)(1)(b) of the cfpa, 12 usc §§ 5531(a) and (c)(1) and 5536(a)(1)(b), (3) refund all garnishment-related fees paid by the affected consumers totaling no less than $592,000 and cancel any unpaid garnishment related fees, (4) certain undertakings, and (5) payment of a civil monetary penalty in the amount of $10,000,000. The civil monetary penalty was paid in accordance with the terms of the order.","ab":"Bank of America, National","firms":[7691],"id":827},{"d":"2022-04-29","di":"2022-04-04","dr":"2022-04-29","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20242.56,"al":"On 4 April 2022, LMR received notification from the Federal Financial Supervisory Authority (BAFIN) that it had determined that LMR shall pay a final penalty fee of 19,200eur in relation to the delayed reporting of short positions in german listed securities. Such fee related to six position reports in total (two positions relating to the same name) made during the period August 2019 to September 2020. Four position reports were delayed due to data errors and two due to human error (COVID-19 and public holiday related).","res":"Other","sm":"The matter was resolved on April 29, 2022 when LMR paid the above-mentioned penalty fee.","ab":"LMR Partners LLP","self":true,"firms":[159639],"id":828},{"d":"2022-04-28","di":"2022-04-13","dr":"2022-04-28","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"RSRH-22-6554","al":"On April 13, 2022, the market regulation department of the CME Group Inc. (\"CME\") determined that Goldman Sachs & Co. LLC (\"GSCO\") violated CME rule 561, for late adjustments to large trader reporting of certain listed futures and options positions on six different trade dates in March 2022.","res":"Decision","sm":"CME imposed a fine in the amount of $5000 which gsco paid by submission of a wire on April 28, 2022.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":829},{"d":"2022-04-22","di":"2021-07-19","dr":"2022-04-22","k":"Regulatory Action","rg":"Other","reg":"The Swiss Federal Department of Finance (\"Swiss FDF\")","san":"Other","os":"Settlement sum","st":"Final","fine":50000.0,"al":"On dates in 2017 and in 2018, BlackRock, Inc. was late in making certain threshold filings with the swiss regulator. These late filings were caused by two separate issues: (1) incorrect share issue information provided to BlackRock by its third party vendor; and, (2) BlackRock's outgoing email quarantine system incorrectly quarantining threshold information emails from BlackRock to the swiss regulator.","res":"Settled","sd":"The swiss federal department of finance imposed a settlement sum of CHF 50,000. BlackRock, Inc. paid the fee on April 22, 2022.","sm":"BlackRock, Inc. paid settlement sum of CHF 50,000 on April 22, 2022.","ab":"BlackRock, Inc; BlackRock, Inc.","firms":[106614,107105,282125,290336],"id":830},{"d":"2022-04-19","di":"2022-01-26","dr":"2022-04-19","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":213600.0,"dk":"FL DNR 20-26798","al":"The finansinspektionen notified Armistice Capital, LLC on January 26, 2022 of a penalty of sek 2,000,000 (US $213,600) due to the failure to report changes in holdings of certain shares within the time limit prescribed by Swedish law. When the penalty subsequently became legally binding, Armistice received an invoice and paid the fine on April 19, 2022.","res":"Decision","sd":"Armistice Capital, LLC paid sek 2,000,000 (US $213,600) to finansinspektionen.","ab":"Armistice Capital LLC","self":true,"firms":[168978],"id":831},{"d":"2022-04-15","di":"2022-03-31","dr":"2022-04-15","k":"Regulatory Action","rg":"NFA","reg":"National Futures Association","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":2500000.0,"dk":"22-BCC-003","al":"On March 31, 2022, in conjunction with accepting Goldman Sachs & Co. LLC's offer to settle the matter, the NFA's business conduct committee (\"BCC\") issued a complaint against the firm alleging violations of NFA rule 2-49(a), for failure to comply with certain requirements under CFTC regulation 23, and NFA rule 2-49(b), for failing to promptly submit accurate and complete information as required by the NFA.","res":"Decision","sm":"Goldman Sachs & Co. LLC made an offer to settle the matter, without admitting or denying liability, by paying a fine of $2,500,000 to NFA. On March 31, 2022, the BCC accepted the offer, and issued a decision (effective on April 15, 2022) ordering Goldman Sachs & Co. LLC to pay a fine in that amount. As part of a side letter executed in connection with the offer, the firm and NFA also agreed to additional terms and conditions with regard to a separate set of issues self-disclosed to NFA.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":832},{"d":"2022-04-14","di":"2021-12-07","dr":"2022-04-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":225000.0,"dk":"20190610611","al":"Matter was finalized and disclosed in form BD amendments - see occurrence id numbers 2207388, 2198938, 2198016, 2198013, 2197898, 2197896, 2197884, 2197741, 2196513, 2196512, 2196511, 2196510, 2193636, 2193625, and 2193582. Please move DRP to archive. On December 7, 2021, Goldman Sachs & Co. LLC (\"gsco\" or the \"firm\") received a notice from FINRA's department of enforcement, on behalf of CBOE exchange, inc. (\"CBOE\") and other exchanges. During gsco's 2019 cycle options examination, they identified a potential violation relating to the firm's failure to establish, maintain and enforce a supervisory system related to the recording of transmittal times for options orders manually routed to floor brokers.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":833},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Other","reg":"Miax Pearl, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061110","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Miax Pearl, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":834},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Gemx, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061103","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Nasdaq Gemx, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":835},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq MRX, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061106","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Nasdaq MRX, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":836},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Options Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061101","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Nasdaq Options Market, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":837},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061104","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Nasdaq Ise, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":838},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3500.0,"dk":"2019061061108","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of NYSE American LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":839},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE C2 Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"STAR NO. 20190610611-13 / FILE NOS. USE-2251-02 & URE-39-02","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of CBOE C2 Exchange, Inc., and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":840},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":80750.0,"dk":"2019061061107","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of NYSE ARCA, Inc., and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to comply with recordkeeping requirements and failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3 of the Securities Exchange Act of 1934, and the relevant exchange rules. FINRA has alleged that, during the period of January 2017 - December 2020, GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":841},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"STAR NO. 20190610611-15 / FILE NOS. USE-2251-03 & URE-39-03","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of CBOE BZX Exchange, Inc., and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":842},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"STAR NO. 20190610611-12 / FILE NOS. USE-2251-04 & URE-39-04","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of CBOE Edgx Exchange, Inc., and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":843},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"STAR NO. 20190610611-14 / FILE NOS. USE-2251-01 & URE-39-01","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of CBOE Exchange, Inc., and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":844},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Other","reg":"Miax Emerald, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061109","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Miax Emerald, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":845},{"d":"2022-04-14","di":"2022-03-23","dr":"2022-04-14","k":"Regulatory Action","rg":"Other","reg":"Miami International Securities Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2019061061111","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Miami International Securities Exchange, LLC, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3, and the relevant exchange rules. FINRA has alleged that GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":846},{"d":"2022-03-31","di":"2021-08-12","dr":"2022-03-31","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt FÜR Finanzdienstleistungsaufsicht (BAFIN, German Federal Financial Supervisory Authority)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":183150.0,"dk":"WA 17-WP 3120-2016/0031; WA 17-WP 3120-2018/0015; WA 17-WP 3120-2019/0128","al":"The german federal financial supervisory authority (\"BAFIN\") sanctioned Wellington management in relation to three individual administrative breaches of large shareholder disclosure requirements. The breaches relate to events which occurred in 2016, 2018 and 2019 respectively.","res":"Settled","sd":"The amount of the administrative charge was eur 165,000","sm":"We consented to the fine in full settlement of the matter. There were no additional conditions imposed.","ab":"Wellington Management Company LLP","self":true,"firms":[106595],"id":847},{"d":"2022-03-31","di":"2021-11-26","dr":"2022-03-31","k":"Regulatory Action","rg":"Other","reg":"Japan Financial Services Agency (\"FSA\")","san":"Other","os":"Business improvement order","st":"Final","dk":"N/A","al":"The regulatory action is directed to Mizuho bank LTD. (\"Mizuho bank\") and its parent company, Mizuho Financial Group inc. (the \"MHFG\"). Mizuho bank caused system failures eight times in total during the period from February to September 2021, which significantly affected its individual and corporate customers. Furthermore, in the restoration process after the system failure on September 30, a problem was found in relation to Mizuho bank's compliance with laws and regulations related to asset freezing and other economic sanctions as well as the AML/CFT guidelines. The FSA found that the direct cause of the series of multiple system failures as follows: ·Mizuho bank has failed to conduct verification sufficiently for ensuring quality in system development and responses to failures. ·Mizuho bank has not developed a maintenance and operation structure to ensure stable operation of its new core system, such as failing to correct problems in system maintenance and operation and to govern outsourcees sufficiently. ·Mizuho bank has failed to verify its preparedness for emergencies sufficiently through drills and training. The FSA further found that MHFG failed to manage and control Mizuho bank appropriately as a bank holding company and identified MHFG's governance related issues. The FSA considers that the root causes of these problems in terms of systems and governance are as follows: (1)disregard for system-related risks and expertise (2)disregard for the actual situation of the it section (3)lack of sensitivity to the impact on customers and disregard for the actual situation of the sales section (4)attitude to refrain from saying what needs to be said and to only do what was instructed accordingly, the FSA has ordered Mizuho bank and MHFG to formulate business improvement plans as further described in 12.b below.","res":"Order","sd":"See above.","sm":"Mizuho bank and MHFG will be taking actions as directed in the business improvement order and provide a business improvement plan, relevant reports, and status updates to the FSA by their respective due dates as set forth in the business improvement order.","ab":"Mizuho Financial Group,","firms":[110843],"id":848},{"d":"2022-03-23","di":"2022-03-23","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":80750.0,"dk":"2019061061105","al":"On the back of an escalation from a trading and financial compliance exam, FINRA enforcement found, on behalf of Nasdaq PHLX, and other exchanges, that Goldman Sachs & Co. LLC (\"GSCO\") failed to comply with recordkeeping requirements and failed to establish and maintain a supervisory system reasonably designed to prevent and detect violations of rule 17A-3 of the Securities Exchange Act of 1934, and the relevant exchange rules. FINRA has alleged that, during the period of January 2017 - December 2020, GSCO did not systematically record timestamps on options orders that were routed manually to floor brokers, as required by the applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting to or denying the findings, gsco has agreed to resolve the matter with the exchanges for an aggregate amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":849},{"d":"2022-03-21","di":"2022-03-04","dr":"2022-03-21","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Authority of Norway (\"Finanstilsynet\")","san":"Other","os":"Order","st":"Final","fine":1100.0,"al":"Maple rock received a letter from finanstilsynet noting that Maple rock had violated the notification requirement under section 3-5 of the norwegian securities trading act, CF. Regulation (EU) no 236/2012 (\"SSR\") article 5 CF. Article 9, by not notifying finanstilsynet within the time limit set out in the SSR of the relevant net short positions. Under this provision, firms are required to notify finanstilsynet of certain net short positions no later than 15:30 cet on the following trading day. Due to delays in resolving technical issues with finanstilsynet, Maple rock notified finanstilsynet of net short positions after the deadline. Maple rock did not appeal finanstilsynet's decision regarding the violation penalty or the resulting claim.","res":"Order","sd":"Maple rock paid the claim amount of nok 10,000 (approx. usd 1,100) on March 21, 2022.","sm":"In addition to paying the claim amount outlined above, Maple rock bolstered its operations by implementing additional supervisory and checklist controls to ensure timely and accurate filings. No further actions are required. No information Filed","ab":"Maple Rock Capital Partners Inc.","self":true,"firms":[173887],"id":850},{"d":"2022-03-10","di":"2022-02-10","dr":"2022-03-10","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland (Eurex)","san":"Reprimand","st":"Final","dk":"M 2021/60","al":"Eurex deutschland (\"Eurex\") found that, from April 2021 through June 2021, Deutsche bank AG, frankfurt am main (\"DB AG\") failed to convert 126 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014.","res":"Decision","sm":"On February 10, 2022, DB AG received a decision from Eurex finding that, from April 2021 through June 2021, DB AG failed to convert 126 short codes into long codes as required by section 72 of the Eurex exchange rules, resulting in a violation of section 26 g of the german stock Exchange Act as well as article 25(2) and (3) of regulation (EU) no. 600/2014, and issuing a reprimand to DB AG. The decision became final on March 10, 2022.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":851},{"d":"2022-03-04","di":"2020-08-19","dr":"2022-03-04","k":"Regulatory Action","rg":"State regulator","reg":"National Banking and Securities Commission (Comision Nacional Bancaria Y de Valores - \"CNBV\")","st":"Final","dk":"211-2/81637-RDGH/2020","al":"On August 19, 2020, Goldman Sachs Mexico, S.A. De C.V. casa de bolsa (\"MCBO\") received a fine imposed by the National Banking and Securities Commission (Comision Nacional Bancaria Y de Valores - \"CNBV\") of 403,000 pesos (approximately 18,500 usd), for an alleged violation of article 212, paragraph one, sub-section I, of the LMV. CNBV alleged MCBO failed to maintain an appropriate financial crimes risk assessment policy. MCBO paid the fine of 403,000 pesos on September 29, 2020. An administrative and a judicial appeal were filed, leading ultimately on March 2022 to a resolve of this matter in favor of MCBO. The penalty imposed by the CNBV was annulled, and MCBO obtained a refund in the updated amount (based on inflation index) of 440,842 pesos (approximately 20,700 usd).","res":"Other","sm":"Mcbo paid the fine of 403,000 pesos on September 29, 2020. An administrative and a judicial appeal were filed, leading ultimately on March 2022 to a resolve of this matter in favor of mcbo. The penalty imposed by the CNBV was annulled, and mcbo obtained a refund in the updated amount (based on inflation index) of 440,842 pesos (approximately 20,700 usd).","ab":"Goldman Sachs Mexico,","firms":[361],"id":852},{"d":"2022-03-03","di":"2020-09-15","dr":"2022-03-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Disgorgement","os":"Cease & desist and civil & administrative penalty/fine","st":"Final","fine":5500000.0,"dk":"ADMIN PROC FILE NO. 3-20789","al":"The SEC alleged that from 2016 through 2019, city national rochdale did not adequately disclose that, where it was not prudent or possible to invest a client's assets in the individual securities and bonds that comprise city national rochdale's internally developed model portfolios, city national rochdale would invest the client's assets in city national rochdale's proprietary mutual funds - which are designed to track the respective asset class allocations used in city national rochdale's model portfolios. City national rochdale and its affiliates received fees from such investments. The SEC further alleged that from 2016 until January 2019, city national rochdale received 12B-1 fees from certain clients, such as those who invest with city national rochdale through their third-party financial advisors, without adequately disclosing to such clients that a lower-cost share class was available to them. The SEC also alleged that city national rochdale failed to implement policies and procedures reasonably designed to detect and prevent conflicts of interest.","res":"Settled","sd":"Disgorgement of $22,013,612, plus prejudgment interest of $2,848,192. The disgorgement, penalty, and prejudgment interest amounts, collectively totaling $30,361,804, were paid into a fair fund escrow account on March 10, 2022.","sm":"Without admitting or denying the findings, city national rochdale consented to the entry of an order finding that city national rochdale violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder (the \"order\"). Under the terms of the order, city national rochdale was censured and agreed to pay a total of $30.4 million in disgorgement, prejudgment interest, and civil penalty, and to use those monies to establish a fair fund to repay affected clients. City national rochdale has enhanced its disclosures regarding potential conflicts of interest and, as part of the order, is retaining an independent compliance consultant to review its policies and procedures regarding the use of proprietary mutual funds.","ab":"RBC Rochdale, LLC","self":true,"firms":[117198],"id":853},{"d":"2022-02-28","di":"2022-02-28","dr":"2022-02-28","k":"Regulatory Action","rg":"State regulator","reg":"State Bank of Pakistan (\"SBP\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5682.0,"dk":"13938/DBK/02/2022","al":"The State Bank of Pakistan (\"SBP\") found that in 2011, Deutsche bank AG (\"DB AG\"), through its karachi branch, failed to report disbursement of, and interest charged on, certain loans to the SBP in monthly foreign exchange returns as required by foreign exchange circular letter no. 5.","res":"Order","sm":"On February 28, 2022, DB AG received an order from the SBP, finding that in 2011, DB AG, through its karachi branch, failed to report disbursement of, and interest charged on, certain loans to the SBP in monthly foreign exchange returns as required by foreign exchange circular letter no. 5. The SBP imposed an administrative penalty of PKR 1,030,000 which is approximately usd $5,682, which will be timely paid.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":854},{"d":"2022-02-24","di":"2022-02-24","dr":"2022-02-24","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service (\"FSS\"), South Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":19821.0,"dk":"CAPITAL MARKET INVESTIGATION DEPARTMENT, INVESTIGATION TEAM 3 - 116","al":"The south korean financial supervisory service claimed that on March 31, 2020 Vanguard Investments Australia limited (\"VIA\"), engaged in the sale of two korean-listed securities without corresponding ownership of the positions, a practice which is prohibited under south korean law.","res":"Decision & Order of Offer of Settlement","sd":"On February 02/24/2022 ~ $ 19821 (KRW 24 million) was submitted as voluntary payment, a discount from the KRW 30 million originally sought.","sm":"On February 24, 2022, the financial services commission imposed an administrative fine in the amount of ~$ 19821 (KRW 24 million) on via, (a discount from KRW 30 million for voluntary payment) in connection with one incident during 2020 in which via sold two korean-listed securities without corresponding ownership of the positions, which is a practice that is prohibited under south korean law.","ab":"Vanguard Investments","firms":[105958],"id":855},{"d":"2022-02-17","di":"2022-02-17","dr":"2022-02-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25500.0,"dk":"NO. USRI-9864-05","al":"From in or about August 2015 through November 2020 (the \"review period\"), the firm entered approximately 36,122,470 orders on BZX marked with the principal capacity code when they should have been marked with the agency 3 capacity code. Additionally, during the review period, the firm entered approximately 13,068,439 orders on BZX marked with the agency capacity code when they should have been marked with the principal capacity code. As a result, the firm's books and records contained inaccurate information as to the correct capacity on each order.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":856},{"d":"2022-02-17","di":"2022-02-17","dr":"2022-02-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8500.0,"dk":"NO. USRI-9864-06","al":"From in or about August 2015 through November 2020 (the \"review period\"), the firm entered approximately 217,214 orders on byx marked with the agency capacity code when they should have been marked with the principal capacity code. As a result, the firm's books and records contained inaccurate information as to the correct capacity on each order.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":857},{"d":"2022-02-17","di":"2022-02-17","dr":"2022-02-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25500.0,"dk":"NO. USRI-9864-07","al":"From in or about aug 2015 thru nov 2020(\"review period\"),the firm entered APPROX.35,507,601 orders on edgx marked with the prin capacity code when they should have been marked with the agency capacity code.additionally, during the review period,the firm entered APPROX.13,039,931 orders on edgx marked with the agency capacity code when they should have been marked with the prin capacity code.as a result,the firm's books and records contained inaccurate information as to the correct capacity on each order.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":858},{"d":"2022-02-17","di":"2022-02-17","dr":"2022-02-17","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25500.0,"dk":"NO. USRI-9864-08","al":"From in or about aug 2015 - nov 2020(the \"review period\"),the firm entered approx 31,079,479 orders on edga marked with the prin capacity code when they should have been marked with the agency capacity code.additionally,during the review period, the firm entered approx 10,293,131 orders on edga marked with the agency capacity code when they should have been marked with the prin capacity code.as a result,the firm's books and records contained inaccurate information as to the correct capacity on each order.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":859},{"d":"2022-02-17","di":"2021-04-21","dr":"2022-02-17","k":"Regulatory Action","rg":"Other","reg":"The Mexican Federal Economic Competition Commission (\"Cofece\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":82743.0,"dk":"VCN-002-2021","al":"In April 2019, certain portfolios managed by the registrant sold shares of international automotive components group north america, LLC to GCM spvmi, L.P. (the \"sale\"). Following the initiation of a verification procedure regarding the sale, cofece determined that the parties failed to comply with the federal economic competition law (\"LFCE\") requirement to apply to cofece for approval of the sale prior to its consummation.","res":"Order","sd":"Cofece imposed a civil monetary fine of 1,734,917.66 MXN pesos on the registrant for failing to comply with the lfce requirement to apply for approval of the sale by cofece prior to its consummation. The registrant paid usd 82,743, which constitutes the full fine, on March 10, 2022.","sm":"Cofece imposed a fine that has since been paid in full by the registrant, as described above in item 12. The fine relates solely to cofece's determination that the registrant failed to comply with the pre-consummation approval requirements as described above in item 7. Cofece approved the sale based on its determination that the sale did not impose a risk of harming free competition and open access to the markets. No information Filed","ab":"Franklin Mutual Advisers, LLC","self":true,"firms":[111376],"id":860},{"d":"2022-02-10","di":"2021-03-05","dr":"2022-02-10","k":"Regulatory Action","rg":"Other","reg":"Bank of Lithuania","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"On appeal","fine":117410.0,"dk":"361-1","al":"Tomasz Ciborowski, a partner, officer and shareholder of eic has been fined by the Bank of Lithuania (BOL) for an alleged breach related to the sale of ab \"NOVATURAS\" (NOVATURAS) shares on the Nasdaq vilnius during an accelerated book building (ABB) in November 2019. The fine has been upheld by a lithuanian court. Tomasz Ciborowski has appealed the verdict to a higher court which is currently pending.","res":"Order","sd":"Fine of $117,410 levied against tomasz Ciborowski. Payment pending resolution of the appeal.","sm":"The fine has been upheld by a lithuanian court. Tomasz Ciborowski has appealed the verdict to a higher court which is currently pending. No information Filed","ab":"Ciborowski, Tomasz","firms":[160833],"id":861},{"d":"2022-02-04","di":"2022-02-04","dr":"2022-02-04","k":"Regulatory Action","rg":"Other","reg":"Foreign Financial Regulatory Authority : Financial Supervisory Service","san":"Other","os":"Warning","st":"Final","fine":317257.0,"al":"Financial supervisory service alleged that Samsung Life Insurance (1) failed on obligation to comply with basic document (2) failed on obligation of protecting policyholder by delayed compensation payment (3) failed to keep credit information accurate and up-to-date(4) failed obligation to ensure safeness of electronic financial transaction.","res":"Decision","sm":"On feb 4, 2022, financial supervisory service issued a notice of its decision, finding Samsung Life Insurance co., LTD. liable for the allegations listed in our answer to question 7. As a result, financial supervisory serviceimposed a fine of KRW 377,000,000 on and issued a warning letter against Samsung Life Insurance co., LTD..","ab":"Samsung Life Insurance","firms":[158319],"id":862},{"d":"2022-01-28","di":"2022-01-28","dr":"2022-01-28","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission - Hong Kong (SFC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Reprimand","st":"Final","fine":44601423.0,"dk":"N/A","al":"The SFC alleged that Citigroup Global Markets asia limited (CGMAL) allowed various trading desks under its cash equities business to disseminate mislabeled indications of interest and make misrepresentations/non-disclosure to institutional clients when executing facilitation trades. The SFC also alleged that CGMAL incurred serious and systemic lapses across its controls framework and its first and second lines of defence.","res":"Other","sm":"The SFC reprimanded the firm and fined it HK348.25 million, which is approximately USD44,601,423.","ab":"Citigroup Global Markets","firms":[7059],"id":863},{"d":"2022-01-28","di":"2021-03-19","dr":"2022-01-28","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India (Sebi)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":114865.0,"dk":"SO/MC/HP/2021-22/6448-49 AND SO/MC/HP/2021-22/6451-57","al":"The securities and exchange board of india (\"SEBI\") alleged that: (1) PENBROOK capital advisors private limited (\"PENBROOK\"), the investment manager of peninsula Brookfield india real estate fund (the \"fund\") and a joint venture between (I) Brookfield capital partners LTD (BERMUDA), a wholly owned subsidiary of Brookfield asset management inc., and (II) peninsula land LTD, a third-party real estate developer); (2) the current and former directors of PENBROOK, including anuj ranjan (former director) and Sridhar Rengan (current director); and (3) peninsula Brookfield trustee private limited, (the trustee of the fund, having the same shareholders as PENBROOK) ((1), (2) and (3) collectively, the \"noticees\"), accepted impermissibly small investments from certain investors in the fund, failed to maintain sufficiently large investments themselves in the fund, and extended the tenure of the fund beyond the permissible period, in violation of the securities and exchange board of india act of 1922 and regulations framed thereunder (the \"SEBI act\"). SEBI further alleged that the annual compliance test report for the fund did not reflect the non-compliance matters associated with the alleged violations.","res":"Settled","sd":"The noticees agreed to a total settlement amount of inr 8,500,000, or approximately usd $114,865, which was timely paid without an admission or denial of guilt.","sm":"On March 19, 2021, the noticees received a notice from sebi alleging that the noticees accepted impermissibly small investments from certain investors in the fund, failed to maintain sufficiently large investments themselves in the fund, and extended the tenure of the fund beyond the permissible period, in violation of the sebi act. The notice further alleged that the annual compliance test report for the fund did not reflect the non-compliances associated with the alleged violations. In order to fully settle the proceeding, the noticees agreed to pay inr 8,500,000, or approximately usd $114,865, which was timely paid without an admission or denial of guilt. No information Filed","ab":"Sridhar Rengan; rengan, sridhar","firms":[316590,326747],"id":864},{"d":"2022-01-17","di":"2022-01-17","dr":"2022-01-17","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"al":"The firm failed to file a notice of relevant short position in violation of the notice requirement under section 3-14 of the norwegian securities trading act.","res":"Decision","sd":"$10000 paid on or about February 11, 2022 no portion was waived","sm":"Whitebox sold shares in May 2020. At the time of the sale, Whitebox had received an allocation of new issue shares in a public offering and considered itself in a long position. The Financial Supervisory Authority of Norway disagreed finding that the newly issued shares were not tradeable at the time of the sale and resulted in a net reportable short position. No information Filed","ab":"Whitebox Advisors LLC","self":true,"firms":[121995],"id":865},{"d":"2022-01-10","di":"2022-01-10","dr":"2022-01-10","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","st":"Final","fine":500000.0,"dk":"2019-09-00112","al":"NYSE ARCA enforcement alleged that: the firm failed to establish and maintain a reasonable supervisory system as to the firm's founder and former president, and certain accounts that he actively traded on behalf of customers, himself, and the firm or its affiliates; the firm continued to allow the founder to trade for these customer accounts along with his personal and proprietary accounts, without adequate process or procedures in place to supervise the order entry, trade executions, or trade allocations in these accounts; the founder and his trading assistant used an order management system that was not frequently used by other members of the firm; the order management system did not provide the ability to assign orders to specific firm affiliate accounts before execution and did not interface directly with the firm's back office system; . The founder's trading assistant manually inputted account allocations for trades executed by him after the trades occurred; the method for determining trade allocations for executed orders in the affiliate accounts remained undocumented and unapproved by the firm, and there continued to be no independent mechanism at the firm to assess the appropriateness of the allocations; the founder's trading activity presented conflicts of interest, and these conflicts were compounded by the fact that the founder regularly engaged in day trading for his personal and proprietary accounts in some of the same securities that he traded on behalf of his customers. In addition, NYSE alleged that as a consequence of failing to allocate orders entered on behalf of the affiliate accounts to specific accounts prior to order execution, the firm continued to inaccurately mark a subset of principal orders in certain proprietary accounts as agency. NYSE acknowledged that the firm made efforts to provide direct lines of supervision over the founder, but alleged that these efforts were delayed and did not reasonably resolve all of the issues identified herein. NYSE charged the firm with violations of NYSE ARCA rules 11.18, 11.1(b), and 9.2010-e.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $500,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":866},{"d":"2022-01-06","di":"2021-10-29","dr":"2022-01-06","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet - the Financial Supervisory Authority of Norway","san":"Other","os":"Violation fee","st":"Final","fine":4556.0,"dk":"20/10945","al":"Certain net short position filings of norwegian issuers were inadvertently made shortly after the next day filing deadline.","res":"Decision","sd":"The financial supervisory authority of norway decided to impose a violation penalty in the amount of nok 40,000 ($4556 usd)","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":867},{"d":"2021-12-31","di":"2021-12-29","dr":"2021-12-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":2600000.0,"dk":"2017054718901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report, and inaccurately reported, over-the-counter (OTC) options positions to the large options positions reporting system (LOPR). The findings stated that these violations were caused by errors in the reporting logic of the firm's internal risk system that it used to compile and submit OTC LOPR reports and it remained undetected for years. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to comply with its LOPR reporting obligations. The firm used supervisory systems to detect inaccurate LOPR reports. Those systems were not designed to detect, and in fact did not detect, instances where the firm failed to report OTC options positions to the LOPR. Further, the firm had no system to review whether contract quantities were reported accurately. In addition, the firm's WSPS identified firm principals who were responsible for conducting supervisory reviews of the firm's LOPR reports, but these procedures did not provide any guidance or set forth a process for how these principals should detect instances where the firm failed to report OTC options positions to the LOPR or to confirm the accuracy of reported contract quantities. Ultimately, the firm implemented multiple new surveillance reports and procedures to determine whether its reportable OTC positions had been reported and were accurate.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":868},{"d":"2021-12-28","di":"2021-12-28","dr":"2021-12-28","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":9800000.0,"dk":"WA 17 - WP 3139-2021/0001","al":"The German federal financial supervisory authority (\"BAFIN\") alleged that from April 24, 2019 to April 23, 2020, Deutsche bank AG (\"DB AG\"), as a supervised contributor to the euribor benchmark rate, did not have sufficiently effective controls for the submission of data pursuant to article 16(2)(a) of the regulation (EU) 2016/1011 (EU benchmark regulation).","res":"Consent","sm":"On December 28, 2021, DB AG received a fine notice in connection with a regulatory settlement with BAFIN. BAFIN alleged that from April 24, 2019 to April 23, 2020, DB AG, as a supervised contributor to the euribor benchmark rate, did not have sufficiently effective controls for the submission of data pursuant to article 16(2)(a) of the regulation (EU) 2016/1011 (EU benchmark regulation). DB AG agreed to a fine of 8,663,200 euros, which is approximately usd $9,800,000, which was timely paid on January 14, 2022.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":869},{"d":"2021-12-22","di":"2021-02-03","dr":"2021-12-22","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service (\"FSS\"), South Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15409.0,"dk":"CAPITAL MARKET INVESTIGATION DEPARTMENT, INVESTIGATION TEAM 3 - 116","al":"The south korean financial supervisory service (FSS) claimed that on September 27, 2019 The Vanguard Group, Inc. (\"VGI\"), engaged in the sale of one korean-listed security without corresponding ownership of the position, a practice which is prohibited under south korean law.","res":"Decision & Order of Offer of Settlement","sd":"On December 22, 2021 $15,409 (KRW 18 million) was submitted as payment.","sm":"On November 12, 2021, the south korean financial services commission imposed an administrative fine in the amount of $15,409 (KRW 18 million) on vgi, in connection with one incident during 2019 in which vgi sold a korean-listed security without corresponding ownership of the position, a practice that is prohibited under south korean law.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":870},{"d":"2021-12-22","di":"2021-02-03","dr":"2021-12-22","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service (\"FSS\"), South Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":19177.0,"dk":"CAPITAL MARKET INVESTIGATION DEPARTMENT, INVESTIGATION TEAM 3 - 116","al":"The south korean financial supervisory service claimed that on March 18, 2020 Vanguard Global Advisers, LLC (\"VGA\"), engaged in the sale of one korean-listed security without corresponding ownership of the position, a practice which is prohibited under south korean law.","res":"Decision & Order of Offer of Settlement","sd":"On December 22, 2021, $19,177 (KRW 22.5 million) was submitted as payment.","sm":"On November 12, 2021, the south korean financial services commission imposed an administrative fine in the amount of $19,177 (KRW 22.5 million) on vga, in connection with one incident during 2020 in which vga sold a korean-listed security without corresponding ownership of the position, which is a practice that is prohibited under south korean law.","ab":"Vanguard Global Advisers,","firms":[105958],"id":871},{"d":"2021-12-20","di":"2021-12-20","dr":"2021-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution","st":"Final","dk":"2016049188701","al":"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 reasonably designed to supervise representatives' 529 plan share-class recommendations. The findings stated that the firm's written supervisory procedures (WSPS) did not reasonably address the share-class suitability factors specific to 529 plan investments. The firm's WSPS for 529 plans did not specifically address the relationship between account beneficiary age, the number of years until funds would be needed to pay qualified education expenses, and 529 plan share-class suitability. Instead, they merely referenced suitability factors generally applicable to all investment products, such as fees and expenses, investment objective and risk tolerance. In addition, the firm's electronic alert system did not include parameters to identify 529 plan share-class recommendations that appeared to be inconsistent with the age of the account beneficiary or the account's stated investment horizon.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC; Wells Fargo Advisors Financial Network, LLC; Wells Fargo Clearing Services, LLC","self":true,"firms":[6413,11025,19616],"id":872},{"d":"2021-12-20","di":"2021-12-20","dr":"2021-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":950000.0,"dk":"NO. 2018057201801","al":"The Financial Industry Regulatory Authority found that Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) failed to reasonably supervise the transmittal of customer funds via externally-initiated automated clearing house transfers and as a result failed to detect that two of its registered representatives were able to misappropriate funds from certain customers, in violation of NASD rules 3010 and 3012 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPFS agreed to the imposition of a censure, a fine in the amount of $950,000, and completion of an undertaking. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":873},{"d":"2021-12-20","di":"2021-12-20","dr":"2021-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, undertaking","st":"Final","fine":1200000.0,"dk":"NO. 2018058015702","al":"The Financial Industry Regulatory Authority found that Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) failed to comply with its FINRA rule 8210 obligations in two separate FINRA enforcement investigations, which interfered with and delayed FINRA's investigations in violation of FINRA rules 8210 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPFS agreed to the imposition of a censure, a fine in the amount of $1,200,000, and completion of an undertaking. The fine was paid in accordance with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":874},{"d":"2021-12-20","di":"2021-12-20","dr":"2021-12-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and civil penalty","st":"Final","fine":4500000.0,"dk":"3-20683","al":"According to the SEC order, gim (I) did not offset from applicable management fees eligible fees paid to it by a fund portfolio company, (II) did not offset from applicable management fees the full amount it owed a fund's limited partners in connection with eligible fees it collected from a fund portfolio company and (III) included inconsistent provisions concerning the management fee calculation methodology in the offering and governing documents for two funds. In addition, the SEC order found that gim did not adopt and implement written policies and procedures reasonably designed to prevent the above violations of the Advisers Act.","res":"Settled","sd":"The penalty amount of $4,500,000 was paid on December 20, 2021.","sm":"The SEC administrative order is final. The civil penalty was paid within 10 days of the entry of the order.","ab":"BlackRock Advisors, LLC; BlackRock Capital Investment Advisors, LLC; BlackRock Financial Management, Inc","self":true,"firms":[106614,107105,290336],"id":875},{"d":"2021-12-17","di":"2021-12-17","dr":"2021-12-17","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Commision","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":125000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-20681","al":"On December 17, 2021, J.P. Morgan Securities LLC (\"JPMS\" or the \"respondent\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). The respondent consented to the entry of the order, which found that JPMS willfully violated section 17(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rules 17A-4(b)(4) and 17A-4(j) thereunder. The order found that from at least January 2018 through at least November 2020, JPMS employees often communicated about securities business matters on their personal devices, using text messaging applications (including whatsapp) and personal email accounts, none of these records were preserved by JPMS, and some of the written communications were not able to be furnished promptly to a commission representative when asked. The order also found that JPMS's widespread failure to implement its policies and procedures which forbid such communications led to its failure to reasonably supervise its employees within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":876},{"d":"2021-12-17","di":"2021-12-17","dr":"2021-12-17","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil penalty, undertakings","st":"Final","fine":75000000.0,"dk":"CFTC DOCKET NO. 22-07","al":"On December 17, 2021, J.P. Morgan Securities LLC (\"JPMS\"), JPMorgan chase bank, N.A. and J.P. Morgan Securities PLC (collectively, \"respondents\") entered into a settlement with the Commodity Futures Trading Commission (\"CFTC\") resulting in an administrative order (the \"order\"). The respondents consented to the entry of the order, which found (1) the respondents failed to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the Commodity Exchange Act (\"act\") and regulations 1.31, 23.201, 23.202(a)(1) and (b)(1); (2) JPMS failed to maintain required records in violation of section 4g of the act and regulation 1.35; (3) respondents failed to diligently supervise matters related to its business as a CFTC registrant in violation of section 4s(h)(1)(b) of the act and regulation 23.602; and (4) JPMS failed to diligently supervise matters related to its business as a CFTC registrant in violation of regulation 166.3. The order found that from at least July 2015, respondents' employees used unapproved methods to engage in business-related communications, including messages related to respondents' businesses as CFTC registrants that were required to be maintained. The order found that none of these written communications were maintained and preserved by respondents and they were not able to be furnished promptly to a CFTC representative when requested. The order also found that respondents failed to diligently supervise matters related to its business as a CFTC registrant.","res":"Order","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","firms":[79],"id":877},{"d":"2021-12-16","di":"2018-07-31","dr":"2021-12-16","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority (U.K.)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fine","st":"Final","fine":12363410.0,"dk":"N/A","al":"Gam international management limited (GIML) has reached a settlement with the FCA. The FCA opened the investigation into GIML following the suspension of an investment director on 31ST July 2018. This settlement concerns the operation of GIML's conflicts of interest framework between November 2014 and October 2017 and conflicts of interest arising out of three specific investments made by the absolute return bond fund (ARBF) team between October 2016 and March 2018. GIML has fully cooperated with the FCA's investigation, and this brings their investigation into GIML to a close. GIML is paying a financial penalty of GBP 9.1 million.","res":"Settled","sd":"Financial settlement","sm":"The FCA opened the investigation into giml following the suspension of an investment director on 31ST July 2018. This settlement concerns the operation of giml's conflicts of interest framework between November 2014 and October 2017 and conflicts of interest arising out of three specific investments made by the absolute return bond fund (ARBF) team between October 2016 and March 2018. No information Filed","ab":"Gam London Limited","self":true,"firms":[110670],"id":878},{"d":"2021-12-15","di":"2021-12-15","dr":"2021-12-15","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":1000000.0,"dk":"3-20679","al":"The Securities and Exchange Commission (the \"commission\") alleged that from January 2017 through September 2018 (the \"relevant period\"), the firm engaged in unregistered offers and sales of large blocks of low-priced securities by an offshore customer, in violation of sections 5(a) and 5(c) of the Securities Act of 1933 (the \"Securities Act\"), as no registration statement was in effect as to the offers and sales of the securities at issue, no exemption from registration was applicable, and the firm failed to conduct a reasonable inquiry. In addition, the commission alleged that Wedbush failed to file suspicious activity reports for certain suspicious transactions that it executed on behalf of its offshore customer during the relevant period, as required by section 17(a) of the Exchange Act and rule 17A-8 thereunder, despite the presence of certain red flags concerning the offshore customer's activities.","res":"Order","sd":"The firm shall cease and desist; is censured; shall comply with the undertakings enumerated in the offer; and shall pay disgorgement of $173,508.40, prejudgment interest of $34,332.16, and a civil penalty of $1,000,000 to the Securities and Exchange Commission.","sm":"The Securities and Exchange Commission (the \"commission\") accepted an offer of settelment from Wedbush. Pursuant to the settlement offer, Wedbush did not admit or deny the commission's findings that Wedbush willfully violated sections 5(a) and 5(c) of the Securities Act of 1933 (the \"Securities Act\"), and section 17(a) of the Exchange Act of 1934 (the \"Exchange Act\"), and rule 17A-8 thereunder. Wedbush was ordered to: cease and desist from committing or causing any violations and any future violations of sections 5(a) and 5(c) of the Securities Act and section 17(a) of the Exchange Act and rule 17A-8 promulgated thereunder; was censured; was ordered to comply with the undertakings enumerated in the offer; and agreed to pay disgorgement of $173,508.40, prejudgment interest of $34,332.16, and a civil penalty of $1,000,000 to the commission.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":879},{"d":"2021-12-15","di":"2021-12-15","dr":"2021-12-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":550000.0,"dk":"2017054432703","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPS), reasonably designed to achieve compliance with FINRA and municipal securities rulemaking board (MSRB) rules with respect to representatives' recommendations of high-yield corporate and municipal bonds. The findings stated that the firm's policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. The procedures did not include guidance as to how much of a customer's portfolio should be in vested in these products based on the customer's investor profile. The findings also stated that the firm used two automated alerts, a daily alert and a monthly alert, to identify potentially unsuitable concentrations of high-yield bonds in customer accounts, but neither alert functioned as intended. After the firm changed the tax coding of municipal bonds in its system, it inadvertently disabled the ability of the high-yield bond alerts to identify potential concentration issues for further assessment. The firm did not detect that these alerts were not working, in part, because the firm did not test its alerts. Once the firm first discovered that the alerts were defective, it did not fix the alerts until ten months later. During this ten-month period, the firm did not adopt alternative measures to identify potentially unsuitable concentrations in high-yield bonds. The firm also did not notify supervisors that the alerts were not working as intended and that they could not rely on the alerts for their review. As a result, the firm failed to review more than 100 customer accounts with conservative profiles for potentially unsuitable concentrations of high-yield bonds. In a number of those accounts, the holdings in high-yield bonds were more than six times the thresholds set by the firm.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":880},{"d":"2021-12-13","di":"2020-12-15","dr":"2021-12-13","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Censure","st":"Final","fine":12500.0,"dk":"NYSE PROCEEDING NO. 2020-12-15- 00012","al":"On June 11, 2018, baird received orders from a customer to buy security 1. After receiving the orders, baird routed them, as two separate parent orders to two different NYSE floor broker firms. Both recipient floor broker firms, as executing brokers, broke up the parent orders into child orders and routed them to the market for execution. Baird's sending of these orders to two different floor broker firms inadvertently led to competing child orders on behalf of the customer in security 1 that could execute at the same time and price over a six-hour period. Neither floor broker firm was aware the other firm was handling the competing orders. One purpose of NYSE rule 122 is to prevent circumvention of the NYSE parity allocation rules so that a member organization or its customer cannot obtain preferential execution by sending competing orders to multiple floor brokers at the same time. Because baird routed orders to NYSE floor broker firms for execution, the firm had obligations to implement reasonably designed supervisory systems, including WSPS, to detect and prevent routing of potentially competing orders to two different floor brokers. Specifically, baird should have had supervisory procedures in place to conduct reasonable due diligence to assure that orders it was routing to different floor broker firms in the same security that could have executed at the same time and price were not for the account of the same principal. Prior to October 2020, the firm had no procedures in place addressing NYSE rule 122.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Baird paid the $12,500.00 fine on 12/29/2021","sm":"The firm accepted and consented without admitting or denying the findings and the imposition of a $12,500 fine. Upon identification of the order routing incident by the NYSE, baird promptly re-educated trading staff on the requirements of NYSE rule 122 and will continue to appropriately educate and remind trading staff of their responsibilities. Baird also took steps to update its supervisory system by implementing a supervisory review procedure specific to the requirements of NYSE rule 122.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":881},{"d":"2021-12-13","di":"2021-12-13","dr":"2021-12-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine and restitution","st":"Final","fine":100000.0,"dk":"2016050947801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to theentry of findings that it failed to establish and maintain a supervisory system that wasreasonably designed to supervise short-term trading of unit investment trusts (UITS). Thefindings stated that the firm did not establish a supervisory system that was reasonablydesigned to identify early uit rollovers. The firm had an automated report that flagged salesof a mutual fund or uit followed within 25 days by a purchase of any of those same products,and in the ordinary course the firm sent switch letters to customers when this report wasgenerated. However, that report did not account for the length of time a uit was held beforeit was sold. As a result, the firm did not have any automated system to identify when uitswere rolled over significantly in advance of their maturity date - even though the firm'swritten supervisory procedures (WSPS) recognized that UITS should generally be held tomaturity. As such, the firm failed to detect that on thousands of occasions, itsrepresentatives recommended potentially unsuitable early series- to-series rollovers. Onthousands of other occasions, the firm failed to detect that its representatives repeatedly recommended other potentially unsuitable early uit rollovers that caused customers to pay unnecessary sales charges. Collectively, these early uit rollovers may have caused customers to pay $375,137.67 in sales charges that they would not have incurred had they held the UITS until their maturity dates. The firm has voluntarily employed corrective measures to revise its procedures, including by revising its WSPS and by implementing improved controls relevant to its uit business, such as establishing automated alerts to assist in identifying when representatives recommend early uit rollovers.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":882},{"d":"2021-12-13","di":"2021-12-13","dr":"2021-12-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine and restitution","st":"Final","fine":550000.0,"dk":"2016050947801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to theentry of findings that it failed to establish and maintain a supervisory system that wasreasonably designed to supervise short-term trading of unit investment trusts (UITS). Thefindings stated that the firm did not establish a supervisory system that was reasonablydesigned to identify early uit rollovers. The firm had an automated report that flagged salesof a mutual fund or uit followed within 25 days by a purchase of any of those same products, and in the ordinary course the firm sent switch letters to customers when this report was generated. However, that report did not account for the length of time a uit was held before it was sold. As a result, the firm did not have any automated system to identify when UITS were rolled over significantly in advance of their maturity date - even though the firm's written supervisory procedures (WSPS) recognized that UITS should generally be held to maturity. As such, the firm failed to detect that on thousands of occasions, its representatives recommended potentially unsuitable early series-to-series rollovers. On thousands of other occasions, the firm failed to detect that its representatives repeatedly recommended other potentially unsuitable early uit rollovers that caused customers to pay unnecessary sales charges. Collectively, these early uit rollovers may have caused customers to pay $2,083,624.66 in sales charges that they would not have incurred had they held the UITS until their maturity dates. The firm has voluntarily employed corrective measures to revise its procedures, including by revising its WSPS and by implementing improved controls relevant to its uit business, such as establishing automated alerts to assist in identifying when representatives recommend early uit rollovers.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":883},{"d":"2021-12-10","di":"2021-12-10","dr":"2021-12-10","k":"Regulatory Action","rg":"Other","reg":"Louisiana Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250.0,"dk":"N/A","al":"RBC Capital Markets, LLC. failed to timely report administrative actions in violation of l.a.r.s 22:1563(a).","res":"Settled","sm":"Form BD amendments which were submitted and on file with FINRA were not uploaded to insurance national insurance producer registry attachment wharehouse in a timely manner.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":884},{"d":"2021-12-10","di":"2018-01-18","dr":"2021-12-10","k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":298353.0,"al":"Pursuant to regulation (EU) no. 236/2012 on short selling (the \"regulation\"), Jupiter Investment management limited (\"JIML\") is required to file net short position reports (the \"reports\") with the autoriteit financiele markten (the dutch financial supervisory authority) when certain prescribed thresholds are crossed. In November 2017, the compliance function of merian global investors (UK) limited (\"MGI\"), now known as JIML, identified an error in the monitoring of such thresholds. MGI immediately commenced an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. On January 18 2018, MGI notified the autoriteit financiele markten of its inadvertent failure to file the reports during the period between April 2016 and January 2018. MGI filed the delinquent reports and put appropriate controls in place to mitigate the risk of the error reoccurring. The autoriteit financiele markten subsequently found that MGI breached the regulation by failing to file such reports.","res":"Consent","sd":"See details in number 13 below","sm":"On June 24, 2021, the autoriteit financiele markten determined that mgi breached the regulation and issued a penalty fee of eur 250,000. Jupiter Investment management limited paid the penalty fee to autoriteit financiele markten on December 10 2021.","ab":"Jupiter Investment","firms":[306863],"id":885},{"d":"2021-12-07","di":"2021-05-11","dr":"2021-12-07","k":"Regulatory Action","rg":"Other","reg":"German Federal Financial Supervisory Authority (\"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":376996.0,"dk":"WA 17-WP 3120-2021/0030","al":"BAFIN claimed that The Vanguard Group, Inc. (\"VGI\") erred in performing a technical process from 2017 to 2019, which led to untimely voting rights notifications for three positions in connection with securities lending arrangements.","res":"Decision & Order of Offer of Settlement","sd":"On December 7, 2021 $376,996 (eur 290,000) was accepted as payment.","sm":"On November 25 2021, BAFIN imposed an administrative fine in the amount of $376,996 (eur 290,000) on vgi, related to a technical error in fulfilling voting rights notification obligations within the prescribed period for three positions from 2017 thru 2019.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":886},{"d":"2021-12-06","di":"2021-12-06","dr":"2021-12-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Civil fine","st":"Final","fine":2250000.0,"dk":"2020066327501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to store records related to its customer identification program (CIP)-an integral part of an anti-money laundering program-in the required non-erasable and non-writable format, known as \"write once, read many\" (WORM) format. The findings stated that firm personnel discovered that the firm was storing records related to its CIP on a system that was not WORM compliant, and advised an internal working group that addressed books and requirements of the issue. The working group concluded that the issue should be escalated to determine if it needed to be reported to FINRA. The issue, however, was not escalated to the firms' working group that considered FINRA reporting obligations, and the firm did not report it to FINRA or remediate it at that time. The firm continued to store CIP records on the non-WORM compliant platform for more than three years. Approximately 13 million CIP-related records, pertaining to approximately 8.2 million customers, were stored on the non-WORM compliant platform, with approximately 4 million documents having been stored on the firm's non-WORM compliant platform after the issue was discovered. Therefore, the firm violated Exchange Act rule 17A-4(f)(2)(II)(a). In addition, the firm failed to notify FINRA, its designated examining authority, at least 90 days prior to using the non-WORM compliant platform on which it stored the CIP- related records. Therefore, the firm violated Exchange Act rules 17A-4(f)(3)(v) and 17A-4(f)(2)(I).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm entered into an AWC agreement with FINRA on December 6, 2021, fully resolving this matter, which included agreement to the entry of a censure against the firm and a fine payable to FINRA. Fine was received by FINRA on December 23, 2021.","ab":"Wells Fargo Advisors Financial Network, LLC; Wells Fargo Clearing Services, LLC","self":true,"firms":[11025,19616],"id":887},{"d":"2021-12-03","di":"2021-12-03","dr":"2021-12-03","k":"Regulatory Action","rg":"Other","reg":"Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":350000.0,"dk":"CO-21-201911026-S","al":"The consent order alleged that the firm violated section 36B-31-6F of the regulations under the Connecticut uniform Securities Act by failing to enforce its supervisory procedures with regard to two former agents of the firm, Connecticut residents james thomas booth (CRD number 1906145) and matthew o. Clason (CRD number 4692266). Booth allegedly misappropriated approximately $1.1 million from his LPL Financial LLC clients, and plead guilty to one count of securities fraud in federal court (United States v. james t. Booth, crim. No. 19-CR-00699-JGK (S.D.N.Y.)). On November 17, 2020, booth was sentenced to a 42-month prison term. Booth's conduct also involved generating consolidated client account statements with fictitious investments and sending those statements to clients in an effort to deceive clients about the value of their accounts. Booth had been the subject of a June 18, 2020 order issued by the commissioner revoking booth's registration as a broker-dealer agent and investment adviser agent and fining booth $100,000, a penalty amount that remains unpaid. The revocation was uncontested. The consent order acknowledged that LPL Financial LLC had entered into settlements with those firm clients who were affected by booth's scheme, and that the firm had repaid those clients a total of $1,636,347.07. Clason purportedly opened a joint bank account with an LPL Financial, LLC customer without the firm's knowledge, then transferred approximately $668,000 from the customer's investment accounts (approx $365,000 from her outside RIA investment account, and $253,000 from her brokerage annuity contracts) to the joint account. Clason then proceeded to withdraw at least $620,000 from the joint account for his personal use without the customer's knowledge or consent. On May 12, 2021, in connection with the foregoing conduct, clason plead guilty to one count of wire fraud in federal court (United States v. matthew o. Clason, crim. No. 3:21-CR-00066 (d. Conn)). Clason was sentenced on December 6, 2021, to 30 months imprisonment. The LPL Financial LLC customer affected by clason's conduct has since been fully compensated through a February 25, 2021 settlement involving the firm and other parties. LPL Financial, LLC contributed $500,000 to that settlement.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":888},{"d":"2021-12-02","di":"2021-12-02","dr":"2021-12-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":375000.0,"dk":"2020067388401","al":"Alleged violation of article v, section 2(c) of FINRA's by-laws, FINRA rule 3110 and 2010 in that Citigroup Global Markets Inc. failed to amend, timely or at all, the uniform application for securities industry registration or transfer (Form U4) of certain registered representatives to disclose certain unsatisfied tax liens and judgments and failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to ensure that it disclosed unsatisfied liens or judgments of registered representatives on Form U4S from January 1, 2016 through August 31, 2021.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and $375,000 fine","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":889},{"d":"2021-12-02","di":"2021-12-02","dr":"2021-12-02","k":"Regulatory Action","rg":"Other","reg":"The European Commission (\"The Commission\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":196954958.0,"al":"The european commission in December 2021 completed a cartel investigation into the foreign exchange ('forex') spot trading market by imposing fines on five financial institutions, including HSBC Holdings PLC. The commission's investigation focused on the trading of the G10 currencies. The commission's investigation revealed that some traders in charge of the forex spot trading of G10 currencies, acting on behalf of the fined banks, exchanged sensitive information and trading plans, and occasionally coordinated their trading strategies through an online professional chatroom. The commission found that these information exchanges enabled the traders tomake informed market decisions on whether and when to sell or buy the currencies they had in their portfolios, as opposed to a situation where traders acting independently from each other take an inherent risk in taking these decisions. Occasionally, these information exchanges also allowed the traders to identify opportunities for coordination, for example through a practice called \"standing down\", whereby some of them would temporarily refrain from trading to avoidinterfering with another trader. HSBC cooperated with the investigation and has paid the fine noted below","res":"Settled","sd":"Fine announced by the commission on 12/2/21","sm":"HSBC Holdings caused the fine to be paid within in the timeframe directed by the commission.","ab":"HSBC Bank PLC; HSBC Holdings PLC","firms":[154700,172522,324468],"id":890},{"d":"2021-11-30","di":"2020-08-31","dr":"2021-11-30","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Civil penalty of not less than $5,000 and not more than $10,000 per violation","st":"Final","fine":32500000.0,"al":"Goldman Sachs & Co. LLC (\"GSCO\") and other underwriters of residential mortgage-backed securities (\"RMBS\") were named in a complaint in intervention filed by the state of New Mexico on August 31, 2020 and moved to unseal a qui tam action initially filed by integra rec, LLC. the complaint in intervention asserted violations of the New Mexico fraud against taxpayers act, the New Mexico Securities Act, and the common law of New Mexico based on allegations the defendants misrepresented the nature, quality, characteristics, and risk profile of residential mortgage pools backing RMBS.","res":"Settled","sd":"The state of New Mexico and the defendants, including gsco, entered into a settlement agreement for the total amount of $32,500,000 on November 19, 2021, in which the defendants settled all claims without any admission of liability or wrongdoing.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":891},{"d":"2021-11-24","di":"2021-11-24","dr":"2021-11-24","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Censure","os":"Monetary fine","st":"Final","fine":12690.0,"dk":"USRI-8346-06","al":"Pursuant to a letter of consent (LOC) which became final on 11/24/2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, on December 19, 2019, did not have reasonably designed order-by- order size controls to prevent the entry of erroneous orders on the exchange and was unable to provide documentation of empirical analysis to justify the threshold parameters at which such controls were set; and did not maintain written supervisory procedures regarding the review and release of orders paused by soft blocks or maintain documentation surrounding the review and/or rationale for the release of orders paused by soft blocks. The LOC found that these practices violated Exchange Act rule 15C3-5, and CBOE Byx Exchange, Inc. rule 3.2.","res":"Consent","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the letter of consent, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the letter of consent are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":892},{"d":"2021-11-24","di":"2021-11-24","dr":"2021-11-24","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Censure","os":"Monetary fine","st":"Final","fine":44450.0,"dk":"USRI-8346-05","al":"Pursuant to a letter of consent (LOC) which became final on 11/24/2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, on August 7, 2018 and December 19, 2019, did not have reasonably designed order-by-order size and price controls to prevent the entry of erroneous orders on the exchange and was unable to provide documentation of empirical analysis to justify the threshold parameters at which such controls were set; and did not maintain written supervisory procedures regarding the review and release of orders paused by soft blocks or maintain documentation surrounding the review and/or rationale for the release of orders paused by soft blocks. The LOC found that these practices violated Exchange Act rule 15C3-5, and CBOE BZX Exchange, Inc. rule 3.2.","res":"Consent","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the letter of consent, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the letter of consent are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":893},{"d":"2021-11-24","di":"2021-11-24","dr":"2021-11-24","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Censure","os":"Monetary fine","st":"Final","fine":34730.0,"dk":"USRI-8346-07","al":"Pursuant to a letter of consent (LOC) which became final on 11/24/2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, on August 7, 2018 and December 19, 2019, did not have reasonably designed order-by-order size and price controls to prevent the entry of erroneous orders on the exchange and was unable to provide documentation of empirical analysis to justify the threshold parameters at which such controls were set; and did not maintain written supervisory procedures regarding the review and release of orders paused by soft blocks or maintain documentation surrounding the review and/or rationale for the release of orders paused by soft blocks. The LOC found that these practices violated Exchange Act rule 15C3-5, and CBOE Edgx Exchange, Inc. rule 3.2.","res":"Consent","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the letter of consent, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the letter of consent are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":894},{"d":"2021-11-24","di":"2021-11-24","dr":"2021-11-24","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","san":"Censure","os":"Monetary fine","st":"Final","fine":28130.0,"dk":"USRI-8346-08","al":"Pursuant to a letter of consent (LOC) which became final on 11/24/2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, on December 19, 2019, did not have reasonably designed order-by- order size controls to prevent the entry of erroneous orders on the exchange and was unable to provide documentation of empirical analysis to justify the threshold parameters at which such controls were set; and did not maintain written supervisory procedures regarding the review and release of orders paused by soft blocks or maintain documentation surrounding the review and/or rationale for the release of orders paused by soft blocks. The LOC found that these practices violated Exchange Act rule 15C3-5, and CBOE Edga Exchange, Inc. rule 3.2.","res":"Consent","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the letter of consent, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the letter of consent are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":895},{"d":"2021-11-23","di":"2021-11-11","dr":"2021-11-23","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"RSRH-21-6403","al":"On November 11, 2021, the market regulation department of the CME Group Inc. (\"CME\") determined that Goldman Sachs & Co. LLC (\"GSCO\") violated CME rule 561 for late adjustments to large trader reporting of certain listed futures and options positions on six trade dates in positions in October 2021.","res":"Decision","sm":"CME imposed a summary fine in the amount of $2,500, which gsco paid by submission of a wire on November 23, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":896},{"d":"2021-11-19","di":"2021-11-19","dr":"2021-11-19","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Options Market","san":"Censure","os":"Fine, restitution","st":"Final","fine":50000.0,"dk":"2020.01.0101","al":"Alleged violation of nom rule options 5, section 101 and rules 3010(a) and 2010(a) in that Citigroup Global Markets Inc. submitted a contrary exercise advice without meeting the exceptions set forth in the rule in order to take advantage of a material news announcement after the 5:30 P.M. Exercise cut-off time on February 15, 2019 and the firm's supervisory system was not reasonably desigend to ensure that employees submitted cea's in accordance with nom rules from at least February 2019 through July 2021.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $50,000 and restitutions of $1,722,604.27","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":897},{"d":"2021-11-18","di":"2021-11-18","dr":"2021-11-18","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","st":"Final","fine":32500000.0,"al":"State of New Mexico alleges JPMorgan securities LLC (JPMS) making false and/or fraudulent payments and making untrue statements under the New Mexico fraud against taxpayers act (nmsa § 44­9­1, et seq.), The New Mexico Securities Act (nmsa §§ 58­ 13B-1, et seq.), And the common law of New Mexico involving the sale of residential mortgage-backed securities (\"RMBS\").","res":"Settled","sd":"Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (general securities principal, financial operations principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against applicant or control affiliate, date paid and if any portion of penalty was waived: without admitting liability, defendants agreed to pay $32.5 million to settle allegations that they did not adequately disclose the characteristics of certain mortgage-backed securities when they were purchased by New Mexico pension funds and a state- run investment council. The settlement amount will be paid within 30 days of dismissal of the action with prejudice.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":898},{"d":"2021-11-17","di":"2021-11-17","k":"Regulatory Action","dk":"2021-0220-S","ab":"Georger, F, D","firms":[7691],"id":899},{"d":"2021-11-10","di":"2021-06-16","dr":"2021-11-10","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3997.76,"dk":"442 2-629","al":"On June 16, 2021, the Swiss Federal Department of Finance concluded their administrative criminal investigation and determined that Goldman Sachs international (\"GSI\") violated the disclosure requirements of article 151 and article 134 of the financial market infrastructures act, by submitting late notices for twelve transactions executed during an ongoing tender offer of a Swiss issuer.","res":"Decision","sm":"The Swiss Federal Department of Finance issued a fine of CHF 3640 (approximately usd 3997.76) which was paid by a submission of a wire on November 10, 2021.","ab":"Goldman Sachs","firms":[361],"id":900},{"d":"2021-10-29","di":"2021-09-22","dr":"2021-10-29","k":"Regulatory Action","rg":"Other","reg":"Japan Financial Services Agency","san":"Other","os":"Business improvement order","st":"Final","dk":"N/A","al":"Mizuho Financial Group inc. (the \"advisory affiliate\")'s banking subsidiary, Mizuho bank, LTD. (\"Mizuho bank\") had several system failures in 2021 which caused significant influences on its customers. In the meantime, Mizuho bank plans to renew and update its systems necessary for business continuity (the \"system renewal plan\"). In connection with the above, the FSA issued a business improvement order to Mizuho bank and the advisory affiliate thereby ordering Mizuho bank (1) to reexamine and review the system renewal plan taking into account the past system failures, the necessity and urgency of the system renewal plan, and possible risks to the banking business, (2) to ensure appropriate controls be placed in connection with the system renewal plan and (3) to submit the results of (1) and (2) above. The business improvement plan also ordered the advisory affiliate, as a bank holding company of Mizuho bank, to verify the results of Mizuho bank's reexamination and review of the system renewal plan as well as a plan for appropriate controls, and to submit the results of such verification by October 29, 2021.","res":"Other","sd":"Same as above.","sm":"The advisory affiliate is in the process of reviewing and verifying Mizuho bank's system renewal plan and management controls, and preparing the verification results to be submitted to the FSA.","ab":"Mizuho Financial Group,","firms":[110843],"id":901},{"d":"2021-10-28","di":"2021-10-28","dr":"2021-10-28","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"CBOT 21-1460-BC","al":"A panel of the Chicago Board of Trade business conduct committee (\"BCC\") alleged that Bank of America, National association (the \"firm\") (1) executed an exchange for related risk (\"EFR\") transaction that consisted of the simultaneous execution of futures positions without the exchange of corresponding OTC swaps, thereby constituting a non-bona fide EFR; and (2) as part of the same large, counterparty-proposed transaction, executed buy and sell orders for the same account and knew or reasonably should have known that the orders would match and avoid any market risk. The BCC found that the firm violated CBOT rules 538.c and 534.","res":"Other","sm":"Without admitting or denying the rule violation or factual findings upon which the penalty is based, the BCC ordered the firm to pay a $30,000 fine.","ab":"Bank of America, National","firms":[7691],"id":902},{"d":"2021-10-20","di":"2021-10-04","dr":"2021-10-20","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":112000.0,"dk":"2021SCM066","al":"On October 4, 2021 New York Life Insurance company (\"NYLIC\") received an order of civil penalty and adoption of a corrective action plan from the Kentucky Department of Insurance alleging that NYLIC incorrectly implemented premium rate increases on 112 individual long term care contracts in violation of Kentucky insurance law.","res":"Order","sm":"Nylic paid a civil penalty of $112,000 to the Kentucky Department of Insurance.","ab":"New York Life Insurance","firms":[107717,169553,173355,309234],"id":903},{"d":"2021-10-20","di":"2021-10-04","dr":"2021-10-20","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":56000.0,"dk":"2021SCM066","al":"On October 4, 2021 New York Life Insurance company (\"NYLIC\") received an order of civil penalty and adoption of a corrective action plan from the Kentucky Department of Insurance alleging that NYLIC incorrectly implemented premium rate increases on 112 individual long term care contracts in violation of Kentucky insurance law.","res":"Stipulation and Consent","sm":"Nylic paid a $56,000 fine on October 20, 2021 in accordance with the order which stipulates 50% of the penalty to be held in abeyance and subject to dismissal following (1) execution and satisfaction of the corrective action plan, and (2) correct implementation of the rate increase.","ab":"New York Life Insurance","firms":[340676],"id":904},{"d":"2021-10-19","di":"2021-09-27","dr":"2021-10-19","k":"Regulatory Action","rg":"Other","reg":"Bank of Portugal","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000.0,"dk":"PROCEEDING NO. 44/20/CO","al":"The Bank of Portugal alleged that three employees at a branch agency of Deutsche Bank AG-portugal branch (\"DB AG portugal\") had not completed required training for managing cash (euro banknotes and coins). The Bank of Portugal further alleged that DB AG portugal thus made euro notes available to the public that were not verified by professionals properly qualified to verify authenticity and quality.","res":"Consent","sm":"On October 19, 2021, DB AG portugal submitted a declaration of acceptance of a decision issued by the Bank of Portugal alleging that three employees at a branch agency of DB AG portugal had not completed required training for managing cash (euro banknotes and coins). The Bank of Portugal further alleged that DB AG portugal thus made euro notes available to the public that were not verified by professionals properly qualified to verify authenticity and quality. Pursuant to the declaration of acceptance, DB AG portugal agreed to a fine of 6,000 euros, which is approximately usd $7,000. The fine was timely paid on October 19, 2021.","ab":"Deutsche Bank AG","firms":[300838],"id":905},{"d":"2021-10-11","di":"2021-10-11","dr":"2021-10-11","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","st":"Final","fine":250000.0,"dk":"2020-01-00098","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to create, maintain, and preserve accurate records of manual customer orders routed to the NYSE American options floor (the \"american options floor\"). The findings stated that the firm failed to accurately make and keep current order memoranda reflecting the price and transmission times for institutional customer orders that it routed to the american options floor. These inaccuracies resulted from the fact that when routing orders to the american options floor, the firm's proprietary order management system transmitted as the price of the orders a snapshot of the market at the time, rather than the actual price at which the firm wanted to trade. Firm traders would then contact NYSE American floor brokers through communication channels (some but not all of which it has retained) with the true price once it had been agreed upon with its institutional customer. However, the firm did not make or keep current order memoranda of these true prices or the time at which it transmitted them to the american options floor for execution. Second, the electronic transmission times recorded by the firm and produced to NYSE regulation were inaccurate. Third, the firm routinely recorded manually received institutional customer options orders as having a price of MKT, for market order, despite the firm having agreed to a specific price with its institutional customer. The firm failed to make or keep current order memoranda reflecting this agreed-upon price. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to ensure compliance with its books and records obligations. Specifically, the firm failed to maintain a reasonably designed supervisory system to ensure the creation and retention of accurate records for manual options orders, including: (I) the prices of orders that it transmitted to the american options floor for execution; (II) the time at which it transmitted orders to the american options floor for execution; and (III) the prices of the orders it received from its institutional customers. The firm failed to remedy the books and records violations noted above despite, among other things, discussions with NYSE regulation identifying potential inaccuracies.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":906},{"d":"2021-10-06","di":"2021-10-06","dr":"2021-10-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":850000.0,"dk":"2016050801702","al":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (the firm) consented to the sanctions and to the entry of findings that it (1) improperly netted the trading activity of five affiliated broker-dealer customers when determining their close-out obligations and claiming pre-fail credit in violation of rule 204 of Regulation SHO and FINRA rule 2010; (2) included securities positions held by the firm's foreign and non-broker-dealer affiliates when calculating the net positions of two independent trading units in violation of rule 200(f) of Regulation SHO; and (3) failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with rule 200(f) of Regulation SHO, in violation of NASD rules 3010 and 2110 and FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm was censured and fined $850,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":907},{"d":"2021-10-04","di":"2021-10-04","dr":"2021-10-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, undertaking","st":"Final","fine":1500000.0,"dk":"2016050801701","al":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (the firm) consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system that was reasonably designed to address short positions in municipal securities and their effects on the customers who hold them in violation of MSRB rule g- 27, failed to take prompt steps to bring short positions in municipal securities within its control within 30 days in violation of Securities Exchange Act of 1934 rule 15C3-3(d)(4) and FINRA rule 2010, and failed to provide its customers with notice clearly identifying their receipt of substitute interest payments and the potential tax liability resulting from the payments in violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm was censured, fined $1,500,000 and agreed to certain undertakings.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":908},{"d":"2021-10-04","di":"2021-09-30","dr":"2021-10-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure","st":"Final","fine":50000.0,"dk":"3-20611","al":"Promissory notes from client loans were not held by registered broker dealer and were not listed on client statements but were only being shown in clients online \"drop box\" folder. Therefore CCO and CIO were not aware of promissory note investments. Since promissory notes were held in \"drop box\" folder, Redwood wealth management per SEC maintained custody of client assets.","res":"Decision & Order of Offer of Settlement","sd":"Redwood wealth management civil penalty of $50000.00 paid 10/2021 benjamin Lincoln civil penalty of $20000.00 paid 10/2021","sm":"In 2019, MR. Lincoln suggested to several clients an investment opportunity with a mortgage firm. Clients would fund an investment in this mortgage firm by being issued promissory notes. Several clients accepted and purchased a total of 30MM in promissory notes. In late 2019 mortgage firm repaid all clients in full. Promissory notes were held at Redwood in each clients folder but not disclosed on client statements. Per SEC, Redwood wealth management maintained custody because promissory notes were held in account files. No information Filed","ab":"Lincoln, Benjamin, Asher","firms":[173916],"id":909},{"d":"2021-09-30","di":"2021-09-30","dr":"2021-09-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":750000.0,"dk":"3-20612","al":"The Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to section 8a of the Securities Act of 1933 (\"Securities Act\"), sections 15(b) and 21c of the Securities Exchange Act of 1934 (\"Exchange Act\"), and sections 203(e) and 203(k) of the Investment Advisers Act of 1940 (\"Advisers Act\") against LPL Financial LLC (\"respondent\" or \"LPL\"). The commission finds that these proceedings arise out of respondent's failure to verify and respond to conflicting information when it opened a customer account and processed wire transfers at the request of eugenio GARCIA jimenez, JR. (\"GARCIA\"). As alleged in the commission's December 1, 2020 complaint against GARCIA, he acted as an unregistered investment adviser and misappropriated $7.1 million of taxpayer funds from the municipio autÓnomo de mayagÜez, Puerto Rico (\"the city\") over the course of seven months in 2016. The city entrusted GARCIA to provide advice and carry out his promised strategy to invest $9 million of city funds such that they had principal protection and 8-10% returns. After misappropriating $4.1 million of the city's funds through an account at brokerage firm 1, GARCIA approached LPL in April 2016 to open an investment account. During its review before opening the account, LPL failed to comply with its customer identification program procedures and, despite various individuals in different departments questioning the account's beneficial ownership, source of funds, and reason for transfer from the brokerage firm 1, GARCIA opened an account controlled by him at LPL in June 2016. LPL subsequently processed wire transfers that GARCIA requested. In the less than one month before LPL froze (and later liquidated) the account, GARCIA was able to misappropriate an additional $3.1 million of city funds. Through certain failures, LPL was a cause of GARCIA's violations of Securities Act sections 17(a)(2) and (3) and Advisers Act section 206(2), which prohibit fraudulent conduct in the offer or sale of securities and upon any client or prospective investment advisory client. Further, LPL willfully violated Exchange Act section 17(a) and rule 17A-8 thereunder, which require broker-dealers to comply with reporting, record keeping and record retention requirements in regulations implemented under the Bank Secrecy Act, including the customer identification program rule (31 C.F.R. § 1023.22, the \"cip rule\").","res":"Order","sm":"Respondent has submitted an offer of settlement, which the commission has determined to accept. Respondent willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder and was a cause of garcia's violations of sections 17(a)(2) and (3) of the Securities Act and section 206(2) of the Advisers Act. Accordingly, it is hereby ordered that the respondent cease and desist from committing or causing any violations, and any future violations, of section 17(a) of the Exchange Act and rule 17A-8 thereunder, sections 17(a)(2) and (3) of the Securities Act, and section 206(2) of the Advisers Act; is censured; and shall pay disgorgement of $114,318, prejudgment interest of $26,884, and a civil money penalty of $750,000 to the commission. LPL has paid $4.1m restitution and have completed everything required.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":910},{"d":"2021-09-27","di":"2021-09-27","dr":"2021-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Fine, undertaking","st":"Final","fine":1000000.0,"dk":"21-15","al":"Alleged violation of section vi.a of the 2017 order, sections 2(a)(13)(g), 4r(a)(3), and 4s(h)(1)(b) of the act, 7 U.S.C. Sections 2(a)(13) (g), 6r(a)(3), 6s(h)(1)(b) (2018), and regulations 23.602(a), 45.3, 45.4, and 45.6, 17 C.F.R. Sections 23.602(a), 45.3, 45.4, 45.6 (2020) in that Citibank, N.A. and Citigroup Global Markets limited failed to report legal entity identifiers properly for certain swaps, failed to satisfy the conditions of available CFTC no-action relief on which they sought to rely, and failed to supervise their swap dealer activities diligently from in or about 2013 to at least September 2020.","res":"Order","sm":"Without admitting or denying the allegations, the firms consented to cease and desist, a civil monetary penalty of $1,000,000 and undertakings to not deny any findings, to cooperate with the commission, to provide corrected swap data, and to make a report to the commission.","ab":"Citibank, N.A.","firms":[7059],"id":911},{"d":"2021-09-27","di":"2021-09-27","dr":"2021-09-27","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Civil asset forfeiture","st":"Final","fine":37337319.9,"al":"The United States attorney's office for the southern district of New York alleged that from 2010 through 2017, Wells Fargo Bank, N.A. defrauded 771 commercial customers who used the bank's FX services by misrepresenting FX pricing levels and engaging in other improper FX pricing practices in violation of the mail fraud, wire fraud, and bank fraud statutes 18 U.S.C. §§ 1341, 1343, 1344.","res":"Settled","sd":"Restitution of $35,337,319.90 was paid to affected consumers.","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":912},{"d":"2021-09-24","di":"2021-09-24","dr":"2021-09-24","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"21-0631","al":"Alleged violation of rule 576 in that Citigroup Global Markets Inc. submitted default operator id's that represented multiple users and failed to maintain accurate and current registration in the exchange fee system and certain operator id's were not registered in efs from January 1, 2021 through March 31, 2021.","res":"Decision","sm":"Firm was issued a summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":913},{"d":"2021-09-21","di":"2021-08-23","dr":"2021-09-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Disgorgement","os":"Cease-and-desist prejudgment interest civil money penalty","st":"Final","fine":97523.0,"dk":"NO. 3-20587","al":"On December 18 2020, Helikon self-reported to the SEC that they sold short american depositary shares (\"adss\" or \"shares\") and then, within the rule's five-day restricted period, purchased adss of the same issuer in an offering, thereby violating rule 105.","res":"Settled","sm":"Closed, disgorgement of profit and minor financial penalty. No information Filed","ab":"Helikon Investments Limited","self":true,"firms":[307662],"id":914},{"d":"2021-09-17","di":"2021-09-17","dr":"2021-09-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut, Department of Banking, Securities and Business Investments Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":20000.0,"dk":"CO-21-202023 S","al":"Commonwealth, through its execution of the consent order, acknowledged the allegation of the commissioner that there were sufficient facts upon which the firm could have been found to have violated SEC. 36B-31-6F(b) of the regulations of the Connecticut state agencies by failing to establish, enforce and maintain a system for supervising the activities of its agents that was reasonably designed to achieve compliance with applicable securities laws and regulations.","res":"Consent","sd":"Monetary fine ($20k) paid prior to order issued and cease and desist","sm":"Cease and desist from engaging in conduct constituting or which would constitute a violation of the act or any regulation, rule or order adopted or issued under the act, either directly or through any person, organization or other device, including without limitation engaging in any activity in or from Connecticut that violates section 36B-31-6F(b) of the regulations and pay a $20,000 administrative fine.","ab":"Commonwealth Equity Services, LLC","self":true,"firms":[8032],"id":915},{"d":"2021-09-17","di":"2021-09-17","dr":"2021-09-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":150000.0,"dk":"3-20568","al":"It is alleged that from 2014-2017, RBC Capital Markets LLC engaged in improper conduct in connection with the allocation, purchase and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules.","res":"Order","sm":"RBC submitted an offer of settlement, which the commission accepted and published on September 17, 2021. The SEC order found that as a result of the negligent conduct and its willful violations of MSRB rules G-11(k), G-17 and G-27, RBC willfully violated section 15b(c)(1) of the Exchange Act. The SEC order found that RBC also caused violations of section 15(a)(1) of the Exchange Act. The SEC ordered that the RBC cease and desist from committing or causing any violations and any future violations of sections 15(a)(1) and 15b(c)(1) of the Exchange Act; is censured; shall pay disgorgement of $552,440, prejudgment interest of $160,886.97 on disgorgement, and a civil money penalty of $150,000 to the commission. The payments were made by RBC on September 22, 2021.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":916},{"d":"2021-09-13","di":"2021-09-13","dr":"2021-09-13","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"RSRH-21-6253","al":"Alleged violation of rule 526 and 526.f in that Citigroup Global Markets Inc. did not report a block trade in a timely manner or with an accurate execution time to the exchange on certain occasions in June 2021.","res":"Decision","sm":"The firm was issued a fine of $2,500","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":917},{"d":"2021-09-08","di":"2021-06-04","dr":"2021-09-08","k":"Regulatory Action","rg":"State regulator","reg":"Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"$10,000 civil penalty","st":"Final","fine":10000.0,"dk":"SEC-2021-00027","al":"The Virginia State Corporation Commission alleged that, from December 1, 2017 through November 27, 2020, RBC employed an investment advisor representative (IAR) who was registered in the District of Columbia but not Virginia and that RBC failed to enforce its written supervisory procedures regarding IAR registration.","res":"Settled","sm":"On September 8, 2021, RBC executed the settlement order which states that RBC neither admits nor denies the Virginia State Corporation Commission's allegations.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":918},{"d":"2021-09-07","di":"2021-09-07","dr":"2021-09-07","k":"Regulatory Action","rg":"OCC","reg":"Office of Comptroller of the Currency (OCC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":250000000.0,"dk":"AA-ENF-2021-29 & AA-ENF-2021-20","al":"Without admitting liability, the bank consented to consent agreements in which the office of the Comptroller of the Currency (OCC) alleged the bank engaged in (1) unsafe or unsound practices related to loss mitigation activities and inadequate independent risk management and internal audit of the loss mitigation and (2) violations covered under the 2018 consent order, AA-EC-2018-15. Wells Fargo Bank, N.A. agreed to pay a civil money penalty of $250,000,000. To the OCC upon acceptance of the consent agreement and within 150 days provide the OCC examiner-in-charge a written acceptable action plan for remedial actions under the agreement.","res":"Other","sm":"N/a","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":919},{"d":"2021-08-31","di":"2021-08-31","dr":"2021-08-31","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"CASE NO. 2020-012","al":"ICE Futures U.S., Inc. (\"IFUS\") alleged that Deutsche bank AG (\"DB AG\") may have violated IFUS rule 4.02(c) on February 28, 2020 by executing a block trade between two accounts that shared the same beneficial owner for the purpose of moving a position from one clearing member to another.","res":"Settled","sm":"On August 31, 2021, DB AG, without admitting or denying the findings contained therein, entered into a settlement agreement with ifus. In the settlement agreement, ifus alleged that DB AG may have violated ifus rule 4.02(c) on February 28, 2020 by executing a block trade between two accounts that shared the same beneficial owner for the purpose of moving a position from one clearing member to another. Pursuant to the settlement agreement, DB AG agreed to a fine of usd $7,500, which was timely paid on September 14, 2021.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":920},{"d":"2021-08-23","di":"2021-08-23","dr":"2021-08-23","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"dk":"20-30222","al":"The Swedish Financial Supervisory Authority (the \"sfsa\") alleged that Redmile Group, LLC (\"Redmile\") failed to notify the sfsa with respect to an increase in the number of shares of an investment held by clients of Redmile within the required time period specified in the Swedish financial instruments trading act.","res":"Order","sd":"Redmile paid an approximately $100,000 (1,000,000 kronor) civil money penalty on or around October 13, 2021.","sm":"The sfsa issued its decision on August 23, 2021, and the decision was final shortly thereafter. The fine was paid by Redmile pursuant to the decision. No information Filed","ab":"Redmile Group, LLC","self":true,"firms":[143606],"id":921},{"d":"2021-08-20","di":"2021-08-20","dr":"2021-08-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":100000.0,"dk":"2014041721501","al":"Pursuant to a letter of acceptance, waiver, and consent (AWC) accepted on August 20, 2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, from July 2009 through September 2015, failed to reasonably communicate allocations to close out fails to introducing brokers, resulting in fail to delivers not being timely closed out and securities not being subject to penalty box requirement; looking at account level basis whether fails were closed out properly; and related written supervisory procedures were not reasonably designed to achieve compliance with close out rules. The AWC found that these practices violated rule 240 of SEC Regulation SHO and FINRA rule 2010 and the supervisory system provisions of NASD rules 3010(a)&(b) and FINRA rule 3110(a)&(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the AWC, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the AWC are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":922},{"d":"2021-08-20","di":"2021-04-16","dr":"2021-08-20","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc. (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"21-CH-2110","al":"On August 20, 2021, the clearing house risk committee (the \"committee\") at the CME Group, Inc. (\"CME\") provided a notice of final decision to J.P. Morgan Securities LLC's (\"JPMS\" or the \"firm\") settlement amount of $50,000 to settle the committee's charge that JPMS violated comex rule 930.E.3 in connection with the CME's 2020 annual examination. The CME's exam included a review of the FCM business, including margin call listing reporting for the financial reporting period as of September 30, 2020. On April 16, 2021, the CME issued its final examination report citing one finding with respect to its review of JPMS's margin call listing records that accurate written records were not maintained for certain performance bond margin calls, based on inconsistencies in JPMS's aged margin call reporting.","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":923},{"d":"2021-08-20","di":"2021-08-10","dr":"2021-08-20","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"RSRH-21-6304","al":"In a notice dated August 10, 2021, the market regulation department of the CME Group Inc. (\"CME\") identified a reporting infraction related to a reduction of open interest of a futures position by Goldman Sachs & Co. LLC (\"GSCO\") in violation of rule 854, concurrent long and short positions.","res":"Decision","sm":"CME imposed a fine in the amount of $2,500, which gsco paid by submission of a wire on August 20, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":924},{"d":"2021-08-19","di":"2021-08-19","dr":"2021-08-19","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Censure","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":100000.0,"dk":"2014041721503","al":"Pursuant to a letter of acceptance, waiver, and consent (AWC) which became final on August 19, 2021, J.P. Morgan Securities LLC (JPMS), on a neither admit nor deny basis, agreed to a settlement resolving findings that JPMS, until September 2015, failed to reasonably communicate allocations to close out fails to introducing brokers, resulting in fail to delivers not being timely closed out and securities not being subject to penalty box requirement; looking at account level basis whether fails were closed out properly; related written supervisory procedures were not reasonably designed to achieve compliance with close out rules. The AWC found that these practices violated rule 240 of SEC Regulation SHO and the supervisory system provisions of NYSE American rule 320.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Solely for the purpose of settling this proceeding, JPMS entered into the AWC, without admitting or denying the findings. The allegations, disposition, findings, and sanctions of the AWC are described in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":925},{"d":"2021-08-18","di":"2021-04-20","dr":"2021-08-18","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":854.55,"dk":"2021/10","al":"Eurex Deutschland intitiated sanction proceedings against Goldman Sachs international (\"GSI\") and a GSI sales trader on April 20, 2021 in relation to four requests for cross in the Eurex product adidas DEC23 without subsequent entry or a corresponding trade or order. Eurex Deutschland alleges that submission of the cross requests was in violation of number 2.6 of the exchange rules of Eurex Deutschland.","res":"Decision","sm":"Eurex Deutschland inititated sanction proceedings against Goldman Sachs international (\"GSI\") on April 20, 2021 and issued a summary fine of euro 1,000 (approximately usd 854.55) to GSI, which was paid by submission of a wire on August 18, 2021.","ab":"Goldman Sachs","firms":[361],"id":926},{"d":"2021-08-18","di":"2018-01-18","dr":"2021-08-18","k":"Regulatory Action","rg":"Other","reg":"Foreign - Finansinspektion (The Swedish Financial Supervisory Authority)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":80436.0,"dk":"FI REF. NO. 18-3251","al":"Pursuant to regulation (EU) no. 236/2012 on short selling (the \"regulation\"), Jupiter Investment management limited (\"JIML\") is required to file net short position reports (the \"reports\") with finansinspektionen (the swedish financial supervisory authority) (\"swedish FSA\") when certain prescribed thresholds are crossed. In November 2017, the compliance function of merian global investors (UK) limited (\"MGI\"), now known as JIML, identified an error in the monitoring of such thresholds. MGI immediately commenced an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. On January 18 2018, MGI notified the swedish FSA of its inadvertent failure to file the reports during the period between April 2016 and January 2018. MGI filed the delinquent reports and put appropriate controls in place to mitigate the risk of the error reoccurring. The swedish FSA subsequently found that MGI breached the regulation by failing to file such reports.","res":"Consent","sd":"See details in number 13 below","sm":"\"On June 24, 2021, the swedish FSA determined that mgi breached the regulation and issued a penalty fee of sek 700,000 (approximately $80,436). Jupiter Investment management limited paid the penalty fee to finansinspektionen on August 18 2021.\"","ab":"Jupiter Investment","firms":[306863],"id":927},{"d":"2021-08-17","di":"2021-08-17","dr":"2021-08-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement and civil and administrative penalties and fines","st":"Final","fine":8978183.0,"dk":"FILE NO. 3-20463","al":"Per the allegations set forth in the SEC's order, which the respondents neither admitted nor denied,from June 2016 through October 2017, the respondents erroneously provided order-marking information on sale orders of their client to brokers, causing those brokers to mismark these sales as \"long.\" The order finds that in providing the inaccurate information, the respondents also caused the brokers to fail to borrow or locate shares prior to executing the sales. The order further finds that Murchinson and bistricer caused the fund to engage in dealer activity without registering with the SEC or being exempt from registration.","res":"Decision & Order of Offer of Settlement","sm":"The action is final. The respondents agreed to pay the indicated civil money penalties and agreed to disgorgement. The respondents agreed to cease and desist from violating the specified rules of Regulation SHO and section 15(a)(1) of the Exchange Act and well as to commit the the undertaking set forth above. No information Filed","ab":"Zogala, Paul, Edward Otakar","firms":[310138],"id":928},{"d":"2021-08-16","di":"2021-08-16","dr":"2021-08-16","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; undertaking","st":"Final","fine":400000.0,"dk":"R-2019-0040","al":"The Massachusetts Securities Division (MSD) alleged that Morgan Stanley Smith Barney LLC (the \"firm\") (1) employed certain agents who were required to be registered in Massachusetts but were not registered in Massachusetts in violation of section 201 of the Massachusetts uniform Securities Act (the act), (2) failed reasonably to supervise the registration status of certain agents in Massachusetts, and (3) failed to supervise certain publicly available websites regarding the Massachusetts registration status of certain agents who were not registered in Massachusetts in violation of section 204(a)(2)(j) of the act.","res":"Order","sm":"On August 16, 2021, the firm became the subject of a consent order issued by the MSD regarding allegations that the firm (1) employed certain agents who were required to be registered in Massachusetts but were not registered in Massachusetts in violation of section 201 of the act, (2) failed reasonably to supervise the registration status of certain agents in Massachusetts, and (3) failed to supervise certain publicly available websites regarding the Massachusetts registration status of certain agents who were not registered in Massachusetts in violation of section 204(a)(2)(j) of the act. Without admitting or denying the statement of facts and the violations of law and without adjudication of any issue of law or fact, the firm consented to (1) the entry of the order, (2) cease and desist from violating mass. Gen. Laws CH. 110a §§ 201(a), 201(b) and 204(a)(2) (j), (3) the imposition of a censure, (4) certain undertakings, and (5) the payment of an administrative fine in the amount of $400,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":929},{"d":"2021-08-09","di":"2021-07-22","dr":"2021-08-09","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1830000.0,"dk":"WA 17-WP 3120-2020/0011","al":"Negligent breach of supervisory and organizational duties in connection with infringements of section 21 of the german securities trading act.","res":"Order","sm":"An administrative fine of 1,830,000 euros is imposed pursuant to section 30 (1) no. 1, (4) sentence 1 of the german act on breaches of administrative regulations, on the grounds of a negligent breach of supervisory and organizational duties in connection with infringements of section 21 of the german securities trading act relating to the filing of voting rights notifications.","ab":"JPMorgan Chase & Co; JPMorgan Chase & Co.","firms":[79,20989,134776,135960],"id":930},{"d":"2021-08-05","di":"2021-08-05","dr":"2021-08-05","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Office of the Secretary of State - Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":50000.0,"dk":"INV20-096","al":"The Nevada securities division alleged that Edward jones failed to supervise a former financial advisor who had offered and sold personal seat licenses (\"PSLS\") to an Edward jones client in violation of Nevada revised statutes 90.420. The division also alleged that the former financial advisor never delivered the PSLS to the client.","res":"Consent","sm":"On August 5, 2021, an administrative consent order (the \"order\") was entered by the securities administrator of the state of Nevada against Edward jones (\"Edward jones\" or \"the firm\"). Edward jones consented to the order without either admitting or denying the allegations set forth in the order. The order alleged that Edward jones failed to supervise a former financial advisor who had offered and sold personal seat licenses (the \"PSLS\") to an Edward jones client without disclosing such activity to the firm. The order also alleged that the former financial advisor never delivered the PSLS to the client. The order also stated that when Edward jones became aware that the former financial advisor engaged in this activity, the firm immediately terminated the financial advisor. The firm subsequently made the client whole, inclusive of interest. The order requires Edward jones to cease violating, and to comply with, the Nevada Securities Act. Additionally, Edward jones agreed to pay to the Nevada secretary of state's office $50,000.00 and $2,762.57 as a civil penalty and investigatory costs, respectively. Such payments were mailed to the secretary of state's office on or about August 9, 2021, pursuant to the terms of the order.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":931},{"d":"2021-08-02","di":"2021-07-21","dr":"2021-08-02","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"NO. 2019-07-00074","al":"The New York Stock Exchange LLC (\"NYSE\") alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) and Bofa Securities, Inc. (BOFAS) (1) routed two competing parent orders on behalf of two different portfolios managed by the same advisor to two different floor broker firms, resulting in executions at the same time and price of orders on behalf of the same customers by two floor brokers in violation (unintentionally) of NYSE rule 122, and (2) failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to achieve compliance with NYSE rule 122 in violation of NYSE rule 3110(a) and (b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPFS and bofas agreed to the imposition of a censure and fine in the amount of $25,000, allocated jointly and severally between MLPFS and bofas. The fine was paid in accordance with the terms of the AWC.","ab":"Bofa Securities, Inc.","firms":[7691],"id":932},{"d":"2021-08-02","di":"2018-01-18","dr":"2021-08-02","k":"Regulatory Action","rg":"Department of Justice","reg":"U.S. Department of Justice (DOJ)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":101500000.0,"dk":"CASE1:18 CR 00030 LDH","al":"In January 2018, following the conclusion of the US Department of Justice's (DOJ) investigation into HSBC's historical foreign exchange activities, HSBC Holdings entered into a three-year deferred prosecution agreement with the criminal division of the DOJ (the FX dpa), regarding fraudulent conduct in connection with two particular transactions in 2010 and 2011. In January 2021, the FX dpa expired and, in August 2021, the charges deferred by the FX dpa were dismissed.","res":"Consent","ab":"HSBC Holdings PLC","firms":[154700,172522,324468],"id":933},{"d":"2021-07-28","di":"2021-07-14","dr":"2021-07-28","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"RSRH-21-6265","al":"On July 14, 2021, the market regulation department of the CME Group Inc. (\"CME\") determined that Goldman Sachs & Co. LLC (\"GSCO\") violated CME rule 561 for late adjustments to large trader reporting of listed futures positions in June 2021.","res":"Decision","sm":"CME imposed a fine in the amount of $1,500, which gsco paid by submission of a wire on July 28, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":934},{"d":"2021-07-28","di":"2021-01-22","dr":"2021-07-28","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement","st":"Final","fine":119605.6,"dk":"CBOT 19-1230-BC","al":"The CME concluded that BlackRock violated Chicago Board of Trade (CBOT) rule 562, which prohibits firms from holding positions on the CME larger than the limits proscribed by CME rules.","res":"Settled","sd":"In accordance with the settlement offer, the panel ordered BlackRock to pay a fine in the amount of $20,000 and ordered disgorgement in the amount of $99,605.60 which BlackRock paid on July 29TH, 2021.","sm":"Pursuant to an offer of settlement in which BlackRock inc. neither admitted nor denied the rule violation upon which the penalty is based, on July 26, 2021, a PANEL of the Chicago Board of Trade (\"CBOT\") business conduct committee (\"PANEL\") found that on November 12, 2019, and November 13, 2019, BlackRock-managed accounts held an all months combined CBOT soybean meal position that exceeded the all months position limit on an end of day and intraday basis. Specifically, BlackRock- managed accounts held an aggregate position of 6,919 contracts long on November 12, and 6,920 contracts long on November 13, 2019. This exceeded the all months combined position limit for soybean meal by 419 contracts, or 6.45%, on November 12, and by 420 contracts, or 6.46%, on November 13. BlackRock recognized the overage on November 13, and attempted to reduce its position via an exchange for risk (\"EFR\") transaction, but was unable to execute the trade on that day. However, on the morning of November 14, 2019, BlackRock executed the EFR and brought the accounts' positions into compliance, which resulted in a total monetary benefit of $99,605.60 to the accounts. The PANEL concluded that BlackRock thereby violated CBOT rule 562. In accordance with the settlement offer, the PANEL ordered BlackRock to pay a fine in the amount of $20,000 and ordered disgorgement in the amount of $99,605.60 which BlackRock paid on July 29TH, 2021.","ab":"BlackRock, Inc.","firms":[106614,107105,282125,290336],"id":935},{"d":"2021-07-26","di":"2021-07-26","dr":"2021-07-26","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"dk":"NYMEX 20-1311-BC","al":"A panel of the NYMEX business conduct committee (\"BCC panel\") found that on multiple occasions during March 2020, RBC submitted block trades in crude oil and natural gas futures to the exchange outside the reporting time requirements, submitted inaccurate block trade execution times to the exchange on one or more occasion, and also failed to properly advise and train its brokers as to relevant exchange rules and market regulation advisory notices (\"MRANS\") in a manner sufficient to ensure compliance with the exchange's block trade reporting rules.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":936},{"d":"2021-07-22","di":"2021-06-01","dr":"2021-07-22","k":"Regulatory Action","rg":"Other","reg":"Comissao de Valores Mobiliarios (CVM)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1454941.55,"dk":"19957.000791/2020-59","al":"Goldman Sachs Do Brasil banco multiplo S.A. (\"GS brazil\"), Goldman Sachs international (\"GSI\"), and daniel motta camargo silva, a director of the trading desk (FICC) of GS brazil, submitted a settlement proposal that was accepted by the Comissao de valores mobiliarios (\"CVM\") board of commissioners. The settlement resolved allegations that between January 1, 2018 and December 31, 2019, GSI and GS brazil created artificial conditions of demand, offer, or price by crossing in the brazilian exchange di x US dollar spread futures in violation of CVM instruction n. 08/79.","res":"Settled","sm":"Without admitting or denying the allegations, GS brazil, gsi, and MR. silva entered into a settlement agreement on July 22, 2021 with the CVM for a total amount of brazilian reais 7,480,000 (approximately usd 1,454,941.55), which was paid by a wire submission on August 5, 2021.","ab":"Goldman Sachs Do Brasil","firms":[361],"id":937},{"d":"2021-07-15","di":"2021-06-24","dr":"2021-07-15","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen (Swedish Financial Services Regulator)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":236000.0,"dk":"18-23325","al":"Following a self-initiated internal review in October 2018, Squarepoint identified issues with its european short sale notification calculations and processes. As the process was centralized to satisfy all european jurisdictions, this impacted historical notifications, at that point in time, to a number of european regulatory authorities, including the swedish Finansinspektionen. In November, 2018, Squarepoint voluntarily contacted the swedish fi to notify them of the issues and to correct historical records. The identified errors affecting swedish issuers were corrected by January 2019.","res":"Acceptance, Waiver & Consent(AWC)","sd":"On 24TH June 2021 the swedish fi issued a notice of determination and imposition of a penalty fee of SEK2,000,000 to Squarepoint for the reporting failures. This penalty fee included reductions to take into account, amongst other items, the fact that Squarepoint self reported these issues and the time taken by the fi to come to the determintation.","sm":"Historical notifications were corrected and actions taken to mitigate re-occurance and after issuing a notice of determination and imposition of a penalty fee, no further action was necessary. No information Filed","ab":"Squarepoint Ops LLC","self":true,"firms":[172116],"id":938},{"d":"2021-07-12","di":"2021-07-12","dr":"2021-07-12","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500000.0,"dk":"2021-CFPB-0004","al":"On July 12, 2021, the Consumer Financial Protection Bureau (\"CFPB\") entered a consent order against Greensky LLC (\"Greensky\") after determining Greensky violated sections 1031(a) and 1036(a)(1)(b) of the Consumer financial protection act. From March 2014 through July 2021, the CFPB identified multiple instances of Greensky engaging in unfair acts and practices with regard to loans to consumers who did not authorize them and by structuring its loan origination and servicing activities in a manner that enabled unauthorized loans.","res":"Order","sm":"Without admitting or denying any of the findings of fact or conclusions, Greensky agreed to the issuance of the consent order which will terminate five years after the effective date of July 12, 2021, barring any further violations. Greensky is to pay redress to consumers identified by the consent order as being impacted by the violations in a total amount to not be less than $750,000 and to not exceed $3,000,000, and loan cancellations in an amount no more than $6,000,000. In addition, a civil penalty of $2,5000,000 was ordered to be paid to the CFPB. Greensky was ordered to implement additional compliance measures to prevent further violations including the establishment of a compliance committee to be responsible for monitoring and coordinating Greensky's adherence to the provisions of the consent order for the effective time period.","ab":"Greensky, LLC","firms":[361],"id":939},{"d":"2021-07-07","di":"2019-05-09","dr":"2021-07-07","k":"Civil Judicial Action","san":"Other","os":"Annulment of sanction","st":"Final","fine":174034.0,"al":"The spanish national securities markets commission (the \"CNMV\") determined that Renaissance had entered into trades on behalf of funds that it manages in violation of a spanish short selling ban on the securities of liberbank in 2017. Renaissance reduced long positions in liberbank after the short selling ban had taken effect. Renaissance appealed this decision, on the grounds that the CNMV had improperly broadened the scope of the spanish regulation and of the ban beyond their intent and plain language in sanctioning Renaissance given that Renaissance did not engage in any short sale transaction.","res":"Judgment Rendered","sd":"Renaissance paid the spanish national securities markets commission a fine equal to 150,000 euros on June 26, 2019. (The monetary fine in 13(a) was converted into U.S. dollars using the exchange rate on the date of payment.)","ab":"Renaissance Technologies LLC","self":true,"firms":[106661],"id":940},{"d":"2021-07-06","di":"2021-06-23","dr":"2021-07-06","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":10000.0,"dk":"2020-04-00115","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it violated NYSE rule 3110(a) and (b) (supervision) by failing to establish and maintain a supervisory system and written supervisory procedures reasonably designed to detect and prevent errors in market on close (MOC) orders. The findings stated that on April 24, 2020, the firm entered a MOC basket order on behalf of its U.S. broker-dealer affiliate that mistakenly included approximately 300,000 shares across 476 exchange traded fund (ETF) component securities. The firm's affiliate broker-dealer utilizes the firm's NYSE membership and connectivity in order to gain access to the NYSE exchange. In connection with their ETF market making responsibilities, traders at the firm's affiliate may route MOC basket orders to hedge their existing exposure. On the review date, a trader mistakenly included an ETF that the firm did not need to hedge against when manually adding components into an excel macro script that is used to identify all underlying component securities that needed to be entered for that day's order. As a result, the firm routed to the NYSE a basket containing incorrect ETF component securities which the firm did not intend to execute during the closing auction. The desk responsible for generating the MOC basket did not recognize that the ETF component securities were erroneously included before entering the order and routing it to market. After the 3:50 PM cut-off time specified in NYSE rule 7.35b, but prior to the closing cross, the desk recognized its error and cancelled the basket. The firm failed to detect and prevent the error in the underlying MOC basket. Although the firm had the ability to review the components input into the firm's excel script and the generated MOC basket for errors before releasing it to market, they nonetheless were not able to catch this error in time, and there was no other check in place to alert the firm to the manual error. The firm also failed to maintain updated written supervisory procedures (WSPS) that accurately reflected the appropriate cut-off time of 3:50 PM for the cancellation of MOC orders; instead, the firm's WSPS reflected an outdated cut-off time of 3:45 PM. In addition, the firm failed to enable appropriate risk management controls to ensure against improper MOC order cancellations after the prescribed cut-off time. During the firm's migration to NYSE's pillar platform, its soft warning and hard block functionalities, which would alert the firm to potentially improper MOC order cancellations, became disabled for more than six months. Further, the firm failed to detect errors in its surveillance system that prevented the firm from being alerted to MOC orders canceled after the applicable cut-off time. Due to errors in an overlay file used to generate alerts for the firm's surveillance of MOC orders canceled after the applicable cut-off time, which was caused by an internal system update in October 2018, the firm's surveillance system was unable to generate alerts for potentially improper MOC cancellations until the error was discovered and corrected in July 2020, and the cancellation of the MOC basket was not identified as a potential exception for further review by supervision during the firm's t+1 review process.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":941},{"d":"2021-06-29","di":"2020-12-01","dr":"2021-06-29","k":"Regulatory Action","rg":"Other","reg":"Fsma (Belgium)","san":"Other","os":"No sanction - transactional agreement","st":"Final","al":"In October 2020, Belfius Bank initiated an advertising campaign concerning a compartment of an undertaking for collective investment (UCI) in belgium which had not been submitted to the belgian financial services and markets authority for prior approval as required by regulatory requirements in belgium (law of 3/08/2012 and ar 25/04/2014). According to the Fsma, the advertising campaign of Belfius Bank related to the cure compartment of the Belfius equities opc did not constitute a \"brand awareness advertising\"\", and therefore the Fsma was of the opinion that Belfius Bank did not comply with the information obligations (law of 3/08/2012 and ar 25/04/2014) when selling financial products to retail clients. A settlement has been concluded between Belfius Bank and the Fsma on 29 June 2021. The settlement agreement stipulates the payment of an amount of 300,000 euros, as well as the nominative publication of the settlement document on the website of the Fsma.","res":"Settled","sd":"No sanction - transactional agreement","ab":"Belfius Bank","firms":[173355,340676],"id":942},{"d":"2021-06-25","di":"2021-06-25","dr":"2021-06-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution, censure","st":"Final","fine":3250000.0,"dk":"2017053437701","al":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (the firm) consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with FINRA's suitability rule as it pertains to early rollovers of unit investment trusts, in violation of NASD rule 3010 (for conduct before December 1, 2014), FINRA rule 3110 (for conduct on or after December 1, 2014) and FINRA rule 2010. The firm has since enhanced its controls relevant to the uit business, including by implementing new automated reports to identify patterns of uit liquidations prior to maturity and by prohibiting early series to series rollovers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm was censured and fined $3,250,000 and ordered to pay $8,437,233.38, plus interest, in restitution to customers. The fine was paid on or around July 1, 2021.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":943},{"d":"2021-06-25","di":"2021-06-25","dr":"2021-06-25","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"CASE NO. 2021-1","al":"Bloomberg SEF LLC (\"BSEF\") alleged that Deutsche Bank AG (\"Dbag\") executed offsetting and correcting trades for a January 21, 2021 trade after the permitted timeframe of three business days and failed to use appropriate offsetting terms as required under BSEF rules.","res":"Decision","sm":"On June 25, 2021, DB AG, without admitting or denying the findings contained therein, entered into a written decision with BSEF. In the written decision, BSEF alleged that DB AG executed offsetting and correcting trades for a January 21, 2021 trade after the permitted timeframe of three business days and failed to use appropriate offsetting terms as required under BSEF rules. Pursuant to the written decision, DB AG agreed to a fine of usd $7,500, which was timely paid on 7/15/2021.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":944},{"d":"2021-06-18","di":"2021-06-18","dr":"2021-06-18","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet: the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":23000.0,"dk":"21/2955","al":"On June 18, 2021, Kayne Anderson Rudnick Investment Management, LLC (\"KAR\") received notice from norway's financial regulator, the financial supervisory authority of norway (\"finanstilsynet\"), that the regulator had levied a penalty against KAR equivalent to approximately $23,000 usd based on a finding that a notification of large share ownership in a norwegian company was not made in a timely manner under norwegian law.","res":"Decision","ab":"Kayne Anderson Rudnick Investment Management, LLC","self":true,"firms":[104599],"id":945},{"d":"2021-06-18","di":"2019-03-17","dr":"2021-06-18","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"18/8988","al":"Connor, clark & lunn investment management LTD. (\"CC&l\") failed to report a short position in astek a/s within the required time period. The reporting was due on March 19, 2018 and was submitted by CC&l's third party service provider on March 22, 2018. The delay was the result of the service provider having incorrect shares outstanding information combined with time zone differences between CC&l (CANADA), the regulator (FINLAND) and the service provider (AUSTRALIA).","res":"Decision","sm":"By a decision made on March 7, 2019, Finanstilsynet has decided that Connor, clark & lunn investment management LTD. shall pay a penalty fee of nok 20 000. The appeal period for the penalty fee expired on March 28, 2019; an invoice for the penalty fee has been received and paid.","ab":"Connor Clark & Lunn Investment Management Ltd","self":true,"firms":[107557],"id":946},{"d":"2021-06-18","di":"2021-02-24","dr":"2021-06-18","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"20/11180","al":"Connor, clark & lunn investment management LTD. (\"CC&l\") failed to report short positions within the required time period on five occassions between July 2019 and April 2020. On one occassion, CC&l did not cancel a filing that was made in error (incorrect year). The issue was identified by CC&l and the correct filing was submitted on time. On the other occassions, the filings were submitted between 7 minutes and 1 business day late. The delays were either the result of the service provider having incorrect shares outstanding information or due to processing delays.","res":"Decision","sm":"By a decision made on February 24, 2021, Finanstilsynet has decided that Connor, clark & lunn investment management LTD. shall pay a penalty fee of nok 40 000. The appeal period for the penalty fee expired on March 17, 2021; an invoice for the penalty fee has been received and paid. No information Filed","ab":"Connor Clark & Lunn Investment Management Ltd","self":true,"firms":[107557],"id":947},{"d":"2021-06-18","di":"2021-06-02","dr":"2021-06-18","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"DQA-21-0626","al":"The CME Group alleged that Deutsche Bank AG's (\"DB AG\") electronic audit trail relating to electronic order routing for front- end systems failed to meet a CME Group requirement to maintain a complete electronic audit trail for a minimum of five years. The CME Group acknowledged that DB AG subsequently applied new measures to its recordkeeping processes to ensure compliance with the relevant requirement.","res":"Decision","sm":"On June 18, 2021, DB AG agreed to the entry of a summary fine notice by the CME Group. In the summary fine notice, the CME Group alleged that DB AG's electronic audit trail relating to electronic order routing for front-end systems failed to meet a CME Group requirement to maintain a complete electronic audit trail for a minimum of five years. The CME Group acknowledged that DB AG subsequently applied new measures to its recordkeeping processes to ensure compliance with the relevant requirement. Pursuant to the summary fine notice, DB AG agreed to a fine of usd $1,000, the fine will be paid.","ab":"Deutsche Bank AG","firms":[300838],"id":948},{"d":"2021-06-16","di":"2021-02-24","dr":"2021-06-16","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet - the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":41939.27,"dk":"20/4962","al":"On February 24, 2021, Finanstilsynet, the financial supervisory authority of norway concluded that Goldman Sachs group, inc., Goldman Sachs international, and Goldman Sachs & co. LLC violated the notification requirement under section 3-14 of the norwegian securities trading act, CF. Regulation (EU) no 236/2012 (\"SSR\") article 5, CF. Article 9, by not notifying Finanstilsynet of net short positions within the time limit laid in accordance with SSR.","res":"Decision","sd":"On February 24, 2021, Finanstilsynet imposed a violation penalty of nok 350,000(approximately usd 41,939.27). The fine was paid in full by wire submission on June 16, 2021.","sm":"On February 24, 2021, Finanstilsynet imposed a violation penalty of nok 350,000 (approximately usd 41,939.27). The fine was paid in full by wire submission on June 16, 2021.","ab":"Goldmans Sachs Group,","firms":[283221,286067],"id":949},{"d":"2021-06-15","di":"2021-02-24","dr":"2021-06-15","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet, the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":41939.27,"dk":"20/4962","al":"On February 24, 2021, Finanstilsynet, the Financial Supervisory Authority of Norway concluded that Goldman Sachs Group, Inc., Goldman Sachs international, and Goldman Sachs & Co. LLC violated the notification requirement under section 3-14 of the norwegian securities trading act, CF. Regulation (EU) no 236/2012 (\"SSR\") article 5, CF. Article 9, by not notifying Finanstilsynet of net short positions within the time limit laid in accordance with SSR.","res":"Decision","sm":"On February 24, 2021, Finanstilsynet imposed a violation penalty of nok 350,000 (approximately usd 41,939.27). The fine was paid in full by wire submission on June 15, 2021.","ab":"Goldman Sachs Group, Inc.","firms":[361],"id":950},{"d":"2021-06-15","di":"2021-06-15","dr":"2021-06-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":350000.0,"dk":"2019064316401","al":"Alleged violation of FINRA rules 3110(a), 3110(b), 3110(d), and 2010 in that Citigroup Global Markets Inc. failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to monitor its employees' outside brokerage accounts during the period from at least June 2017 to February 2019.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine of $350,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":951},{"d":"2021-06-04","di":"2021-06-04","dr":"2021-06-04","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance (Efd)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":33000.0,"dk":"442.2-358","al":"The Swiss federal department of finance (the \"Swiss efd\") found that Deutsche Bank AG (\"DB AG\") failed to make timely reports to the SIX Swiss exchange (\"SIX\") when DB AG's holdings of two SIX-listed companies had fallen below the threshold requiring notification to the SIX within four trading days. In addition, the Swiss efd found that DB AG failed to correct inaccurate disclosure reports relating to its holdings in another SIX-listed company.","res":"Order","sm":"On June 4, 2021, the Swiss efd entered an order (the \"order\") finding that DB AG failed to make timely reports to the SIX Swiss exchange (\"SIX\") when DB AG's holdings of two SIX-listed companies had fallen below the threshold requiring notification to the SIX within four trading days. In addition, the Swiss efd found that DB AG failed to correct inaccurate disclosure reports relating to its holdings in another SIX-listed company. The Swiss efd imposed a fine of thirty thousand Swiss francs, which is approximately usd $33,000, which will be timely paid.","ab":"Deutsche Bank AG (\"DB AG\")","firms":[300838],"id":952},{"d":"2021-06-03","di":"2021-05-26","dr":"2021-06-03","k":"Regulatory Action","rg":"Other","reg":"ICE Futures Europe","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14436.56,"dk":"16622","al":"In a notice dated May 26, 2021, ICE Futures Europe (\"ICE\") found that Goldman Sachs & Co. LLC (\"GSCO\") violated ICE rule P.3 because a GSCO client held a position over the position limit in February 2021 wti crude futures at the close of business on January 14, 2021, without an exemption.","res":"Decision","sm":"ICE issued a summary fine of euro 17,500 to gsco, which was paid on June 3, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":953},{"d":"2021-05-31","di":"2020-07-30","dr":"2021-05-31","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority (\"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":309595.0,"dk":"WA 17-WP 3120-2020/0003; WA 17-WP 3120-2020/0004","al":"Invesco Ltd and aim international mutual funds failed to submit voting rights notifications to BAFIN and the issuers by the required deadline. BAFIN issued a notice of hearing on July 30, 2020 to Invesco Ltd. alleging that violations of the voting rights requirements occured on 26 occassions relating to the voting rights notifications of Invesco Ltd and on 28 occasions relating to voting rights notifications of aim international mutual funds.","res":"Decision","sd":"Decision to impose a fine of 260,000 euros (approximately $309,595 usd) against Invesco Ltd will be paid by the July 2, 2021 deadline.","sm":"BAFIN imposed a fine of 260,000 euros (approximately $309,595 US dollars) against Invesco Ltd for 54 incorrect threshold filings between 05/2019 and 10/2019. The fine will be paid by the July 2, 2021 deadline.","ab":"Invesco Ltd; Invesco Ltd.","firms":[104983,105360,107584,141854],"id":954},{"d":"2021-05-27","di":"2021-05-27","dr":"2021-05-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"2016049001401","al":"Goldman Sachs & Co. LLC (\"GSCO\") submitted a letter of acceptance, waiver and consent (\"AWC\") that was accepted by the Financial Industry Regulatory Authority (\"FINRA\") and became final on May 27, 2021. The AWC resolved alleged violations of FINRA rules 7230a(g)(2), 7330(g)(2), and 2010 during various time periods between January 2015 and June 2019. The AWC states that GSCO failed to report timely or over-reported certain transactions to the FINRA/Nasdaq trade reporting facility and OTC reporting facility.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On May 27, 2021, without admitting or denying the allegations or findings in the AWC, gsco consented to a censure and a fine in the amount of $50,000. Gsco paid the fine by wire submission on July 7, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":955},{"d":"2021-05-26","di":"2021-05-26","dr":"2021-05-26","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet, the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","al":"Notification that Charles Schwab Investment Management, Inc.'s (\"CSIM\") holdings exceeded 5% of the share capital of the norwegian traded company seadrill limited (SDRL) was submitted late. Notification that CSIM's holdings went below 5% of the share capital of the norwegian traded company seadrill limited (SDRL) also was submitted late.","res":"Decision","sd":"Violation penalty of 150,000 nok imposed.","sm":"Violation charge incurred due to late disclosure notifications. No information Filed","ab":"Charles Schwab Investment Management, Inc","self":true,"firms":[106753],"id":956},{"d":"2021-05-20","di":"2021-04-26","dr":"2021-05-20","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"21-0605","al":"On May 19, 2021, the market regulation department of the CME Group Inc. (\"CME\") determined that Goldman Sachs & Co. LLC (\"GSCO\") trade data reviewed during its audit of trade dates December 2, 2020 through January 29, 2021 reflected a computerized trade reconstruction error rate in excess of the applicable 10% threshold levels, set forth in CME rule 536.f.","res":"Decision","sm":"CME imposed a fine in the amount of $2,500, which gsco paid by submission of a wire on May 20, 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":957},{"d":"2021-05-18","di":"2021-04-14","dr":"2021-05-18","k":"Regulatory Action","rg":"Other","reg":"Republic of the Philippines Anti-Money Laundering Council","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":21000.0,"dk":"AMLC ADMIN. CASE NO. 18-024","al":"The philippines anti-money laundering council (\"AMLC\") alleged that Deutsche bank AG (\"DB AG\"), manila branch failed to report all covered transactions to the AMLC within five working days, as required under the philippines anti-money laundering act of 2001, as amended. In particular, the AMLC alleged that 2,069 covered transaction reports were filed beyond the five-day period during the first semester of 2017. The AMLC found that DB AG showed \"good cause\" in adequately remediating AML system issues, including the covered transaction reports at issue. Accordingly, the AMLC agreed to withdraw the case upon receipt of an assessment payment and confirmation of DB AG's remedial measures.","res":"Order","sm":"On May 18, 2021, the amlc approved a resolution (the \"resolution\") in connection with DB AG, manila branch's alleged failure to report all covered transactions to the amlc within five working days, as required under the philippines anti-money laundering act of 2001, as amended. In particular, the amlc alleged that 2,069 covered transaction reports were filed beyond the five-day period during the first semester of 2017. The amlc found that DB AG showed \"good cause\" in adequately remediating AML system issues, including the covered transaction reports at issue. Accordingly, the amlc agreed to withdraw the case upon receipt of an assessment payment and confirmation of DB AG's remedial measures. The amlc imposed an assessment of one million philippine pesos, which is approximately usd $21,000, which was timely paid on May 24, 2021.","ab":"Deutsche Bank AG (Manila","firms":[300838],"id":958},{"d":"2021-05-17","di":"2021-04-22","dr":"2021-05-17","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen (Swedish Financial Supervisory Authority)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":120457.0,"dk":"FI REF. NO. 17-20166","al":"The swedish financial supervisory authority alleged that Renaissance Technologies LLC (\"Renaissance\") had not timely filed notifications regarding net short positions held by Renaissance-managed funds in a swedish listed security.","res":"Decision","sd":"The swedish financial supervisory authority imposed a sek 1,000,000 fine, which was paid by Renaissance in U.S. dollars on May 17, 2021. The amount of the fine in item 12(a) above (usd 120,457) is stated in U.S. dollars using the exchange rate on the date of payment.","sm":"In September 2017, Renaissance self-reported to the swedish financial supervisory authority that on multiple occasions in 2016 and 2017, it had failed to timely file notifications with respect to net short positions held by Renaissance-managed funds in a specific swedish listed security (\"short notifications\"). The failure was due to a coding error related to an ambiguity as to whether transactions in that particular security were exempt from reporting following a corporate transaction by the issuer. Renaissance detected the error in connection with a routine review and corrected it. On April 22, 2021, the swedish financial supervisory authority determined that Renaissance had not timely filed the short notifications and imposed a fine of sek 1,000,000 (usd 120,457). Renaissance paid the fine on May 17, 2021.","ab":"Renaissance Technologies LLC","self":true,"firms":[106661],"id":959},{"d":"2021-05-06","di":"2021-04-16","dr":"2021-05-06","k":"Regulatory Action","rg":"Other","reg":"California Department of Financial Protection and Innovation","san":"Revocation","st":"Final","fine":14500.0,"dk":"CFL # 60DBO-65349","al":"As a result of an acquisition transaction that occurred on December 23, 2020, the control and management of SVB Innovation Credit fund VIII, L.P. (\"fund VIII\") was changed to a new (and current) general partner, SVB Innovation Credit partners VIII, LLC. note that, upon the change of control, notice to the California Department of Financial Protection and Innovation (DFPI) was initiated to change fund VIII's address, name, contact information, and other management information. These changes were approved by the DFPI on or about June 4, 2021. Unfortunately, fund VIII inadvertently missed the deadline to file its annual report with the DFPI by March 15, 2021, as required by California financial code 22159. This was partially due to fund VIII not receiving notices sent by the DFPI to CFL licensees between December 2020 and March 2021 since the DFPI had not yet completed the process to change fund VIII's contact and other information as mentioned above. On April 16, 2021, the DFPI commissioner issued an order summarily revoking California finance lenders license pursuant to financial code section 22715 for CFL license number 60dbo- 65349 (\"summary revocation order\"). On April 29, 2021, fund VIII became aware of the summary revocation order, and on April 30, 2021, fund VIII submitted its annual report to the DFPI. On May 6, 2021, the DFPI commissioner and fund VIII entered into a consent order that rescinded the summary revocation order thereby reinstating fund VIII's CFL license. Fund VIII is currently managed by the investment adviser.","res":"Order","sd":"Monetary penalty in the amount of $14,500 paid on May 12, 2021.","sm":"The consent order constituted a full and final resolution of the issue. No further proceedings or actions are ongoing.","ab":"SVB Innovation Credit","firms":[326747],"id":960},{"d":"2021-04-28","di":"2018-12-20","dr":"2021-04-28","k":"Regulatory Action","rg":"Other","reg":"European Commission","san":"Cease and Desist","st":"Final","dk":"AT.40346","al":"The European Commission (\"commission\") found that Deutsche Bank AG, DB group services (UK) limited, and Deutsche securities inc. (together, \"DB\") and three other banks took part in anticompetitive conduct relating to the secondary trading market within the European economic area of supra-sovereign, sovereign and agency (\"SSA\") bonds denominated in U.S. dollars. In particular, the commission found that from 2010 to 2014, certain DB traders participated in a cartel with traders at the three other banks by coordinating on prices of SSA bonds quoted to clients and the market in general, in violation of European union rules prohibiting anticompetitive business practices. As a result of its voluntary disclosure and cooperation with the commission and pursuant to the commission's 2006 leniency notice, DB was granted full immunity relating to the infringements described in the decision.","res":"Decision","sm":"On April 28, 2021, the commission issued a decision finding that DB and three other banks took part in anticompetitive conduct relating to the secondary trading market within the European economic area of ssa bonds denominated in U.S. dollars. In particular, the commission found that from 2010 to 2014, certain DB traders participated in a cartel with traders at the three other banks by coordinating on prices of ssa bonds quoted to clients and the market in general, in violation of European union rules prohibiting anticompetitive business practices. As a result of its voluntary disclosure and cooperation with the commission and pursuant to the commission's 2006 leniency notice, DB was granted full immunity relating to the infringements described in the decision and agreed to cease and desist from the relevant infringements.","ab":"Deutsche Bank AG, DB","firms":[300838],"id":961},{"d":"2021-04-27","di":"2021-04-27","dr":"2021-04-27","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Censure","os":"Fine","st":"Final","fine":40000.0,"dk":"2020-11-24-00034","al":"Alleged violation of NYSE rules 122 and 3110(a) and (b) in that Citigroup Global Markets Inc. maintained orders for the account of the same principal with two different floor brokers in the same security that could execute at the same time and price between December 1, 2018 and December 31, 2018 and failed to establish and maintain a supervisory system and written supervisory procedures reasonably designed to achieve compliance from January 2018 through the present.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine of $40,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":962},{"d":"2021-04-07","di":"2021-02-12","dr":"2021-04-07","k":"Regulatory Action","rg":"Other","reg":"Comision Nacional Del Mercado de Valores","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"2021025805","al":"On April 7, 2021, Man Group PLC (\"MAN\"), an advisory affiliate of GLG Partners LP (\"GLG\") based in London, UK, agreed to pay a fine of euro 240,000 to the Comision Nacional Del Mercado de Valores (the \"CNMV\"), pursuant to a settled resolution, in connection with the CNMV's findings that MAN had not complied with european union (\"EU\") regulations requiring the disclosure of an investor's short positions in the securities of any issuer based in an EU member country, such as spain. Specifically, the european securities and markets authority (\"ESMA\") has issued regulations on short selling and credit default swaps (\"SSR\") that require investors to file reports disclosing any short positions above a threshold of 0.2% of an issuer's outstanding shares, with additional disclosure thresholds at increasing intervals of 0.1%. Thus, an investor must file disclosures calculating its net short position whenever it crosses thresholds (up or down) of 0.2%, 0.3%, 0.4%, 0.5% etc. in the case of MAN, the CNMV determined that, between December 2017 and November 2018, three of MAN's affiliated managers, including GLG Partners LP had on five occasions failed to correctly disclose their net short position in four spanish issuers amounting to between 0.2% and 0.7% of the issuers' outstanding shares. The SSR regulations impose rules for calculating net short positions at the fund level among affiliated entities, which MAN attempted to apply in good faith. See ESMA 70-145-408, question 8.5, available at HTTPS://www.esma.europa.eu/sites/default/files/library/ESMA70-145-408_qa_on_ssr.pdf. In four cases, the irregularities arose from the incorrect identification of the position holding entity within MAN; (for example, a position held by one MAN manager was incorrectly notified as a position held by another MAN manager). This misreporting resulted in delayed correcting notifications to the CNMV. In one instance, a position was inadvertently not reported. The order related to MAN is set forth in dispatch record no. 2021025805 of the CNMV. The CNMV did not determine that MAN engaged in any misleading or deceptive conduct, nor that it committed any violation in connection with providing investment advisory services to any clients.","res":"Settled","sd":"On April 7, 2021, man, an advisory affiliate of GLG Partners LP agreed to pay a fine of euro 240,000 to the Comision Nacional Del Mercado de Valores (the \"CNMV\"), pursuant to a settled resolution, in connection with the CNMV's findings that man had not complied with european union (\"EU\") regulations requiring the disclosure of an investor's short positions in the securities of any issuer based in an EU member country, such as spain.","sm":"On April 7, 2021, man agreed to accept the findings without contesting and pay a fine of euro 240,000. No information Filed","ab":"Man Group PLC","firms":[163016],"id":963},{"d":"2021-04-07","di":"2021-02-12","dr":"2021-04-07","k":"Regulatory Action","rg":"Other","reg":"Comision Nacional Del Mercado de Valores","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"2021025805","al":"On April 7, 2021, Man Group PLC (\"MAN\"), an advisory affiliate of Ahl Partners LLP (\"AHL\") based in London, UK, agreed to pay a fine of euro 240,000 to the Comision Nacional Del Mercado de Valores (the \"CNMV\"), pursuant to a settled resolution, in connection with the CNMV's findings that MAN had not complied with european union (\"EU\") regulations requiring the disclosure of an investor's short positions in the securities of any issuer based in an EU member country, such as spain. Specifically, the european securities and markets authority (\"ESMA\") has issued regulations on short selling and credit default swaps (\"SSR\") that require investors to file reports disclosing any short positions above a threshold of 0.2% of an issuer's outstanding shares, with additional disclosure thresholds at increasing intervals of 0.1%. Thus, an investor must file disclosures calculating its net short position whenever it crosses thresholds (up or down) of 0.2%, 0.3%, 0.4%, 0.5% etc. in the case of MAN, the CNMV determined that, between December 2017 and November 2018, three of MAN's affiliated managers, including Ahl Partners LLP had on five occasions failed to correctly disclose their net short position in four spanish issuers amounting to between 0.2% and 0.7% of the issuers' outstanding shares. The SSR regulations impose rules for calculating net short positions at the fund level among affiliated entities, which MAN attempted to apply in good faith. See ESMA 70-145-408, question 8.5, available at HTTPS://www.esma.europa.eu/sites/default/files/library/ESMA70-145-408_qa_on_ssr.pdf. In four cases, the irregularities arose from the incorrect identification of the position holding entity within MAN; (for example, a position held by one MAN manager was incorrectly notified as a position held by another MAN manager). This misreporting resulted in delayed correcting notifications to the CNMV. In one instance, a position was inadvertently not reported. The order related to MAN is set forth in dispatch record no. 2021025805 of the CNMV. The CNMV did not determine that MAN engaged in any misleading or deceptive conduct, nor that it committed any violation in connection with providing investment advisory services to any clients.","res":"Settled","sd":"On April 7, 2021, man, an advisory affiliate of Ahl Partners LLP (\"AHL\") agreed to pay a fine of euro 240,000 to the Comision Nacional Del Mercado de Valores (the \"CNMV\") in connection with the CNMV's findings that man had not complied with european union (\"EU\") regulations requiring the disclosure of an investor's short positions in the securities of any issuer based in an EU member country, such as spain.","sm":"On April 7, 2021, man agreed to accept the findings without contesting and pay a fine of euro 240,000. No information Filed","ab":"Man Group PLC","firms":[167882],"id":964},{"d":"2021-04-05","di":"2021-04-05","dr":"2021-04-05","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2021-404B-004","al":"On April 5, 2021, ICE Clear Credit LLC alleged that during March 2021, in one instance, Goldman Sachs & Co. LLC (\"GSCO\") violated ICE Clear Credit rule 404(b) by failing to submit forty-five single name prices on a timely basis.","res":"Decision","sm":"ICE Clear Credit LLC imposed a fine of $20,000, which gsco paid by invoice in June 2021.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":965},{"d":"2021-04-05","di":"2021-04-05","dr":"2021-04-05","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"2021-404B-005","al":"On April 5, 2021, ICE Clear Credit LLC alleged that during March 2021, in one instance, Goldman Sachs international (\"GSI\") violated ICE Clear Credit rule 404(b), by failing to submit eighty-one single name prices on a timely basis.","res":"Decision","sm":"ICE Clear Credit LLC imposed a fine of $40,000, which gsi paid by invoice in June 2021.","ab":"Goldman Sachs","firms":[361],"id":966},{"d":"2021-03-31","di":"2021-03-31","dr":"2021-03-31","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Massachusetts","st":"Final","fine":233907.84,"dk":"E-2019-0005","al":"Firm failed to properly supervise a registered representative who had a client heavily concentrated in the precious metal sector.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":967},{"d":"2021-03-30","di":"2021-03-30","dr":"2021-03-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc. (Edga)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":90000.0,"dk":"STAR NO. 20130386840-05 / FILE NO. USRI-7659-08","al":"During the period of approximately September 1, 2013 through June 2016, and without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated did not reasonably supervise specified public and private side employee designations and/or communications in one business unit under the firm's policies and procedures in contravention of edga rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"During the period of approximately September 1, 2013 through June 2016 (the \"relevant period\"), and without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&s) did not establish and maintain a supervisory system reasonably designed to achieve compliance with applicable edga rules. During the relevant period, the firm's systems and procedures for designating and training public and private side personnel, supervising communications between them, and escalating communications that disclosed potential material nonpublic information (\"MNPI\") were not reasonable. In particular, and during the relevant period, certain personnel in one sub-group who were re-designated from public side to private side under the firm's policies did not receive reasonable training regarding the responsibilities of private side personnel. The firm also did not reasonably enforce its procedures during the relevant period requiring functional and physical separation of public and private side personnel within the sub-group. Although the firm had electronic communication review procedures during the relevant period, the procedures did not describe a reasonable process for escalating for further review communications that contained potential MNPI. The firm enhanced its procedures in June 2016 to address the issues identified. Based on the foregoing, MLPF&s agreed to a censure and a fine of $90,000 to edga.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":968},{"d":"2021-03-30","di":"2021-02-22","dr":"2021-03-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"dk":"STAR NO. 20170565048-04, FILE NO. USRI-7375-07","al":"RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and edgx rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":969},{"d":"2021-03-30","di":"2021-02-22","dr":"2021-03-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"STAR NO. 20170565048-03, FILE NO. USRI-7375-06","al":"BC capital markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and byx rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":970},{"d":"2021-03-30","di":"2021-02-22","dr":"2021-03-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","st":"Final","fine":45000.0,"dk":"STAR NO. 20170565048-01, FILE NO. USRI-7375-08.","al":"RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and edga rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":971},{"d":"2021-03-30","di":"2021-02-22","dr":"2021-03-30","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"dk":"STAR NO. 20170565048-02, FILE NO. USRI-7375-05","al":"RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and BZX rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":972},{"d":"2021-03-29","di":"2021-03-29","dr":"2021-03-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine, Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"21-17219","al":"The state published administrative order 2020-45 that provides firms licensed in Maine temporary relief from on-site branch office inspections due to ongoing COVID-19 pandemic. The order required firms with branch offices in Maine to provide the state with a list of the date(s) on which the firm last conducted an on-site inspection at each branch office in Maine. Janney did not comply with the administrative order by providing a response to the state; though Janney did conduct an on-site inspection of its single branch office in Maine in 2019 and 2020. The state deems Janney is out of compliance due to its lack of response to the order required by November 13, 2020.","res":"Consent","sd":"The firm was fined $2,500.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":973},{"d":"2021-03-23","di":"2021-03-23","dr":"2021-03-23","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Montana State Auditor, Commission of Securities and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"INS 2018-275","al":"The Office of the Montana State Auditor, Commission of Securities and Insurance (\"CSI\") found that since 2015 New York Life Insurance company and New York Life Insurance and annuity corporation (collectively, \"nyl\") used group life insurance and group annuity forms that had not been approved by the CSI, provided coverage under such forms to Montana residents and did not submit the forms for approval as required under Montana law.","res":"Consent","sm":"The March 23, 2021 consent agreement resolves the allegations against nyl and was entered without adjudication of any issue, law or fact.","ab":"New York Life Insurance","firms":[107717,169553,173355,309234],"id":974},{"d":"2021-03-23","di":"2021-03-23","dr":"2021-03-23","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Montana State Auditor, Commission of Securities and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"INS 2018-275","al":"The Office of the Montana State Auditor, Commission of Securities and Insurance (\"CSI\") found that since 2015 New York Life Insurance company and New York Life Insurance and annuity corporation (collectively, \"nyl\") used group life insurance and group annuity forms that had not been approved by the CSI, provided coverage under such forms to Montana residents and did not submit the forms for approval as required under Montana law.","res":"Stipulation and Consent","sm":"The March 23, 2021 consent agreement resolves the allegations against nyl and was entered without adjudication of any issue, law or fact.","ab":"New York Life Insurance","firms":[340676],"id":975},{"d":"2021-03-19","di":"2021-03-19","dr":"2021-03-19","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"21-CH-2101","al":"Pursuant to an offer of settlement in which Citigroup Global Markets Inc. neither admitted nor denied the rule violations upon which the penalty is based, on March 18, 2021, the clearing house risk committee found that Citigroup Global Markets Inc. violated CBOT rules 930.E.2., 970.A.4., 971.A.2.A. B. And c. And 980.B.2. In accordance with the settlement offer, the committee fined the firm $50,000.","res":"Settled","sm":"Without admitting or denying the findings, the firm agreed to pay the $50,000 fine.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":976},{"d":"2021-03-19","di":"2021-03-19","k":"Regulatory Action","dk":"CSB-01379819","ab":"Bergstrom, Brandon, Luke","firms":[7691],"id":977},{"d":"2021-03-18","di":"2020-08-18","dr":"2021-03-18","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"20-1363-BC","al":"Pursuant to an offer of settlement that Mirabella Financial Services LLP (\"Mirabella\") presented at a hearing on March 16, 2021, in which Mirabella neither admitted nor denied the rule violation upon which the penalty is based, a PANEL of the NYMEX business conduct committee (\"PANEL\") found that on August 18, 2020 accounts owned or controlled by Mirabella, which were aggregated for the purposes of exchange position limits, held September 2020 light sweet crude oil futures (\"SEP20 CL\") futures equivalent positions that exceeded the spot month position limit of 3,000 contracts in effect at that time. Specifically, Mirabella began trade date August 18, 2020 with a short position of 4,627 lots in SEP20 CL, 1,627 contracts (54.23%) over the standard expiration month position limit in effect for trade dates August 18, 19, and 20, 2020. The PANEL found that as a result, Mirabella violated rule 562. In accordance with the settlement offer, the PANEL ordered Mirabella to pay a fine to the exchange in the amount of $25,000. This action became final on March 16, 2021 and effective March 18, 2021.","res":"Settled","ab":"Mirabella Financial Services LLP","self":true,"firms":[160328],"id":978},{"d":"2021-03-11","di":"2019-05-20","dr":"2021-03-11","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":300.0,"dk":"FI REF 18-16063","al":"In June 2018,Mackay shileds notified the sfsa of one short position in the shares of a Swedish issuer. That notification was made unintentionally later than the notification deadline specified in regulation (EU) no. 236/2012.","res":"Decision","sd":"Mackay Shields was ordered to pay a special fine of SEC 2,500 (approx. $300.00) upon the issuance of an invoice by the sfsa.","sm":"Mackay Shields was notified on 5/20/19, that the sfsa was investigating to determine whether to impose a special fine. On 6/11/20 Mackay Shields was notified that the sfsa decided to impose a special fine of sek 5,000(approx. $600.00). Mackay Shields appealed the decision. On 2/8/21, Mackay Shields was notified that the appeal was not successful in overturning the decision, however, the amount of the special fine was reduced to sek 2,500 (approx. $300.00). The decision became final on 3/11/21.","ab":"Mackay Shields LLC","self":true,"firms":[107717],"id":979},{"d":"2021-03-11","di":"2019-05-20","dr":"2021-03-11","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","st":"Final","fine":300.0,"dk":"FI REF 18-16063","al":"In June 2018, Mackay Shields notified the sfsa of one short position in the shares of a Swedish issuer. That notification was made unintentionally later than the notification deadline specified in regulation (EU) no. 236/2012.","res":"Decision","sd":"Mackay Shields was notified on 5/20/19, that the sfsa was investigating to determine whether to impose a special fine. On 6/11/20 Mackay Shields was notified that the sfsa decided to impose a special fine of sek 5,000 (approx. $600.00). Mackay Shields appealed the decision. On 2/8/21, Mackay Shields was notified that the appeal was not successful in overturning the decision, however, the amount of the special fine was reduced to sek 2,500 (approx. $300.00). The decision became final on 3/11/21.","ab":"Mackay Shields LLC","firms":[173355],"id":980},{"d":"2021-03-10","di":"2021-03-10","dr":"2021-03-10","k":"Regulatory Action","rg":"Other","reg":"Czech National Bank","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":225000.0,"dk":"REF. NO. 2021 / 25856 / 570; FILE NO.: SP/2020/49/573","al":"The Czech National Bank (\"CNB\") found that Deutsche bank AG (\"DB AG\"), prague branch failed to implement and apply appropriate internal control procedures to mitigate risks relating to anti-money laundering and terrorist financing by failing to verify certain client data against sanction lists, establishing unreasonably long deadlines for checking potentially suspicious transaction alerts, and failing to ensure that control procedures could be adequately reconstructed. In addition, the CNB found that DB AG, prague branch failed to perform client checks to the extent necessary to assess such risks by setting inadequate parameters for the generation of suspicious transaction alerts, and in at least one case, failing to flag cross- border transactions that did meet the parameters","res":"Order","sm":"On March 10, 2021, the CNB entered an order (the \"order\") finding that DB AG, prague branch failed to implement and apply appropriate internal control procedures to mitigate risks relating to anti-money laundering and terrorist financing by failing to enter identification data into its internal system to verify certain client data against sanction lists, establishing unreasonably long deadlines for checking potentially suspicious transaction alerts, and failing to ensure that control procedures could be adequately reconstructed. In addition, the CNB found that DB AG, prague branch failed to perform client checks to the extent necessary to assess risks relating to anti-money laundering and terrorist financing by setting inadequate parameters for the generation of suspicious transaction alerts, and in at least one case, failing to flag cross-border transactions that did meet the parameters for the generation of suspicious transaction alerts. The CNB imposed a fine of five million Czech crowns, which is approximately usd $225,000, which will be timely paid.","ab":"Deutsche Bank AG (Prague","firms":[300838],"id":981},{"d":"2021-03-09","di":"2021-03-09","dr":"2021-03-09","k":"Regulatory Action","rg":"Other","reg":"ICE Futures Europe","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30666.43,"dk":"REF. 16102","al":"J.P. Morgan Securities LLC's client held a short position in wti crude futures in excess of the relevant position limit as of close of business on November 17, 18, and 19, 2020, in violation of ICE Futures Europe rule P.3.","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":982},{"d":"2021-03-05","di":"2021-03-05","dr":"2021-03-05","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":145000.0,"dk":"2015045017001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its market access risk management controls and supervisory procedures were not reasonably designed to manage the financial and regulatory risks of the firm's market access business on the exchange. The findings stated that the firm failed to implement market access controls to its convertibles desk's order flow routed to the market. Therefore, the firm's financial and regulatory risk management controls and supervisory procedures for the convertibles desk were not reasonably designed to address the risks presented by the desk's market access business activity, in violation of Securities Exchange Act rule 15C3-5(b), (c)(1), and (c)(2). The findings also stated that the firm's financial risk management controls and supervisory procedures for its cash, electronic sales and trading, and exchange-traded fund lead market making desks were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders, in violation of rule 15C3-5(b) and (c)(1)(II). The findings also included that the firm's market access rule supervisory system and WSPS were unreasonable. As a result of the deficiencies described above, the firm violated Nasdaq rules 3010 and 2010a.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":983},{"d":"2021-02-26","di":"2021-02-26","dr":"2021-02-26","k":"Regulatory Action","rg":"Other","reg":"South African Reserve Bank","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Reprimand and caution","st":"Final","fine":2600000.0,"dk":"REF.: 15/1/L_DBAG","al":"The South African Reserve Bank (\"SARB\") found that Deutsche Bank AG (\"DB AG\"), johannesburg branch, in connection with its anti- money laundering (\"AML\") and counter-financing of terrorism (\"CFT\") compliance program, failed to comply with certain responsibilities and requirements relating to DB AG's risk management and compliance program, customer due diligence, recordkeeping, and governance.","res":"Order","sm":"On February 26, 2021, the sarb entered an order (the \"order\") finding that DB AG, johannesburg branch, in connection with its AML compliance program, failed to comply with (I)risk management and compliance responsibilities, for example, by failing to identify certain natural-person ubos, {II) customer due diligence requirements for certain clients,{III) recordkeeping requirements for certain terminated client relationships, and {IV) AML/CFT governance requirements relating to customer due diligence, recordkeeping, and screening processes for existing customers. The sarb issued cautions, a reprimand, and a fine of zar 38 million, which is approximately usd $2.60 million, of which zar 28 million (approximately usd$1.92 million) was timely paid on March 23, 2021, and of which zar 10 million (approximately usd $690,000) is suspended for three years provided there are no similar recordkeeping deficiencies within the three-year period.","ab":"Deutsche Bank AG (","firms":[300838],"id":984},{"d":"2021-02-08","di":"2021-02-08","dr":"2021-02-08","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","st":"Final","fine":325000.0,"dk":"2020-02-00065","al":"During the period April 1, 2018 through September 30, 2020 Stifel failed to maintain and enforce written policies and procedures reasonably designed to prevent the potential misuse of material, nonpublic information and to supervise and enforce reasonable information barriers in connection with their stock buyback trading activity.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":985},{"d":"2021-02-05","di":"2021-02-05","dr":"2021-02-05","k":"Regulatory Action","rg":"Other","reg":"Central Bank of the Republic of China (Taiwan)","san":"Revocation","os":"Suspension","st":"Final","dk":"TAI-YANG-WEI-CHI-TZU-1100006870","al":"The Central Bank of the Republic of China (Taiwan) (\"CBC\") found that Deutsche bank AG, taipei branch (\"DBTP\") failed to review transactional documents to verify that its clients' two/foreign currency forward trades were driven by \"foreign exchange genuine need\" for TAIWAN dollars, resulting in the clients engaging in speculative trading in two/foreign currency forwards. In addition, certain of those transactions, when matched with spot FX transactions upon maturity of the forward transactions, were found to be in the nature of synthetic NDF transactions with counterparties other than those allowed by CBC regulations.","res":"Order","sm":"In February 5, 2021, the CBC issued the sanction letter to DBTP. In the sanction letter, the CBC found that DBTP failed to review transactional documents to verify that its clients' two/foreign currency forward trades were driven by \"foreign exchange genuine need\" for taiwan dollars, resulting in the clients engaging in speculative trading in two/foreign currency forwards. In addition, certain of those transactions, when matched with spot FX transactions upon maturity of the forward transactions, were found to be in the nature of synthetic NDF transactions with counterparties other than those allowed by CBC regulations. The sanction letter revoked DBTP's ability to engage in two/foreign currency forward trades and two/foreign currency non- deliverable forward trades, and suspended DBTP for a period of two years from engaging in foreign exchange derivatives transactions. The revocation and suspension are subject to an administrative appeal to be submitted within 31 days following receipt of the sanction letter. DBTP is permitted to re-apply to the CBC to resume business activities covered by the revocation and suspension prior to the end of the two-year period upon demonstration to the CBC of \"concrete improvement.\" No monetary sanction was imposed by the CBC.","ab":"Deutsche Bank AG (Taipei","firms":[300838],"id":986},{"d":"2021-02-02","di":"2020-05-19","dr":"2021-02-02","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Restitution","os":"Cease and desist, censure, review of supervisory procedures, engagement of independent compliance consultant, disgorgement,","st":"Final","fine":200000.0,"dk":"E-2019-0117","al":"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.","res":"Consent","sm":"RBCCM notes that in agreeing to the order RBCCM did not admit to any supervisory deficiencies and believe that the customers' account investments were appropriately supervised and were consistent with their stated investment goals and financial circumstances as well as RBCCM's policies. The customer accounts generated substantial income for the customers that exceed the commissions charged. After 50 years in the financial services industry, the registered representative voluntarily retired in 2020 having been the subject of only one customer complaint throughout his 50 year career, nor was he the subject of any prior regulatory discipline. RBCCM and the registered representative settled this matter in the interests of customer relations and to avoid the costs, uncertainties and distractions associated with litigation.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":987},{"d":"2021-01-29","di":"2021-01-29","dr":"2021-01-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":175000.0,"dk":"2014043783101","al":"Alleged violation of rules 611(a) and (c)of regulation NMS, NASD rule 3010, and FINRA rules 3110 and 2010 in that Citigroup Global Markets Inc. failed to establish, maintain, and enforce written policies and procedures reasonably designed to prevent trade- throughs of protected quotations in NMS stocks. In addition, the firm failed to conduct regular surveillance to ascertain the effectiveness of its rule 611 compliance program and to take prompt action to remedy any deficiencies between January 2013 and April 2020.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a $175,000, and an undertaking to ensure that the firm's processes, controls, policies, systems, and procedures are reasonably designed to achieve compliance with rule 611","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":988},{"d":"2021-01-27","di":"2021-01-27","k":"Regulatory Action","dk":"2020-0392-S","ab":"Hardison, Don","firms":[7691],"id":989},{"d":"2021-01-22","di":"2018-08-16","dr":"2021-01-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":1250000.0,"dk":"2018059113701","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") alleged that between the period of January 2015 and November 2019, Goldman Sachs & Co. LLC (\"GSCO\") violated (I) section 17(f)(2) of the securities and Exchange Act of 1934 (the \"Exchange Act\") and FINRA rule 2010, for failing to fingerprint 1,061 associated, non-registered individuals; (II) article III, section 3(b) of the FINRA by- laws, for allowing two individuals to be associated with the firm who were subject to statutory disqualification; (III) 17(a)(3) of the Exchange Act and FINRA rules 4511 and 2010, for failure to maintain adequate records of fingerprinting; and (IV) FINRA rules 3110 (a) and (b) and 2010, for failing to maintain a supervisory system and written supervisory procedures designed to ensure fingerprint screening of certain populations of non-registered associated individuals (namely employees who transferred to the firm from foreign offices and employees who joined the firm as a result of an acquisition).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the violations, the firm entered into a letter of acceptance, waiver and consent (the \"AWC\") with FINRA on January 22, 2021, pursuant to which the firm consented to (I) a censure; (II) a fine in the amount of $1,250,000, which was paid in full by wire on February 9, 2021; and (III) an undertaking to review the firm's systems and procedures regarding the identification, fingerprinting, and screening of non-registered associated persons, along with a written statement within 60 days of the AWC describing the methodology used to conduct the review and certifying that the firm has adopted and implemented policies and procedures reasonably designed to achieve compliance with the relevant laws and rules, as set forth in the AWC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":990},{"d":"2021-01-21","di":"2021-01-21","dr":"2021-01-21","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet (Norway)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3655.0,"al":"Finanstilsynet fined QVT Financial LP for a purported late regulatory filing in 2018. QVT challenged this allegation directly with Finanstilsynet in 2019 and then appealed the fine to the norwegian ministry of finance (det kongelige finansdepartement) in 2020. In December 2020, the ministry of finance simply denied our appeal without responding to any of our arguments. Although it is QVT's view that it did not violate any regulation, that Finanstilsynet misapplied the relevant laws and that its own published directives contradict its stated position in this matter, QVT opted not to pursue the appeal further in litigation as the costs thereof would far eclipse this small fine assessed. Accordingly, QVT paid the fine (in 2021) to close the matter instead.","res":"Other","sd":"Paid nok 30,000 ($3,655) on 1/21/2021.","sm":"The matter is closed now that the fine has been paid.","ab":"QVT Financial LP","self":true,"firms":[156508],"id":991},{"d":"2021-01-13","di":"2020-10-27","dr":"2021-01-13","k":"Regulatory Action","rg":"Other","reg":"Swiss Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":11994.0,"al":"Kiltearn self-reported through Swiss counsel in relation to a late disclosure of its clients' holding in a Swiss company falling below the three percent (3%) threshold. Kiltearn entered into the agreement to dispense with the need for a determination under the relevant legislation by. In the view of the Swiss Department of Finance, the agreement remedied the late disclosure.","res":"Settled","sd":"Kiltearn paid the sum of CHF 10,000 (~usd 10,900) plus procedural costs of CHF 1,000 (~usd 1,090) to the Swiss Department of Finance as a part of settlement agreement. Kiltearn entered into the agreement to dispense with the need for a determination under the relevant legislation by. In the view of the Swiss Department of Finance, the agreement remedied the late disclosure. Kiltearn paid the agreed sum. The matter is closed.","sm":"Kiltearn paid the agreed sum. The matter is closed. No information Filed","ab":"Kiltearn Partners LLP","self":true,"firms":[158789],"id":992},{"d":"2021-01-12","di":"2021-01-12","dr":"2021-01-12","k":"Regulatory Action","rg":"Other","reg":"The Reserve Bank of India (\"Rbi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":276000.0,"al":"The Reserve Bank of India (\"Rbi\") found that Deutsche Bank AG (\"DB AG\") failed to offer uniform rates of interest paid on deposits of similar amount and tenure accepted on the same dates in seven instances from financial years 2017 to 2019. In addition, the RBI found that DB AG communicated interest rates of bulk deposits before publishing the interest rate schedule on its website, and failed to maintain the bulk deposit interest rate card for corporate customers in its core banking system prior to July 20, 2020.","res":"Other","sm":"On January 12, 2021, the rbi entered an order (the \"order\") finding that DB AG failed to offer uniform rates of interest paid on deposits of similar amount and tenure accepted on the same dates in seven instances from financial years 2017 to 2019. In addition, the rbi found that DB AG communicated interest rates of bulk deposits before publishing the interest rate schedule on its website, and failed to maintain the bulk deposit interest rate card for corporate customers in its core banking system prior to July 20, 2020. The rbi imposed a fine of two core rupees, which is approximately $276,000, which was timely paid on January 19, 2021.","ab":"Deutsche Bank AG","firms":[300838],"id":993},{"d":"2021-01-08","di":"2018-08-24","dr":"2021-01-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Injunction; attorney's fees and related costs","st":"Final","al":"Plaintiff brought a securities class action on behalf of all those who purchased ADT inc. (\"ADT\") common stock in or traceable to ADT's January 19, 2018 initial public stock offering (the \"IPO\"), seeking to pursue remedies under the Securities Act of 1933 (the \"1933 act\") against the issuer, ADT, and a number of other defendants, including Apollo management, L.P., the applicant, and several of its advisory affiliates. The plaintiff alleges, among other things, that the defendants violated several provisions of the 1933 act. As it relates to Apollo management, L.P. and several of its advisory affiliates, plaintiff asserts a claim for violation of section 15(a) of the 1933 act as a result of the alleged misstatements and omissions in the registration statement and in the preparation of the prospectus for the IPO.","res":"Judgment Rendered","sd":"The court's order and judgment dismissing the action terminated all claims against the Apollo entities without any admissions or findings of liability and without imposing any fees, costs, damages, or sanctions on the Apollo entities.","ab":"Apollo Management GP, LLC","firms":[159127],"id":994},{"d":"2021-01-08","di":"2018-05-21","dr":"2021-01-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Prejudgement and post-judgement interest, plus attorney's and expert fees and related costs","st":"Final","al":"Plaintiff brought a securities class action on behalf of those who purchased ADT inc. (\"ADT\") common stock in or traceable to ADT's January 19, 2018 initial public stock offering (the \"IPO\"), seeking to pursue remedies under the Securities Act of 1933 (the \"1933 act\") against the issuer, ADT, and a number of other defendants, including Apollo management, L.P., the applicant, and several of its advisory affiliates. The plaintiff alleges, among other things, that the defendants violated several provisions of the 1933 act. As it relates to Apollo management, L.P. and several of its advisory affiliates, plaintiff asserts a claim for violation of sections 11 and 15(a) of the 1933 act as a result of the alleged misstatements and omissions in the registration statement and in the preparation of the prospectus for the IPO.","res":"Dismissed","sd":"The court's order and judgment dismissing the action (1) terminated all claims against the Apollo entities without any admissions or findings of liability and without imposing any fees, costs, damages, or sanctions on the Apollo entities; and (2) barred similar claims from being asserted against the Apollo entities in future actions.","ab":"Apollo Global","firms":[159127],"id":995},{"d":"2021-01-08","di":"2021-01-08","dr":"2021-01-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement","st":"Final","dk":"FILE NO. 3-20200","al":"The SEC alleged that Deutsche Bank AG (\"Dbag\") improperly used third-party intermediaries, business development consultants, and finders to obtain and retain global business from at least 2009 through 2016. The SEC alleged that DBAG lacked sufficient internal accounting controls related to the use and payment of BDCS during the relevant time period and failed to take sufficient steps to address and remediate known internal accounting control failures until 2016. The SEC also alleged that payments were inaccurately recorded as legitimate business expenses in DBAG's books and records, and involved falsified invoices and documentation.","res":"Order","sm":"On January 8, 2021, the SEC entered an order instituting cease-and-desist proceedings pursuant to section 21c of the Securities Exchange Act of 1934, making findings, and imposing a cease-and-desist order (the \"order\") in the matter of Deutsche bank AG. The order requires dbag to cease and desist from violating sections 13(b)(2)(a) and 13(b)(2)(b) of the Securities Exchange Act and to pay disgorgement of $35,145,619 and prejudgment interest of $8,184,003, which was timely paid on January 14, 2021.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":996},{"d":"2020-12-31","di":"2020-12-31","dr":"2020-12-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":6500000.0,"dk":"2018059192701","al":"Without admitting or denying the findings, LPL Financial LLC (\"the firm\") consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with regulatory obligations including record retention, fingerprinting and screening of associated persons, and supervision of consolidated reports. The findings stated that, among other things, the firm failed to retain electronic records in the required format, preserve certain electronic records, and notify FINRA prior to employing electronic storagemedia, in violation of section 17(a) and rule 17A-4 of the Securities Exchange Act of 1934. The firm's failure affected at least 87 million records and led to the permanent deletion of over 1.5 million customer communications maintained by a third-party data vendor. Further, the firm failed to send account notices that are required to be sent to customers at 36-month intervals for each account in which a suitability determination had been made. The findings also stated that the firm failed to fingerprint non- registered associated persons and thus failed to screen these persons for statutory disqualification based on criminal convictions. This failure arose from the firm's failure to maintain a reasonable supervisory system and procedures to identify and properly screen all persons who became associated with the firm in a non-registered capacity. The firm has not created or maintained required fingerprint records for the persons that it failed to fingerprint. Separately, the firm permitted a non- registered associated person, who was subject to statutory disqualification, to remain associated with the firm. The firm obtained fingerprints for the person, submitted them to FINRA for processing and received a notice from FINRA stating that the person had been convicted of a misdemeanor for possession of a forged instrument, and was therefore subject to disqualification. The findings also included that the firm failed to establish and maintain a supervisory system reasonably designed to supervise certain consolidated reports. The firm was not aware of, and therefore failed to reasonably supervise, certain tools that its approved third-party vendors provided to the firm's registered representatives to create and disseminate consolidated reports. In particular, the firm's vendors created non-finalized consolidated reports, which, although intended for internal use, could be sent to customers. Nonetheless, the vendors did not send such reports to the firm and it therefore did not review them. The firm's vendors also allowed representatives and customers to directly access consolidated reports on the vendors' websites, and the firm did not receive or review consolidate dreports that its representatives disseminated in this manner. The firm also failed to review assets that were manually entered by representatives on consolidated reports when the representatives categorized them as non-securities related, even when the manually entered assets were evidently securities related. A former registered representative of the firm exploited these supervisory deficiencies in perpetrating a ponzi scheme through which he converted at least $1,000,000 of the firm's customers' money. The former representative provided some of his customers with direct access to the website of one of the approved third-party vendors, where they were able to access consolidated reports that contained fictitious, manually added assets. The former representative also directly accessed the","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":997},{"d":"2020-12-30","di":"2020-12-30","dr":"2020-12-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Restitution","os":"Censure","st":"Final","dk":"2019062530701","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Morgan Stanley Smith Barney LLC (the \"firm\") failed to establish and maintain a supervisory system reasonably designed to supervise representatives' recommendations to customers to purchase particular share classes of 529 savings plans in violation of MSRB rule G-27(a) and (b). Specifically, FINRA alleged that the firm's supervisory system was not reasonably designed to supervise 529 share-class recommendations executed (1) in certain legacy smith barney accounts, or (2) through transactions made directly with plans.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 30, 2020, the firm became the subject of a letter of acceptance, waiver and consent (\"AWC\") issued by FINRA regarding allegations that the firm failed to establish and maintain a supervisory system reasonably designed to supervise representatives' recommendations to customers to purchase particular share classes of 529 savings plans in violation of MSRB rule G-27(a) and (b). Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and payment of restitution of $1,460,518 plus interest. The firm voluntarily self-reported the matter to FINRA as part of FINRA's 529 plan share class disclosure initiative and FINRA recognized and credited the firm's extraordinary cooperation.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":998},{"d":"2020-12-21","di":"2020-11-11","dr":"2020-12-21","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1250.0,"al":"On November 11, 2020, Bloomberg SEF LLC (\"BSEF\") notified Goldman Sachs international (\"GSI\") that it had completed its inquiry and concluded that GSI violated BSEF rule 531.a(d) by submitting block trades to BSEF more than 10 minutes after the time the participants agreed to the terms of the block trades. As this was GSI's second such violation within a 12-month period, BSEF imposed a fine of $1,250.","res":"Decision","sm":"The fine imposed by BSEF was in the amount of $1,250, which was paid in full by gsi by wire on December 21, 2020.","ab":"Goldman Sachs","firms":[361],"id":999},{"d":"2020-12-17","di":"2020-12-17","dr":"2020-12-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution","st":"Final","dk":"2018057389701","al":"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 reasonably designed to supervise representatives' recommendations to customers to purchase particular share classes of 529 savings plans in violation of MSRB rule G-27(a) and (b). The findings stated that the firm's supervisory system was not reasonably designed to supervise 529 share-class recommendations executed through transactions made directly with plan fund companies.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In resolving the matter, FINRA recognized and credited cgmi's extraordinary cooperation.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1000},{"d":"2020-12-15","dr":"2020-12-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","dk":"2016047696701","al":"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 reasonably designed to supervise representatives' recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that the firm did not provide adequate guidance to representatives regarding the importance of considering share-class differences when recommending 529 plans. The firm had no procedures requiring supervisors to review 529 plan share-class recommendations for suitability. The firm updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, the firm did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share-class recommendations. Later, the firm issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share-class recommendations. The firm then updated its supervisory systems and procedures with respect to 529 share-class recommendations. Among other things, the firm instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative's 529 share- class recommendation. The firm has agreed to pay restitution and interest relating to the sale of class c shares to certain 529 plan customers in the estimated amount of $839,803.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1001},{"d":"2020-12-14","di":"2019-03-06","dr":"2020-12-14","k":"Regulatory Action","rg":"Other","reg":"De Nederlandsche Bank","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"A formal instruction (aanwijzing) to remedy shortcomings in the compliance with provisions of the anti-money laundering and","st":"Final","fine":392562.0,"al":"In 2018, De Nederlandsche Bank (DNB) conducted a thematic, sector-wide survey among dutch banks, focusing on the measures that the banks have taken to prevent money laundering and terrorism financing. Following this survey, DNB concluded that Triodos bank did not have adequate measures concerning customer due diligence and monitoring of customer transactions.","res":"Other","sm":"Triodos bank reports that it accepted the DNB instruction and is implementing mitigating measures, which are on track. Triodos bank also reports that it paid the administrative penalty without delay. No information Filed","ab":"Triodos Bank, N.V.","firms":[307440],"id":1002},{"d":"2020-12-09","di":"2020-12-09","dr":"2020-12-09","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and adminstrative penalty(IES) / fine(s)","st":"Final","fine":200000000.0,"dk":"FILE NO. 3-20165","al":"The SEC alleged that General Electric Company failed to disclose material information to investors related to two of its reportable business segments during the period 2015 to 2017.first, ge failed to disclose to investors information concerning the nature of its reported profit growth in its power business. Second, from 3q 2015 to 1q 2017, ge failed to disclose to investors trends in its insurance business and the potential for substantial losses.","res":"Settled","sd":"$200,000,000 on 12/31/2020","sm":"On December 9, 2020, ge reached a settlement with the SEC in connection with an investigation related to disclosures and internal controls with respect to ge capital's run off insurance operations during Q3 2015 through to Q1 2017. Ge paid a civil penalty of $200 million and consented to an order requiring it to cease and desist from violations of specified provisions of the federal securities laws and rules promulgated thereunder. In addition, ge agreed to cooperation obligations and to report during a one-year period to the SEC about compliance related to ge capital's run-off insurance operations. Ge has also taken steps to enhance its investor disclosures regarding insurance trends and risks, as well as enhancing internal controls on its insurance premium deficiency testing (also known as loss recognition testing) process and adding disclosure controls and procedures concerning its insurance liabilities. Consistent with common SEC practice, ge neither admits nor denies the findings in the administrative order that the SEC issued in connection with the settlement. No information Filed","ab":"General Electric Company","firms":[323648],"id":1003},{"d":"2020-12-07","di":"2020-12-07","dr":"2020-12-07","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; costs; restitution","st":"Final","fine":1750000.0,"dk":"COM2019-000","al":"Without admitting or denying the facts, violations or statements of law, the firm consented to the entry of a consent order that alleged the firm violated rsa 421-b:8, x (prior to January 1, 2016) and rsa 421-b:4-406(k) (on or after January 1, 2016) for failing to abide by FINRA rule 3110; and violated rsa 421-b:10, I(a) and (b)(10) (prior to January 1, 2016) and rsa 421-b:4-412(d)(9) (on or after January 1, 2016) for failing to detect and reasonably supervise a former registered representative's overcharging an investor, excessive trading, mismarked confirmations, and unsuitable trading of ipos and inverse and leveraged ETFS.","res":"Consent","sm":"Without admitting or denying the facts, violations or statements of law, the firm was ordered to (1) cease and desist from any violations of N.H. Rsa 421-b, (2) pay an administrative fine of $1,750,000, (3) pay costs of $250,000, and (4) upon the execution of the consent order and the contemporaneous execution of a private settlement agreement to resolve an investor's arbitration claims, to pay restitution to the investor in the amount of $24,250,000 to resolve the investor's arbitration claims. The fine, costs, and the restitution will be paid in accordance with the terms of the consent order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1004},{"d":"2020-11-25","di":"2020-11-25","dr":"2020-11-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":75000.0,"dk":"2017054001501","al":"Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that it, failed to make accurate order memoranda in violation of rule 17A-3(a)(6) under the Securities Exchange Act of 1934 and FINRA rules 4511 and 2010, and transmitted inaccurate reports to the order audit trail system (OATS) in violation of FINRA rules 7450 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm entered into an AWC agreement with FINRA on November 25, 2020, fully resolving this matter, which included agreement to the entry of a censure against the firm and a fine payable to FINRA in the amount of $75,000. FINRA received the fine on December 10, 2020.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1005},{"d":"2020-11-23","di":"2020-11-23","dr":"2020-11-23","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"N/A","al":"The South Dakota Division of Insurance (\"division\") alleged LPL Financial LLC (\"LPL\") established two accounts in restricted status without adequate permission, in violation of SDCL 47-31B-412(d)(9).","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1006},{"d":"2020-11-18","di":"2020-10-19","dr":"2020-11-18","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2908.0,"dk":"FI DNR 18-15947","al":"Sfsa alleged that the adviser failed to submit a net short filing with respect to a Swedish issuer in accordance with the next day filing obligation prescribed by sfsa regulations.","res":"Decision","sd":"The penalty of sek 25,000 (approximately $2,908) was paid to the sfsa upon receipt of payment details.","sm":"The sfsa decided to impose a penalty against the adviser of $2,908 for failure to report a net short position within the time limit prescribed by Swedish financial and securities laws. The adviser subsequently self-reported to the sfsa the net short position in the shares of the Swedish issuer. The sfsa decision became binding on November 18, 2020. No further action by the adviser is anticipated or required for the disposition of this matter. No information Filed","ab":"Montanova Capital, LLC","self":true,"firms":[165153],"id":1007},{"d":"2020-11-11","di":"2019-11-06","dr":"2020-11-11","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Other","os":"Special fee","st":"Final","fine":20000.0,"dk":"16932-18; 16937-18","al":"In the matter 16932-18: the firm timely filed with the sfsa the net short position in the shares of a single Swedish issuer. However, the filing contained a typographical error, was later corrected but nonetheless considered by the sfsa to have been filed later than the next day filing deadline. In the matter 16937-18: the firm filed the net short position in the shares of a single Swedish issuer inadvertently later than the next day filing deadline. The firm self-reported the late filing to the sfsa.","res":"Decision","sd":"The sfsa decided to require the firm to pay a special fee of 113,700 Swedish krona (approximately $13,800 usd) (16937-18) and 51,200 Swedish kroner (approximately $6,200 usd) (16932-18), collectively $20,000.","sm":"Appeal was denied.","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":1008},{"d":"2020-11-10","di":"2020-11-10","dr":"2020-11-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":475000.0,"dk":"2017055673701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that (1) due to reliance on a data feed from a third-party service provider to identify the firm's role in transactions for issuers covered by firm research reports, the firm omitted approximately 24,800 required disclosures in 16,850 equity research reports that it was either a manager or co-manager of a public offering of equity securities for the companies covered in the reports, which constituted approximately 6.75% of required manager/co-manager disclosures during the five-year period and affected approximately 4.43% of published equity research reports during the time period in violation of NASD rule 2711(h)(2)(a)(II)(a) and FINRA rule 2241(c)(4)(c)(I), and (2) the firm's omissions were the result, in part, of the firm's failure to establish and maintain a supervisory system and written supervisory procedures reasonably designed to achieve compliance with NASD rule 2711(h)(2)(a) (II)(a) and FINRA rule 2241(c)(4)(c)(I).","res":"Acceptance, Waiver & Consent(AWC)","sm":"In resolving the matter, FINRA recognized cgmi's extraordinary cooperation.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1009},{"d":"2020-11-04","di":"2020-11-04","dr":"2020-11-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"2016051352401","al":"Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that, from April 2016 through October of 2016, the firm distributed 6,851 account statements to customers containing valuation information for one or more direct participation programs (DPPS) or real estate investment trusts (REITS) that did not comply with NASD rule 2340(c). The firm also failed to establish and maintain supervisory procedures reasonably designed to ensure that its customer account statements reflected DPP and REIT prices derived from a valuation methodology allowed by NASD rule 2340 (c). For the same reasons the firm also failed to maintain accurate books and records violating FINRA rules 3110(a) and (b), 4511 and 2010","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1010},{"d":"2020-10-27","di":"2020-10-09","dr":"2020-10-27","k":"Regulatory Action","rg":"Other","reg":"Akk ­ ÁLlamadÓSSÁG Kezelo KÖZpont ZÁRTKÖRuen MukÖDo RÉSZVÉNytÁRsasÁG","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1614.5,"al":"Akk ­ ÁLlamadÓSSÁG Kezelo KÖZpont ZÁRTKÖRuen MukÖDo RÉSZVÉNytÁRsasÁG alleged that during the month of September 2020, Goldman Sachs international (\"GSI\") failed to meet its primary dealer quoting obligations in accordance with the agency contract between GSI and akk and the relevant market making rules.","res":"Decision","sm":"The akk imposed a fine on gsi in the amount of huf 500,000, which was paid by submission of a wire on October 27, 2020.","ab":"Goldman Sachs","firms":[361],"id":1011},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s) disgorgement","st":"Final","fine":400000000.0,"dk":"3-20132","al":"On October 22, 2020, The Goldman Sachs Group, inc. (\"GS group\") entered into an order instituting cease and desist proceedings with The Securities and Exchange Commission (the \"SEC\" and the order, the \"SEC order\"), which alleged GS group failed to reasonably maintain a sufficient system of internal accounting controls between 2012 and 2015 with respect to the process by which it reviewed and approved the commitment of firm capital in large, significant and complex transitions, such as the 1malaysia development berhad (\"1MDB\") offerings, and that documentation prepared in connection with the 1MDB transactions did not accurately reflect certain aspects of the bond offerings, including the involvement of a third party intermediary in the offerings.","res":"Order","sm":"GS group paid a civil money penalty in the amount of $400,000,000 to the SEC and disgorgement of $606,300,000, with dollar-for- dollar disgorgement credit up to that amount based on the U.S. dollar value of similar payments made pursuant to the settlement agreement.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1012},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000000.0,"al":"On October 22, 2020, The Goldman Sachs Group, inc. (\"GS group\") entered into a consent order for a civil money penalty with the New York State Department of Financial Services (the \"DFS\", and the consent order, the \"DFS order\"), which alleged violations of the New York banking law (\"banking law\") arising out of investments by a GS group wholly-owned subsidiary, Goldman Sachs bank USA (\"GS bank\"), in instruments related to 1malaysia development berhad (\"1MDB\"). The conduct described in the DFS order includes (I) the failure of GS group to adequately detect or address certain red flags in connection with the 1MDB bond transactions; (II) GS group's failure to escalate or address allegations of bribery communicated to certain senior business personnel following the completion of the 1MDB offerings; (III) GS group's failure to address allegations of its employees suspected involvement in the 1MDB misconduct; and (IV) GS group's failure to convey to GS bank red flags or information known about the 1MDB offerings or the misconduct of its employees so that GS bank could affirmatively report the incident to the DFS. The DFS order also finds that GS group violated section 44 of the banking law by conducting business in an unsafe and unsound manner and 3 N.Y.C.R.R. Section 300.4 by failing to submit a report to the superintendent of the DFS of one or more incidents that appear to relate to a plan or scheme that would be of interest to similar organizations located in the same area or through the state.","res":"Order","sm":"GS group paid a civil money penalty in the amount of $150,000,000 to the DFS.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1013},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":154000000.0,"dk":"20-018-B-HC; 20-018-CMP-HC","al":"On October 22, 2020, The Goldman Sachs Group, inc. (\"GS group\") entered into an order to cease and desist and order of assessment of a civil money penalty with the Board of Governors of the Federal Reserve System (the \"Federal Reserve\", and the order, the \"Federal Reserve order\"), which alleged GS group engaged in unsafe and unsound banking practices relating to the 1malaysia development berhad (\"1MDB\") bond transactions that resulted from deficient policies, procedures and controls. Such deficiencies included (I) the lack of, or failure to implement, adequate compliance policies and procedures to ensure the 1MDB offerings complied with safe and sound practices; (II) the failure of the review and approval process to appreciate the significant risks associated with the 1MDB offerings; (III) the failure of GS group control functions and senior personnel to address red flags, insist on adequate information and documentation regarding key aspects of the offerings prior to execution, and effectively supervise a senior business employee about whom certain GS group personnel had expressed integrity concerns in the past; and (IV) the failure to escalate or address allegations of bribery communicated to certain senior business personnel.","res":"Order","sm":"In addition to payment of the civil money penalty, the Federal Reserve order requires that GS group take certain affirmative actions, including submitting to the Federal Reserve (I) a written plan to enhance, and maintain improvements to, oversight of the review and approval of certain significant and complex transactions; (II) a written plan to enhance its existing anti-bribery compliance program for such transactions; and (III) a written enhanced due diligence program for such transactions, in each case each acceptable to the Federal Reserve.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1014},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"Other","reg":"Hong Kong Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":350000000.0,"al":"The Hong Kong Securities and Futures Commission (\"HKSFC\") issued a statement of disciplinary action (the \"SFC statement\") against Goldman Sachs (Asia) L.L.C. (\"GS ASIA\"), an indirect wholly owned subsidiary of the Goldman Sachs group, inc., on October 22, 2020, relating to GS ASIA's failure to properly examine and address red flags in connection with the 1malaysia development berhad (\"1MDB\") transactions and to diligently supervise its senior personnel in connection with their participation in the 1MDB transactions.","res":"Order","sm":"GS asia paid a financial penalty in the amount of $350,000,000 in connection with the SFC statement.","ab":"Goldman Sachs (Asia) L.L.C.","firms":[361],"id":1015},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":63000000.0,"dk":"142888","al":"Goldman Sachs international (\"GSI\"), an indirect wholly owned subsidiary of the Goldman Sachs group, inc., received on October 22, 2020 a warning notice from the UK Financial Conduct Authority (the \"FCA\" and the notice, the \"FCA notice\"), which cites GSI's failure to (I) assess and manage the risks associated with the 1malaysia development berhad transactions; (II) properly record how GSI committees assessed and managed those risks and; (III) respond appropriately to allegations of bribery and misconduct.","res":"Order","sm":"Gsi paid a financial penalty in the amount of $63,000,000 in connection with the FCA notice.","ab":"Goldman Sachs","firms":[361],"id":1016},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"Other","reg":"Singapore Commercial Affairs Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement","st":"Final","fine":122000000.0,"dk":"HHQ/DOW/TCK/308392/7","al":"On October 22, 2020, Goldman Sachs (Singapore) pte (\"GS Singapore\") received a notice of conditional warning from the Singapore Commercial Affairs Department (\"SCAD\"), at the direction of the Singapore attorney general's chambers (the \"Singapore notice\"), which alleged GS Singapore corruptly gave gratification as a reward in relation to each of the 1malaysia development berhad bond transactions.","res":"Order","sm":"GS Singapore paid a financial penalty in the amount of $122,000,000 in connection with the Singapore notice.","ab":"Goldman Sachs (Singapore)","firms":[361],"id":1017},{"d":"2020-10-22","di":"2020-10-22","dr":"2020-10-22","k":"Regulatory Action","rg":"Other","reg":"Monetary Authority of Singapore","san":"Other","os":"Letter of direction","st":"Final","dk":"6422 5358","al":"On October 22, 2020, Goldman Sachs (Singapore) pte (\"GS SINGAPORE\") received a letter of direction from the Monetary Authority of Singapore (the \"MAS letter\"), requiring GS SINGAPORE to appoint an independent auditor to review the effectiveness and sustainability of the remedial measures implemented by GS SINGAPORE following the Monetary Authority of Singapore's inspection.","res":"Order","sm":"The msa letter requires GS Singapore to appoint an independent auditor to review the effectiveness and sustainability of the remedial measures implemented by GS Singapore following the Monetary Authority of Singapore's inspection.","ab":"Goldman Sachs (Singapore)","firms":[361],"id":1018},{"d":"2020-10-21","di":"2020-10-21","dr":"2020-10-21","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut, Department of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":100000.0,"dk":"CO-20-8388-S","al":"On October 21, 2020, without admitting or denying the allegations, Janney Montgomery Scott LLC (\"Janney\") agreed to entry of an order alleging that Janney permitted a former employee to act as executor of a client's estate in contravention of written supervisory procedures. The consent order also alleged that Janney failed to timely produce records requested by the agency or amend the Form U-5 previously filed related to the former employee.","res":"Consent","sd":"N/a","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1019},{"d":"2020-10-20","di":"2020-10-20","k":"Regulatory Action","dk":"NA","ab":"Smith, Jameson, s","firms":[7691],"id":1020},{"d":"2020-10-07","di":"2020-10-07","dr":"2020-10-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine","st":"Final","fine":47500.0,"dk":"2018057742301","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $47,500. Fine paid in full on 10/27/2020.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1021},{"d":"2020-10-07","di":"2020-10-07","dr":"2020-10-07","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Undertaking","st":"Final","dk":"DOCKET NO. 20-019-B-HC","al":"The Board of Governors of the Federal Reserve System (\"FED\") identified significant ongoing deficiencies in implementation and execution by Citigroup with respect to various areas of risk management and internal controls, including for data quality management and regulatory reporting, compliance risk management, capital planning, and liquidity risk management.","res":"Order","sm":"Citigroup agreed to take certain affirmative actions/undertakings related to source of strength, Board oversight, risk management and internal controls, data quality management, compliance risk management, progress reports, approval and implementation, and designation of a primary contact.","ab":"Citigroup Inc.; Citigroup, Inc.","firms":[7059,119537],"id":1022},{"d":"2020-10-02","di":"2020-06-10","dr":"2020-10-02","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5040.0,"al":"On June 10, 2020, LMR received notification from the Swedish Financial Supervisory Authority (\"finansinspektionen\") that it had determined that LMR shall pay a final penalty fee of approximately £3,800 in relation to the delayed reporting of short positions in a Swedish listed stock on two occasions (May 2018, August 2018). In their notification the Swedish Financial Supervisory Authority noted the extenuating circumstances raised by LMR in submissions made by LMR's legal and compliance team that there had been a technical problem with LMR's email to the regulator's reporting email address and there had been a delay due to a UK public holiday.","res":"Other","sm":"The original penalty fee was reduced by 50% due to the long processing of the matter by the Swedish Financial Supervisory Authority and the extenuating circumstances noted above.","ab":"LMR Partners LLP","self":true,"firms":[159639],"id":1023},{"d":"2020-09-30","di":"2020-09-30","dr":"2020-09-30","k":"Regulatory Action","rg":"Other","reg":"Danish Financial Supervisory Authority","san":"Reprimand","st":"Final","dk":"6376-0270","al":"Winton Capital Management limited filed a short selling notification with the the Danish Financial Supervisory Authority on 12 July 2019. However, due to a rounding error, the short selling notification was reported as a position of 0.2% rather than 0.19% resulting in an erroneous notification.","res":"Decision","sd":"None","sm":"Further to issuing the reprimand letter, the Danish Financial Supervisory Authority determined that no further action was required. No information Filed","ab":"Winton Capital Management Ltd.","self":true,"firms":[130566],"id":1024},{"d":"2020-09-30","di":"2020-09-30","k":"Regulatory Action","rg":"Other","reg":"The Financial Supervisory Authority of Norway (\"Finanstilsynet\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"20/11055","al":"According to requirements imposed by the financial supervisory authority of norway (\"FSA norway\") related to the european securities markets authority EU regulation on short selling, The Mangrove Partners master fund, LTD. (the \"cayman master\") reported its net short position in the issued share capital of three norwegian-listed companies. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 on the trading day following passage of the reporting threshold. Inadvertently, and due to an administrative oversight, the cayman master reported its net short positions at 22:36 and 16:19 on the trading days following the passage of the reporting thresholds and included a typographical error in the notification on a third position which made it appear to be made subsequent to the deadline.","res":"Decision","sd":"As a \"no violation charge,\" Mangrove partners was not subject to any sanctions.","sm":"According to requirements imposed by the FSA norway the cayman master reported its net short position in the issued share capital of three norwegian-listed companies. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 (9:30 am est) on the trading day following passage of the reporting threshold (I.E., April 23, 2020, April 28, 2020 and May 16, 2020, respectively). Inadvertently, and due to an administrative oversight or typographical error, the cayman master, which is advised by New York-based Mangrove partners, reported its net short positions at 16:19 (10:19 am est) on April 23, 2020, at 22:36 (4:36 PM est) on April 28, 2020, and at 13:39 (8:39 am est) on May 16, 2020, respectively. As a result of the cayman master's failure to report its short position in a timely manner, the FSA norway has issued a warning to Mangrove partners as part of a no violation charge. No information Filed","ab":"The Mangrove Partners","firms":[162296],"id":1025},{"d":"2020-09-29","di":"2020-09-29","dr":"2020-09-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000000.0,"dk":"3-20094","al":"Between April 2015 and January 2016 (the \"relevant period\"), certain TRADERS (\"TRADERS\") on the U.S. treasuries trading desk at J.P. Morgan Securities LLC (the \"JPMS treasuries desk\") engaged in manipulative trading of U.S. TREASURY (\"TREASURY\") cash securities in the secondary market. Over the course of the relevant period, the JPMS treasuries desk TRADERS engaged in hundreds of manipulative trading \"events\" that generally involved placing bona fide or genuine orders to buy or sell a particular TREASURY security on one side of the market, while simultaneously or nearly simultaneously placing multiple, layered orders on the opposite side of the market to sell or buy that particular TREASURY security, which the trader did not intend to execute (\"non- bona fide\" or \"deceptive\" orders), in order to create a false appearance of buy or sell interest. The JPMS treasuries desk TRADERS entered these non-bona fide orders to induce other market participants to trade against JPMS's bona fide orders on the opposite side of the market at favorable prices or prices that were artificially raised or artificially depressed by the non-bona fide orders. After securing beneficially priced executions for their bona fide orders, the JPMS treasuries desk TRADERS typically canceled the non-bona fide orders. During the relevant period, this manipulative trading scheme operated as a fraud or deceit on numerous other market participants and resulted in the generation of illicit profits to JPMS, in violation of federal securities laws, including section 17(a)(3) of the secuties act.","res":"Settled","sm":"JPMS has submitted an offer of settlement that the commission has determined to accept. JPMS willfully violated section 17(a)(3) of the Securities Act. Accordingly, it is hereby ordered that JPMS cease and desist from committing or causing any violations and any future violations of section 17(a)(3) of the Securities Act; is censured; and shall pay disgorgement of $10,000,000, and a civil penalty of $25,000,000 to the commission.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1026},{"d":"2020-09-29","di":"2020-09-29","dr":"2020-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertakings","st":"Final","fine":436431811.0,"dk":"CFTC DOCKET NO. 20-69","al":"From at least 2008 through 2016, numerous traders on the precious metals and U.S. treasuries trading desks at JPMorgan chase bank, N.A., J.P. Morgan Securities LLC (\"JPMS\"), and JPMorgan Chase & Co. (collectively, \"JPM\") engaged in a manipulative and deceptive scheme by engaging in the practice of \"spoofing\" (bidding or offering with the intent to cancel the bid or offer before execution) while placing orders for futures contracts on a registered entity, resulting in significant benefit to themselves and harm to other market participants. By virtue of this conduct, JPM engaged in manipulation and attempted manipulation in violation of section 9(a)(2) of the act, 7 U.S.C. § 13(a)(2) (2018); for conduct occurring on or after July 16, 2011, engaged in spoofing in violation of section 4c(a)(5)(c) of the act, 7 U.S.C. § 6c(a)(5)(c) (2018); and for conduct occurring on or after August 15, 2011, engaged in manipulation and attempted manipulation in violation of section 6(c)(1) and 6(c)(3) of the act, 7 U.S.C. § 9(1), (3) (2018), and regulations 180.1(a)(1) and (3) and 180.2, 17 C.F.R. §§ 180.1(a)(1), (3), 180.2 (2019). Further, in conjunction with the above­referenced misconduct, JPMS failed to diligently supervise in violation of commission regulation 166.3, 17 C.F.R. § 166.3 (2019).","res":"Settled","sm":"Respondents JPMS, JPMCB and JPMC & co. have submitted an offer of settlement, which the commission has determined to accept. Accordingly, it is hereby ordered that the JPMS, JPMCB and JPMC & co shall cease and desist from violating sections 4c(a)(5)(c), 6(c) (1), 6(c)(3), and 9(a)(2) of the act and regulations 180.1(a)(1) and (3) and 180.2, and JPMS shall cease and desist from violating regulation 166.3. JPMS shall pay restitution of one hundred five million seven hundred forty-four thousand nine hundred six dollars ($105,744,906), jointly and severally with JPMC & co; a civil monetary penalty of four hundred thirty-six million four hundred thirty-one thousand eight hundred eleven dollars ($436,431,811), jointly and severally with JPMCB and JPMC & co; disgorgement in the amount of fifty one million seven hundred two thousand three hundred sixty dollars ($51,702,360), jointly and severally with JPMC & co; additionally, JPMCB and JPMC & co shall pay two hundred five million nine hundred ninety- twthousand one hundred two dollars ($205,992,102) in resitution and one hundred twenty million three hundred thirty-two thousand four hundred thirty dollars ($120,332,430) in disgorgement, jointly and severally; JPMS, JPMCB & JPMC & co shall comply with the undertakings set forth in the order.","ab":"JPMorgan Chase & Co.","firms":[79],"id":1027},{"d":"2020-09-29","di":"2020-09-29","dr":"2020-09-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertakings","st":"Final","fine":436431811.0,"dk":"CFTC DOCKET NO. 20-69","al":"The CFTC entered an order resolving an action against JPMorgan Chase & Co., an affiliated bank (the \"bank\") and an affiliated broker-dealer (the \"broker-dealer\") (collectively, \"JPM\"). According to the order, from at least 2008 through 2016, numerous traders on the precious metals and U.S. treasuries trading desks at the bank and the broker-dealer engaged in a manipulative and deceptive scheme by engaging in the practice of \"spoofing\" (bidding or offering with the intent to cancel the bid or offer before execution) while placing orders for futures contracts on a registered entity, resulting in significant benefit to themselves and harm to other market participants. By virtue of this conduct, JPM engaged in manipulation and attempted manipulation in violation of section 9(a)(2) of the act, 7 U.S.C. § 13(a)(2) (2018); for conduct occurring on or after July 16, 2011, engaged in spoofing in violation of section 4c(a)(5)(c) of the act, 7 U.S.C. § 6c(a)(5)(c) (2018); and for conduct occurring on or after August 15, 2011, engaged in manipulation and attempted manipulation in violation of section 6(c)(1) and 6(c)(3) of the act, 7 U.S.C. § 9(1), (3) (2018), and regulations 180.1(a)(1) and (3) and 180.2, 17 C.F.R. §§ 180.1(a)(1), (3), 180.2 (2019). Further, in conjunction with the above-referenced misconduct, the broker-dealer failed to diligently supervise in violation of commission regulation 166.3, 17 C.F.R. § 166.3 (2019). The bank and the broker­dealer do not control, nor are they controlled by, the adviser.","res":"Settled","sd":"The order directs JPM to cease and desist from violating sections 4c(a)(5)(c), 6(c)(1), 6(c) (3), and 9(a)(2) of the act, 7 U.S.C. §§ 6c(a)(5)(c), 9(1), (3), 13(a)(2) (2018), and regulations 180.1(a)(1) and (3) and 180.2, 17 C.F.R. §§ 180.1(a)(1), (3), 180.2 (2019). Additionally, the order requires the bank and JPMC & co. to pay restitution in the amount of $205,992,102, and the broker- dealer and JPMC & co. to pay additional restitution in the amount of $105,744,906. The order further requires JPM to pay a civil monetary penalty in the amount of $436,431,811. The order also requires the bank and JPMC & co. to pay disgorgement in the amount of $120,332,430 and the broker-dealer and JPMC & co. to pay disgorgement in the amount of $51,702,360.","sm":"Respondents JPM have submitted an offer of settlement, which the commission has determined to accept. Accordingly, it is hereby ordered that JPM shall cease and desist from violating sections 4c(a)(5)(c), 6(c)(1), 6(c)(3), and 9(a)(2) of the act and regulations 180.1(a)(1) and (3) and 180.2, and the broker-dealer shall cease and desist from violating regulation 166.3. The broker-dealer shall pay restitution of one hundred five million seven hundred forty-four thousand nine hundred six dollars ($105,744,906), jointly and severally with JPMC & co; a civil monetary penalty of four hundred thirty-six million four hundred thirty-one thousand eight hundred eleven dollars ($436,431,811), jointly and severally with the bank and JPMC & co; disgorgement in the amount of fifty one million seven hundred two thousand three hundred sixty dollars ($51,702,360), jointly and severally with JPMC & co; additionally, the bank and JPMC & co shall pay two hundred five million nine hundred ninety-two thousand one hundred two dollars ($205,992,102) in resitution and one hundred twenty million three hundred thirty-two thousand four hundred thirty dollars ($120,332,430) in disgorgement, jointly and severally; JPM shall comply with the undertakings set forth in the order.","ab":"JPMorgan Chase & Co.","firms":[20989,134776,135960],"id":1028},{"d":"2020-09-28","di":"2020-09-28","dr":"2020-09-28","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s), undertakings","st":"Final","fine":4500000.0,"dk":"20-66","al":"The CFTC entered into a settlement order with Citigroup Global Markets, inc., Citibank N.A. and Citigroup energy inc. (collectively, \"Citi\") settling an administrative action. The order found that Citi did not maintain adequate internal controls with respect to its preservation of audio and therefore failed to diligently supervise matters related to its business as a CFTC registrant. The CFTC found that Citi (a) failed to adequately staff the global voice operations (\"GVO\") group, including by failing to employ individuals with adequate technical knowledge; (b) GVO management did not take timely and appropriate steps to mitigate the risk posed by the audio preservation system's design flaw after being on notice of the problem; (c) did not have adequate procedures in place to document, understand, and test changes to the audio preservation system; and (d) did not have adequate procedures in place to ensure that Citi personnel - including legal and compliance personnel who relied on the audio preservation system in responding to regulatory requests - were apprised of important risks to the integrity of the information contained on the audio preservation system that were known to the GVO group. The order found that Citi violated CFTC regulation 166.3, 17 C.F.R. S. 166.3 (2019).","res":"Order","sm":"Citi consented, without admitting or denying any of the findings or conclusions, to cease and desist from violating CFTC regulation 166.3; to pay a civil penalty of $4,500,000; and to comply with the undertakings enumerated in the order.","ab":"Citibank N.A.","firms":[7059],"id":1029},{"d":"2020-09-24","di":"2020-06-18","dr":"2020-09-24","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service (\"FSS\"), South Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"None","st":"Final","fine":104575.0,"dk":"CAPITAL MARKET INVESTIGATION DEPARTMENT, INVESTIGATION TEAM 3 - 1076","al":"The south korean financial supervisory service claimed that on three occasions from 2018 to 2019 The Vanguard Group, Inc. (\"VGI\"), engaged in the sale of two korean-listed securities without corresponding ownership of the positions, a practice which is prohibited under south korean law.","res":"Decision & Order of Offer of Settlement","sd":"On October 12, 2020, $83,660 (KRW 96 million) was accepted as payment, which reflects a discount from the $104,575 (KRW 120 million) originally sought.","sm":"On September 24, 2020, the south korean financial services commission imposed an administrative fine in the amount of $104,575 (KRW 120 million) on vgi, in connection with three instances during 2018 and 2019 in which vgi sold two korean-listed securities without corresponding ownership of the position, a practice which is prohibited under south korean law.","ab":"The Vanguard Group, Inc.","self":true,"firms":[105958],"id":1030},{"d":"2020-09-17","di":"2018-11-14","dr":"2020-09-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure and civil penalty","st":"Final","fine":1700000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-20014","al":"On September 17, 2020, the SEC entered an order against GGHC, following the firm's offer of settlement. The SEC found that certain reviews of client accounts for potentially excessive trading were not conducted from 2017 through early 2018. The SEC also found that GGHC's chief compliance officer at the time, who was required by GGHC's policies to conduct the reviews, altered documents relating to the reviews, and produced these altered documents to the SEC staff on behalf of the firm. The SEC found that the firm willfully violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. GGHC neither admitted nor denied the SEC's findings.","res":"Settled","sd":"Solely for the purpose of settling this proceeding, GGHC consented to a cease-and-desist order, a censure, and to pay a $1.7 million civil monetary penalty, which was paid on September 17, 2020","sm":"Provided). The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12. No information Filed","ab":"Gilder Gagnon Howe & Co. LLC","self":true,"firms":[2002],"id":1031},{"d":"2020-09-08","di":"2020-09-08","dr":"2020-09-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":90000.0,"dk":"2017054220101","al":"It is alleged the firm submitted inaccurate or incomplete reportable order events (ROES) to OATS, failed to reasonably supervise for compliance with its OATS reporting requirements, and failed to reasonably respond to identified OATS reporting deficiencies. The findings state the firm transmitted desk reports including inaccurate desk type code and new order type events that failed to report an information barrier id, submitting desk reports coding its equity retail desk as desk type code of \"t\", indicating its trading desk received the relevant orders for execution. Since all orders sent through the firm's agency desk were routed to other market destinations for execution, the firm should have used the desk type code of \"a\" for agency when reporting these orders to OATS. The firm's written supervisory procedures (WSPS) did not require a review of the OATS data submissions to assess the accuracy of the desk type code and information barrier ids. The firm's revised WSPS failed to provide reasonable guidance on how the OATS review should occur and were not reasonably designed to achieve compliance with its OATS reporting obligations.","res":"Acceptance, Waiver & Consent(AWC)","sd":"He firm was censured, fined $90,000 and required to revise its WSPS with respect to OATS compliance.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1032},{"d":"2020-09-07","di":"2020-05-13","dr":"2020-09-07","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"Injunction, disgorgement and civil penalty","st":"Final","fine":2034446.0,"al":"The complaint alleges that ambassador advisors, LLC and its principals were negligent because they did not adequately disclose a conflict of interest, provide best execution, or have written policies or procedures, in connection with the selection of mutual funds that paid 12B-1 fees. The alleged claims were made under section 206(2), section 206(4) and rule 206(4)-7 of the Investment Advisers Act of 1940.","res":"Settled","sd":"On September 7, 2022, the court entered final judgments against ambassador and its principals. The judgments ordered: (1) MR. bostwick to pay $136,620 in disgorgement, $35,273 in prejudgment interest, and a $136,620 civil penalty; (2) MR. Kauffman to pay $349,395 in disgorgement, $95,972 in prejudgment interest, and a $349,395 civil penalty; (3) MR. young to pay $136,627 in disgorgement, $35,275 in prejudgment interest, and a $136,627 civil penalty; and (4) ambassador to pay a $622,642 civil penalty. In addition, the judgments ordered ambassador and its principals to correct and remove misleading statements from the firm's website and form ADV materials, as well as to send a corrective notice about the case to the firm's advisory clients","sm":"On December 20, 2021, the advisory firm was found to be in violation of section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-7 thereunder, which required the firm to adopt and implement written policies and procedures reasonably designed to prevent violation of the Advisers Act by it and its supervised persons. On March 23, 2022, registrant was found to have violated section 206(2) of the Investment Advisers Act of 1940.","ab":"Kauffman, Robert, Ernest","firms":[116978],"id":1033},{"d":"2020-09-02","di":"2020-09-02","dr":"2020-09-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution, other, civil, and administrative penalty/fines","st":"Final","fine":50000.0,"dk":"2016052124001","al":"Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that it, together with another member firm, failed to establish and maintain a supervisory system, and failed to enforce written supervisory procedures (WSPS), that were reasonably designed to achieve compliance with FINRA's suitability rule as it pertains to switches from variable annuities to investment company products. As a result the firm is alleged to have violated NASD rule 3010 and FINRA rules 3110 and 2010","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm entered into an AWC agreement with FINRA on September 2, 2020, fully resolving this matter, which included agreement to the entry of a censure against the firm, a fine payable to FINRA in the amount of $50,000, and restitution to the customers in the amount of $89,688.31, plus interest on that amount, as set forth in the agreement. Fine received by FINRA September 16, 2020.","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":1034},{"d":"2020-09-02","di":"2020-09-02","dr":"2020-09-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution, other, and civil and administrative penalty/fines","st":"Final","fine":625000.0,"dk":"2016052124001","al":"Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that it, together with another member firm, failed to establish and maintain a supervisory system, and failed to enforce written supervisory procedures (WSPS), that were reasonably designed to achieve compliance with FINRA's suitability rule as it pertains to switches from variable annuities to investment company products. As a result the firm is alleged to have violated NASD rule 3010 and FINRA rules 3110 and 2010","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm entered into an AWC agreement with FINRA on September 2, 2020, fully resolving this matter, which included agreement to the entry of a censure against the firm, a fine payable to FINRA in the amount of $625,000, and restitution to the customers in the amount of $1,355,499.19, plus interest on that amount, as set forth in the agreement. Fine received by FINRA September 16, 2020.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1035},{"d":"2020-09-01","di":"2020-09-01","dr":"2020-09-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":40000.0,"dk":"2018057286802","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it lacked a supervisory system, including WSPS, reasonably designed to detect and prevent the firm and its registered representatives from executing pre-arranged transactions. The findings stated that the firm did not have exception reports, trade alerts, or other supervisory mechanisms designed to enable its supervisors to identify potential pre-arranged transactions. Instead, the firm relied on its supervisors to detect and prevent such transactions as part of their daily review of thousands of transactions on trade blotters. Though the firm' s automated reviews of its trade blotters flagged some types of prohibited transactions for supervisory review, they did not flag pre-arranged transactions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On September 1, 2020, Stifel entered into a letter of acceptance, waiver, and consent (\"AWC\") with FINRA to settle allegations that, during the period of October 31, 2017 through February 27, 2020, the firm lacked a supervisory system, including written supervisory procedures (WSPS), reasonably designed to detect and prevent Stifel and its registered representatives from executing prearranged transactions in violation of municipal securities rulemaking board (MSRB) rule G-27. While not admitting or denying the allegations, the firm consented to a censure and monetary fine of $40,000 to settle the allegations. As indicated in the AWC, Stifel updated its supervisory system and WSPS regarding the cited supervisory deficiencies prior to the entry of the AWC.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1036},{"d":"2020-09-01","di":"2019-07-02","dr":"2020-09-01","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq","san":"Other","st":"Final","fine":25000.0,"dk":"2019.06.0052","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed, in 157 instances, to maintain a continuous two-sided trading interest during regular market hours at prices within certain percentages away from the nbbo and failed to maintain a continuing two-sided trading interest during the entire trading day required by Nasdaq rule 4613(a), for the review period October 1, 2018 through March 31, 2019. The violations occurred because of a system issue with the firm's order management system. The conduct also constitutes a violation of Nasdaq rules 2010a and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $25,000 (comprised of $12,500 for the violations of Nasdaq rule 4613(a) and $12,500 for the violations of Nasdaq rules 2010a and 3010)","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":1037},{"d":"2020-08-28","di":"2020-08-28","dr":"2020-08-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Restitution","os":"Fine","st":"Final","fine":350000.0,"dk":"2015045713304","al":"Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that it failed to reasonably supervise the activities of two former firm representatives, who recommended that many of their customers invest a substantial portion of their assets at the firm in high-risk energy securities. The representatives' conduct generated multiple red flags regarding overconcentration in the firm's customer accounts that raised suitability concerns that the firm failed to reasonably investigate. As a result the firm is alleged to have violated NASD rule 3010(a) and FINRA rules 3110(a) and 2010","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm entered into an AWC agreement with FINRA on August 28, 2020, fully resolving this matter, which included agreement to the entry of a censure against the firm, a fine payable to FINRA in the amount of $350,000, and restitution in the amount of $201,498 plus interest as set forth in the agreement. This matter is now final.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1038},{"d":"2020-08-21","di":"2020-06-12","dr":"2020-08-21","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"al":"The clearing house risk committee of the Chicago Mercantile Exchange alleged that the firm violated CME rule 971.A.1.","res":"Decision & Order of Offer of Settlement","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1039},{"d":"2020-08-12","di":"2020-08-12","dr":"2020-08-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution","st":"Final","fine":175000.0,"dk":"2019063917801","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Morgan Stanley Smith Barney LLC (the \"firm\") failed to reasonably supervise a registered representative who recommended short-term trades of corporate bonds and preferred securities in the accounts of ten customers in violation of NASD rule 3010 (for conduct before December 1, 2014), FINRA rule 3110 (for conduct on or after December 1, 2014) and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 12, 2020, Morgan Stanley Smith Barney LLC (the firm) became the subject of a letter of acceptance, waiver and consent (\"AWC\") issued by FINRA regarding allegations that Morgan Stanley Smith Barney LLC (the \"firm\") failed to reasonably supervise a registered representative who recommended short-term trades of corporate bonds and preferred securities in the accounts of ten customers in violation of NASD rule 3010 (for conduct before December 1, 2014), FINRA rule 3110 (for conduct on or after December 1, 2014) and FINRA rule 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure, fine in the amount of $175,000 and restitution to certain customers in the total amount of $774,574.08 plus interest.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1040},{"d":"2020-08-11","di":"2019-11-04","dr":"2020-08-11","k":"Regulatory Action","rg":"Other","reg":"Autorite Des Marches Financiers - Quebec Provincial Securities Regulator","san":"Other","os":"Administrative agreement","st":"Final","dk":"N/A","al":"Performing activities necessitating registration in the province of quebec.","res":"Other","sd":"N/a","sm":"In August 2020 Hillsdale concluded an administrative agreement with the quebec provincial securities regulator to resolve a situation where an employee of the firm was found to be performing activities necessitating registration in the province of quebec. Hillsdale paid the canadian dollar equivalent of usd$11,200, inclusive of back registration fees, and the situation was resolved. No information Filed","ab":"Hillsdale Investment Management Inc.","self":true,"firms":[137883],"id":1041},{"d":"2020-07-30","di":"2020-07-30","dr":"2020-07-30","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Bureau of Securities Regulation","san":"Cease and Desist","os":"Restitution and cost of investigation.","st":"Final","fine":400000.0,"dk":"I-2019000029","al":"The New Hampshire Bureau of Securities Regulation (\"BUREAU\") conducted an investigation against representative, daniel stokes, involving solicitation of unsecured promissory notes from LPL clients for a purported investment opportunity, which did not occur on LPL systems. The BUREAU concluded MR. stokes defrauded investors in furtherance of the false investment opportunity. In connection with this investigation, the BUREAU determined LPL Financial LLC failed to reasonably supervise MR. stokes, in violation of N.H. Rsa 421-b:4-412(d)(9).","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1042},{"d":"2020-07-22","di":"2020-07-22","dr":"2020-07-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"2015045603201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it (1) reported short sales to a trade reporting facility (TRF) without a required short sale indicator in violation of FINRA rules 6182 and 2010, (2) incorrectly marked principal sell orders as long sales, when the firm should have marked the orders as short sales in violation of rule 200(g) of Regulation SHO and FINRA rule 2010, (3) failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA rule 6182 and rule 200(g) of Regulation SHO, in violation of FINRA rules 3110 (for conduct occurring on or after December 1, 2014) and 2010 and NASD rule 3010 (for conduct occurring prior to December 1, 2014), (4) failed to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the execution or display of short sale orders at prices at or below the national best bid during a short sale circuit breaker, in violation of rule 201(b) of Regulation SHO, FINRA rules 2010 and 3110 (for conduct occurring on or after December 1, 2014) and NASD rule 3010 (for conduct occurring prior to December 1, 2014), and (5) reported certain non-media transactions in national market system equity securities to the FINRA/Nasdaq trade reporting facility with inaccurate capacity codes (the transactions were incorrectly reported as principal transactions, when they should have been reported as riskless principal transactions), in violation of FINRA rules 7230a and 2010 (for conduct occurring on or after December 15, 2008) and NASD rules 6130 and 2110 (for conduct occurring prior to December 15, 2008).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm was censured and fined $150,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1043},{"d":"2020-07-21","di":"2020-07-21","k":"Civil Judicial Action","san":"Disgorgement","os":"Money damages","st":"Pending","al":"Plaintiffs allege breach of fiduciary duty by defendants in connection with the investment of Kentucky retirement system pension assets in certain hedge fund investments.","ab":"Peden, David, Michael","firms":[133449],"id":1044},{"d":"2020-07-08","di":"2020-07-08","dr":"2020-07-08","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2800.0,"dk":"2016050809102","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, acting as a distribution participant in a covered security's offering, purchased shares of the covered security for the firm's proprietary account during the restricted period, in violation of rule 101 of Regulation M promulgated under the Securities Exchange Act of 1934. Nasdaq Stock Market LLC (Nasdaq) also alleged that, during the restricted period, the firm's supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 101, in violation of Nasdaq rules 3010 and 2010a. In particular, Nasdaq alleged that the firm's Regulation M written supervisory procedures manuals failed to establish a supervisory system to determine whether the cash desk communicated to the control room the need to place a security on the firm's restricted security list. The firm implemented procedures to address this deficiency following the restricted period.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm was censured and fined $2,800.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1045},{"d":"2020-07-08","di":"2020-07-08","dr":"2020-07-08","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq BX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2400.0,"dk":"2016050809101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, acting as a distribution participant in a covered security's offering, purchased shares of the covered security for the firm's proprietary account during the restricted period, in violation of rule 101 of Regulation M promulgated under the Securities Exchange Act of 1934. Nasdaq BX, Inc. (BX) also alleged that, during the restricted period, the firm's supervisory system, including its written supervisory procedures, was not reasonably designed to achieve compliance with rule 101, in violation of BX rules 3010 and 2110. In particular, BX alleged that the firm's Regulation M written supervisory procedures manuals failed to establish a supervisory system to determine whether the cash desk communicated to the control room the need to place a security on the firm's restricted security list. The firm implemented procedures to address this deficiency following the restricted period.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm was censured and fined $2,400.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1046},{"d":"2020-07-08","di":"2020-07-08","dr":"2020-07-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":875000.0,"dk":"2017052995901","al":"The Financial Industry Regulatory Authority (FINRA) alleged that Morgan Stanley Smith Barney LLC (the \"firm\") submitted at least 869 inaccurate blue sheets to the Securities and Exchange Commission and FINRA, misreporting information on at least 156,678 options transactions in violation of section 17(a)(1) of the Securities Exchange Act of 1934 (Exchange Act) and rules 17A-4(j) and 17A-25 thereunder, and FINRA rules 8211, 8213 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On July 8, 2020, Morgan Stanley Smith Barney LLC (the firm) became the subject of a letter of acceptance, waiver and consent (\"AWC\") issued by FINRA regarding allegations that firm submitted at least 869 inaccurate blue sheets to the Securities and Exchange Commission and FINRA, misreporting information on at least 156,678 options transactions in violation of section 17(a) (1) of the Securities Exchange Act of 1934 (Exchange Act) and rules 17A-4(j) and 17A-25 thereunder, and FINRA rules 8211, 8213 and 2010. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm accepted and consented to findings and the imposition of a censure and a fine in the amount of $875,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1047},{"d":"2020-07-07","di":"2020-07-02","dr":"2020-07-07","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine","san":"Other","os":"Fine and disgorgement of commissions","st":"Final","fine":2500.0,"dk":"20-16774","al":"Joseph ducote was transacting business in Maine on behalf of Caldwell Sutter Capital without being licensed as an agent in the state.","res":"Consent","sd":"Disgorgement of commissions of $3,686.78 fine of CSC for $2,500 fine of joseph ducote for $500","sm":"RESOLVED BY CONSENT AGREEMENT No Information Filed","ab":"Caldwell Sutter Capital, Inc.","self":true,"firms":[10489],"id":1048},{"d":"2020-07-07","di":"2020-07-07","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","st":"Pending","al":"Breach of contract and related claims arising from a purchase and sale agreement entered into in December 2019 relating to the sale of three commercial real estate properties. The court granted specific performance and ordered closing in March 2021, which was completed. Easterly's claims for tortious interference and civil conspiracy against cim were dismissed in April 2023. Claims against two south korean defendants were dismissed for lack of personal jurisdiction; easterly's appeal of that dismissal was voluntarily dismissed by joint stipulation of all parties in October 2025.","ab":"Consilium Investment","firms":[131934],"id":1049},{"d":"2020-07-07","di":"2020-07-07","dr":"2020-07-07","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services (\"DFS\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000000.0,"al":"In a consent order dated July 7, 2020 (the \"consent order\"), the New York state department of financial services (\"NY DFS\") found that Deutsche Bank AG (\"DBAG\"), DBAG New York branch (the \"NY branch\"), and Deutsche bank trust company americas (\"dbtca,\" together with DBAG and the NY branch, \"Deutsche bank\" or the \"bank\"), in connection with the bank's former relationship with jeffrey epstein and former correspondent banking relationships with danske bank a/s estonia branch (\"danske estonia\") and the federal bank of the middle east LTD. (\"FBME\"), conducted business in an unsafe and unsound manner and failed to maintain an effective and compliant anti-money laundering program. NY DFS found that the bank failed to adequately monitor the activity of MR. epstein and his related entities between August 2013 and December 2018 despite deeming MR. epstein a \"high risk\" client, thereby failing to detect and prevent suspicious transactions. In connection with the bank's correspondent banking relationship with FBME (terminated in July 2014), NY DFS found that the high-risk nature of the relationship, the high number of suspicious transactions, and other AML-related issues should have prompted the bank to exit the relationship before the U.S. Treasury department's financial crimes enforcement network named FBME as a foreign financial institution of primary money laundering concern in July 2014. In connection with the bank's correspondent banking relationship with danske estonia (terminated in October 2015), NY DFS found that the bank continued its relationship with danske estonia despite the high number of suspicious transactions, the history of high-risk scores the bank assigned to danske estonia, and the bank's discussions with danske estonia about danske estonia's AML policies and controls.","res":"Consent","sm":"On July 7, 2020, Deutsche bank entered into a settlement with the NY DFS. That settlement is reflected in a consent order issued by the NY DFS under New York banking law §§ 39 and 44 (the \"consent order\"). The consent order required the bank to continue to cooperate with an independent monitor appointed pursuant to a prior consent order with the NY DFS, dated January 30, 2017; to address the compliance failures alleged in the consent order within the timetables of the prior consent order; to pay a civil money penalty of $150,000,000, which was timely paid on July 10, 2020, and to cooperate with the NY DFS regarding the terms of the consent order.","ab":"Deutsche Bank AG,","firms":[300838],"id":1050},{"d":"2020-07-02","di":"2020-07-02","dr":"2020-07-02","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange and Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Registrant consented to entry of a cease-and-desist order, and agreed to pay a civil money penalty in the amount of $250,000. The","st":"Final","fine":250000.0,"dk":"3-19854","al":"On July 2, 2020, the SEC entered an order instituting administrative and cease-and-desist proceedings pursuant to section 9(f) of the Investment Company Act of 1940 (the \"Investment Company Act\") and sections 203(e) and 203(k) of the Investment Advisers Act of 1940 (the \"Advisers Act\"), making findings, and imposing remedial sanctions and a cease-and-desist order against registrant (the \"order\"). In the order, the SEC found that (1) between December 2014 and November 2015, registrant caused certain Franklin templeton funds it manages (the \"funds\") to invest in shares of three unaffiliated exchange-traded funds (\"ETFS\") in excess of the 10% investment limit under section 12(d)(1)(a)(III) of the Investment Company Act; (2) registrant did not implement certain of the funds' policies and procedures designed to prevent such violations, thereby causing the funds to violate rule 38A-1(a) of the Investment Company Act; and (3) in determining not to reimburse the funds for losses that resulted from the corrective sale of one of the ETFS by offsetting gains realized from the corrective sale of two other ETFS, registrant did not follow its policies and procedures and did not disclose material information to the relevant funds' board, thereby violating section 206(2) and section 206(4) and rule 206(4)-7 of the Advisers Act. Registrant later reported the losses to the funds' board and fully reimbursed the relevant funds for the losses including interest. Registrant neither admitted nor denied the SEC's findings.","res":"Consent","sd":"Registrant consented to entry of a cease-and-desist order, and agreed to pay a civil money penalty in the amount of $250,000. The SEC also imposed a censure on registrant.","sm":"Without admitting or denying the findings in the order, registrant consented to its entry. On July 2, 2020, the SEC entered the order. No information Filed","ab":"Franklin Advisers, Inc.","self":true,"firms":[104517,111361],"id":1051},{"d":"2020-07-02","di":"2020-07-02","dr":"2020-07-02","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Registrant consented to entry of a cease-and-desist order, and agreed to pay a civil money penalty in the amount of $75,000.","st":"Final","fine":75000.0,"dk":"3-19854","al":"On July 2, 2020, the SEC entered an order instituting administrative and cease-and-desist proceedings pursuant to section 9(f) of the Investment Company Act of 1940 (the \"Investment Company Act\") and sections 203(e) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order against registrant (the \"order\"). In the order, the SEC found that at various points between October 2013 and September 2016, registrant caused certain Franklin templeton funds it manages to invest in shares of two unaffiliated exchanged-traded funds in excess of the 3% investment limit under section 12(d)(1) (a)(I) of the Investment Company Act. Registrant neither admitted nor denied the SEC's findings.","res":"Consent","sm":"Fit within the space provided). Without admitting or denying the findings in the order, registrant consented to its entry. On July 2, 2020, the SEC entered the order.","ab":"Franklin Templeton Investments Corp.","self":true,"firms":[111364],"id":1052},{"d":"2020-06-26","di":"2020-03-31","dr":"2020-06-26","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"CBOT 19-1192","al":"On March 31, 2020, the CME Group market regulation department notified Goldman Sachs & Co. LLC (\"GSCO\") that it had completed its investigation into allegations that GSCO violated exchange rule 562. GSCO held a pro-rata share of mellon investment corporation's position excess for three business days on September 11, 2019, September 12, 2019, and September 13, 2019, before it was liquidated on September 16, 2019. The CME Group market regulation department alleges that GSCO failed to liquidate its pro- rata share in excess of limits or otherwise failed to ensure that its customer was in compliance with limits within a reasonable period of time. The above matter has now been referred to the CME Group market regulation's enforcement division. On June 15, 2020, a PANEL of the CBOT business conduct committee (\"PANEL\") concluded that GSCO had violated CBOT rule 562. In accordance with a settlement offer that became effective on June 17, 2020, the PANEL ordered GSCO to pay a fine in the amount of $15,000. GSCO neither admitted nor denied the rule violation upon which the penalty is based. The fine was paid in by GSCO by wire on June 26, 2020.","res":"Settled","sm":"In accordance with a settlement offer that became effective on June 17, 2020, the panel ordered gsco to pay a fine in the amount of $15,000. Gsco neither admitted nor denied the rule violation upon which the penalty is based. The fine was paid in by gsco by wire on June 26, 2020.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1053},{"d":"2020-06-23","di":"2020-06-23","dr":"2020-06-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Department of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; payment of $250,000 to be used at the discretion of the banking commissioner of the state of Connecticut","st":"Final","fine":150000.0,"dk":"CO-20-8249-S","al":"The commissioner alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPF&s\") violated section 36B-14 of the Connecticut uniform Securities Act (the \"act\") by maintaining inaccurate books and records. The commissioner also alleged that Merrill violated section 36B-31-6F of the regulations of Connecticut state agencies (the \"regulations\") by failing to enforce its established procedures for supervising the activities of its agents, investment adviser agents and Connecticut office operations that was reasonably designed to achieve compliance with applicable securities laws and regulations.","res":"Consent","sm":"The banking commissioner alleged that a former supervisor at Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&s) failed to supervise a former Connecticut-based agent. The agent allegedly modified trade tickets and engaged in unauthorized trading that resulted in financial harm to certain customers and allegedly caused MLPF&s to maintain inaccurate books and records. MLPF&s terminated the former supervisor and former agent and paid restitution of $450,000 to the Connecticut resident that suffered financial harm due to the actions of the former agent. Without admitting or denying any of the allegations or findings, MLPF&s entered into a consent order on June 23, 2020 in which it agreed to (I) cease and desist from violating section 36B-14 of the act and section 36B-31-6F of the regulations and to comply with the act, its regulations, and any order under the act; (II) pay an administrative fine of $150,000 to the state of Connecticut, and (III) pay $250,000 to the state of Connecticut to be used at the discretion of the banking commissioner for investor education, staff training, and education material.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1054},{"d":"2020-06-22","di":"2020-06-22","dr":"2020-06-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and restitution","st":"Final","fine":325000.0,"dk":"2018057508101","al":"During the period January 1, 2014 to May 24, 2016, J.P. Morgan Securities LLC, without admitting or denying the allegations, failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its obligations under NASD rule 3010(a) (for conduct prior to December 1, 2014, FINRA rule 310(a) (for conduct on and after December 1, 2014) and FINRA rule 2010, in connection with the sale of volatility-linked exchange traded products (\"volatility etps\").","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1055},{"d":"2020-06-22","di":"2020-06-15","dr":"2020-06-22","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":30000.0,"dk":"2019-08-00125","al":"On June 15, 2020, a letter of acceptance, waiver and consent (\"AWC\") from NYSE ARCA, Inc. (\"NYSE ARCA\") directed at Goldman Sachs & Co. LLC (\"Goldman\") was finalized. Without admitting or denying the findings, Goldman consented to the sanctions and to the entry of findings. The AWC states that Goldman violated NYSE ARCA rule 6.49-o(b) by effecting equity transactions after gaining knowledge of undisclosed terms and conditions of a customer order in the same options series. The findings state that a Goldman trader relayed facilitated cross orders for 800 call options of a certain options series to an NYSE ARCA floor broker that were systematized in six separate pieces at six different times, four 100 quantities and then two 200 quantities. The findings additionally state that the Goldman trader sold a total of 49,000 equity shares of the options series as hedges, and when doing so, however, Goldman sold more shares than needed to hedge the disclosed (or systemized) portions of the second through sixth facilitated options orders, therefore resulting in overhedges.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On June 15, 2020, an AWC from NYSE ARCA directed at Goldman was finalized. In the AWC, NYSE ARCA imposes the sanctions censure and a fine of $30,000 for a violation of NYSE ARCA rule 6.49-o(b). The fine was paid by Goldman by wire on June 22, 2020.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1056},{"d":"2020-06-17","di":"2016-08-18","dr":"2020-06-17","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Injunction and court order appointing compliance monitor","st":"Final","fine":9000000.0,"al":"The CFTC alleged that, with respect to the reporting of swap data, Deutsche Bank AG (\"Dbag\") failed to properly report and correct errors in real-time data, to correct errors and omissions in previously reported data, provide diligent supervision, and maintain an adequate business continuity and disaster recovery plan. The CFTC also alleged that DBAG violated a 2015 CFTC order that resolved a CFTC investigation into a different type of swap reporting error.","res":"Consent","sd":"Without admitting or denying the allegations, dbag agreed to a permanent injunction requiring it to comply with the 2015 CFTC order and restraining it from violating certain provisions of the commodity Exchange Act (\"CEA\") and CFTC regulations related to swap data reporting requirements, business continuity and disaster recovery planning, and supervision. Dbag also agreed to pay a $9,000,000 civil money penalty. The fine was paid on July 1, 2020.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":1057},{"d":"2020-06-15","di":"2020-06-15","dr":"2020-06-15","k":"Regulatory Action","rg":"State regulator","reg":"Office of Attorney General, State of Maryland","san":"Restitution","st":"Final","fine":20000000.0,"dk":"2016-0833","al":"Without admitting or denying liability, Wells Fargo & Company (WF&co) entered into a consent order in which WF&co was alleged to have violated §11­301(2) of the Maryland Securities Act, related to the creation, pooling, structuring, sponsorship, packaging, marketing, underwriting, sale or issuance of residential mortgage-backed securities (\"RMBS\") between January 1, 2005 and January 1, 2009. WF&co agreed to pay restitution of $20,000,000 to the state of Maryland within thirty (30) business days.","res":"Settled","ab":"Wells Fargo & Company; Wells Faro & Company","firms":[11025,19616],"id":1058},{"d":"2020-06-11","di":"2020-06-11","dr":"2020-06-11","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":64046800.0,"al":"On 11 June 2020, the FCA published a final notice imposing a penalty of £64,046,800 on Lloyds Bank PLC, bank of scotland PLC, and the mortgage business PLC ('the banks') for breaches of principles 3 and 6 of the authority's principles for businesses. These breaches were in relation to the handling of mortgage customers in payment difficulties or arrears between 7 April 2011 and 21 December 2015. As a result of these breaches, the FCA found that the banks put a large number of customers at risk of being treated unfairly. The banks agreed to resolve all issues of fact and liability and qualified for a 30% discount under the authority's executive settlement procedures. Were it not for this discount, the authority would have imposed a financial penalty of £91,495,400.","res":"Settled","ab":"Lloyds Bank PLC","firms":[161257],"id":1059},{"d":"2020-06-08","di":"2020-04-01","dr":"2020-06-08","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen - Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":34187.85,"dk":"FI DNR 17-17349","al":"On April 1, 2020, the Swedish financial supervisory authority (finansinspektionen - \"sfsa\") imposed a fine on Goldman Sachs & Co. LLC (\"GSCO\") in the amount of 315,000 Swedish krona (SEK). Sfsa alleges a violation of chapter 4 of the financial instruments trading act (SFS 1991:1980), in relation to a late disclosure of changes in major holdings of shares in micronic ab between June and September of 2017.","res":"Decision","sm":"Gsco paid the fine of 315,000 sek on June 8, 2020 to the sfsa by wire. While the actual payment of the fine was made in sek, using the Federal Reserve's foreign exchange rate of 1 usd: 9.2138 sek as of June 8, 2020, the equivalent U.S. dollar value was approximately 34,187.85 usd.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1060},{"d":"2020-06-05","di":"2016-12-09","dr":"2020-06-05","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","st":"Final","dk":"WTM/SM/IVD/ID1/7863/2020-21","al":"On December 9, 2016, the Securities and Exchange Board of India (\"SEBI\") issued a \"show cause notice\" (the \"notice\") under sections 11, 11b and 11(4) of the SEBI act, 1992, and regulations 3(b), (c), (d) and 4(1) of the SEBI (prohibition of fraudulent and unfair practice relating to securities market) regulations, 2003, addressed to Elliott advisors (HK) limited (\"EAHK\"), Elliott management corporation, Elliott associates, L.P., Elliott International, L.P., the liverpool limited partnership, mansfield (MAURITIUS) limited, suffolk (MAURITIUS) limited (together \"Elliott\") and astrazeneca pharmaceuticals ab sweden (\"az sweden\"). The notice was issued pursuant to SEBI's investigation into matters concerning a sale by az sweden of shares in astrazeneca pharma india limited (\"az india\") in a public offer for sale process (the \"ofs\") conducted in May 2013, and perceived connections with the subsequent intended privatization and delisting of az india that was announced on March 3, 2014 but was not executed. The notice set forth certain allegations, including that (I) Elliott and az sweden employed manipulative and deceptive devices by conducting fraudulent negotiations to influence the delisting price of az india; and (II) material information concerning such negotiations, the size of Elliott's overall exposure to az india, and its ability to influence the intended delisting process was concealed from retail investors.","res":"Order","sd":"See item 13 below.","sm":"On June 5, 2020, Elliott and az sweden received a written order in an administrative proceeding conducted under sections 11(1), 11(4) and 11(b) of the sebi act 1992 by sebi. The order relates to allegations by sebi that Elliott and az sweden employed manipulative and deceptive devices by conducting fraudulent negotiations to influence the delisting price of shares in az india. The delisting of az india was proposed by az sweden in early 2014 but did not take place. As noted above, the sebi order can be interpreted as saying that Elliott and az sweden did not comply with requirements under the sebi (prohibition of fraudulent and unfair practice relating to securities market) regulations, 2003. Elliott and az sweden were censured and directed to refrain from similar actions in the future. No monetary penalty was imposed. Elliott strongly disagrees with the order and the findings, considers them to be wholly without factual and legal foundation, and it remains Elliott's position that the activities of Elliott were lawful at all times.","ab":"Elliott International, L.P.","firms":[307151],"id":1061},{"d":"2020-06-04","di":"2020-06-04","dr":"2020-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Disgorgement; restitution","st":"Final","dk":"2017053494401","al":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\" or \"firm\") consented to the sanctions and to the entry of findings that it failed to provide accounts with mutual fund sales charge waivers and fee rebates to which customers were entitled through rights of reinstatement offered by mutual fund companies. The acceptance, waiver & consent (\"AWC\") finds that as a result, eligible customers paid approximately $6 million in excess sales charges and fees. The AWC also finds that the firm failed to establish, maintain and enforce a supervisory system and procedures reasonably designed to ensure that customers receive these sales charge waivers and rebates, relying primarily on individual registered representatives to determine customer eligibility and apply them manually without reasonable supervisory oversight. As a result of this and an unreasonable reliance on an alert, the firm failed to detect that its representatives did not provide accounts with sales charge waivers and rebates to which they were entitled pursuant to the rights of the reinstatement.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, Merrill lynch consented to the sanctions and to the entry of the findings that it failed to provide accounts with mutual fund sales charge waivers and fee rebates to which customers were entitled through rights of reinstatement offered by mutual fund companies. Merrill lynch was censured and ordered to pay restitution, plus interest, to affected customers in the total amount of $7,225,700.12. Specifically, eligible customers paid approximately $6 million in excess sales charges and fees during the period of April 2011 to April 2017. Prior to the effective date of the AWC, Merrill lynch paid full restitution, plus interest, to the affected customers and provided proof of payment and documentation of its methodology used to determine restitution to FINRA. In entering an AWC without a monetary fine, FINRA recognized the actions and extraordinary cooperation by Merrill lynch including: (1) engaging an outside consulting firm to conduct a complex analysis to identify potentially disadvantaged customers and calculate total remediation; (2) investigating the extent to which it did not provide rights of reinstatement; (3) promptly establishing a plan to provide remediation, notifying the disadvantaged customers, and paying restitution to affected customers; (4) promptly remediating supervisory deficiencies with respect to rights of reinstatement; and (5) providing substantial assistance to FINRA in its investigation.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1062},{"d":"2020-06-02","di":"2019-07-12","dr":"2020-06-02","k":"Regulatory Action","rg":"Other","reg":"The Portuguese Securities Market Commission (CMVM)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"SUMMARY PROCEEDING NO. 06/2016","al":"The portuguese securities market commission (\"CMVM\") has alleged that Goldman Sachs international (\"GSI\")willfully violated its duty to protect the market in alleged violation of articles 311 and 407 of the portuguese securities code. On June 2, 2020, the CMVM closed their investigation into GSI without issuing any formal charges for any violations of the portuguese securities code.","res":"Dismissed","sm":"The CMVM notified gsi that it was proposing to impose a fine in the amount of euro 50,000 (with an additional euro 50,000 suspended for 2 years). Gsi contested the fine. On June 2, 2020, the CMVM closed their investigation into gsi without issuing any formal charges for any violations of the portuguese securities code.","ab":"Goldman Sachs","firms":[361],"id":1063},{"d":"2020-05-28","di":"2020-05-08","dr":"2020-05-28","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2019-033","al":"On May 8, 2020, the ICE Futures U.S. (\"ifus\" or \"exchange\") market regulation department notified Goldman Sachs & Co. LLC (\"GSCO\") that it was issued a summary fine in the amount of $10,000 pursuant to ifus rule 21.02. The exchange alleges that in seven instances, GSCO appeared to have been in violation of ifus rule 6.15(a) when it failed to accurately submit reportable positions to the exchange.","res":"Consent","sm":"The fine imposed by ifus was in the amount of $10,000, which was paid in full by gsco by wire on May 28, 2020.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1064},{"d":"2020-05-28","di":"2020-05-28","dr":"2020-05-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":1750000.0,"dk":"2016050948201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that, from January 2012 through December 2016, it failed to establish and maintain a supervisory system, and failed to establish, maintain, and enforce WSPS, that were reasonably designed to achieve compliance with FINRA's suitability rule as it pertains to early rollovers of unit investment trusts (UIT). The findings stated that the firm's WSPS referenced a UIT switch letter that representatives could use when a client sold a position in a UIT before maturity to purchase another UIT or mutual fund. The purpose of the switch letter was to confirm a customer's understanding of the transaction switch as well as the related risks and expenses. Nonetheless, the WSPS did not provide guidance about when switch letters should be sent or how firm supervisors should monitor for potentially unsuitable patterns of early UIT rollovers. The firm used an automated surveillance alert to identify potential early UIT rollovers, as well as potential switches between uits and mutual funds (the switch alert). However, the switch alert failed to flag UIT switches. The firm discovered that the switch alert did not identify switches from one UIT to another. Despite this knowledge, the firm did not inform its branch managers that the switch alert was not functioning as intended. The firm later developed an alternative surveillance system to flag UIT-to-UIT switches. However, that alert was not reasonably designed to detect unsuitable UIT switches because it only flagged uits that were held for less than a year even if the UIT had a long-term maturity date. Furthermore, the alternative system later stopped functioning as intended, but the firm did not discover that fact until a later date. As a result, although the firm subsequently fixed the switch alert, its compliance department continued to use the firm's alternative system to identify UIT switches. The firm failed to identify that its representatives recommended potentially unsuitable early UIT rollovers, including series-to-series rollovers that may have caused customers to incur $1,891,188.13 in sales charges that they would not have incurred had they held the uits until their maturity dates. The findings also stated that the firm sent switch letters to customers that contained inaccurate or missing information about the costs that they incurred as a result of early UIT rollovers. The firm did not verify the accuracy of the information contained in certain of the switch letters, apart from ad hoc reviews conducted as part of the firm's branch inspection program. Certain UIT switch letters understated the sales charges associated with the switch, and others did not list any sales charge associated with the new UIT purchased by the customer, even though the switches resulted in the customers incurring new sales charges. Collectively, the switch letters disclosed sales charges of approximately $330,440, when the actual sales charges incurred by customers were more than $1,249,052.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In may of 2020 the firm entered into a letter of acceptance, waiver and consent (AWC) with FINRA whereby the firm, without admitting or denying any specific findings, consented to findings that the from January 2012 through December 2016 the firm failed to establish and maintain and enforce written supervisory procedures (WSPS) that were reasonably designed to achieve compliance with finras suitability rule as it pertains to early rollovers of unit investment trusts. As a result the firm violated NASD rule 3010; FINRA rule 3110 and FINRA rule 2010. Additionally, the firm consented to a further violation of FINRA rule 2010 in connection with the sending of \"switch letters\" to customers containing inaccurate information about the costs they incurred as the result of early uit rollovers. The firm agrees to pay a fine of $1.75 million and restitution in the amount of $1,891,188.13, plus interest. The FINRA staff did not require any remedial undertakings by the firm in the AWC. The firm has implemented various enhancements to its supervision and compliance oversight of early rollovers of uits which it believes addresses the alleged deficiencies identified by FINRA. Those enhancements include implementation of a switch alert notification system for early rollovers, a risk-based approach of compliance oversight for early rollover activity and a periodic \"lookback\" by the compliance department of early rollover activity by selected financial advisors.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1065},{"d":"2020-05-26","di":"2020-05-26","dr":"2020-05-26","k":"Regulatory Action","rg":"Other","reg":"The Options Clearing Corporation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2019-22","al":"OCC designated JPMS to participate in a default auction test on November 7, 2019; however, none of the JPMS designated bidders participated in the test in violation of OCC rule 218(d).","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the OCC's allegations, JPMS acknowledged the allegations and consented to the entry of a final decision and imposition of a monetary fine.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1066},{"d":"2020-05-22","di":"2014-06-16","dr":"2020-05-22","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Not applicable. Claim was dismissed.","st":"Final","al":"In June of 2014 and in August of 2014, two separate class action lawsuits were filed in the United States district court for the southern district of New York on behalf of investors in dnyvf against Davis Selected Advisers, L.P. and Davis Selected Advisers - N.Y., inc. (dnyvf's sub-adviser). The plaintiffs claim that the defendants (the \"Davis entities\") charged dnyvf excessive fees to manage dnyvf.","res":"Dismissed","sd":"Not applicable. Claim was dismissed.","ab":"Davis Selected Advisers LP","firms":[108674],"id":1067},{"d":"2020-05-22","di":"2020-05-22","dr":"2020-05-22","k":"Regulatory Action","rg":"Other","reg":"Securities & Exchange Commission","san":"Cease and Desist","os":"Censure, civil monetary penalty.","st":"Final","fine":60000.0,"dk":"3-19807","al":"With respect to the cameroon fund, TSP relied on the audited financials alternative to attempt to comply with the custody rule for the years 2014 through 2018. TSP attempted to engage a PCAOB registered firm to audit the cameroon fund's annual financial statements, but due to the nature of the agricultural assets of the cameroon fund and other extenuating circumstances, such as the political climate in cameroon, TSP was unable to do so. The settlement finds that the 2014 and 2015 audits were delivered 686 days and 927 days late, respectively, and that TSP failed to procure audited financials for the cameroon fund from 2016 through 2018. Accordingly, the settlement finds that TSP did not satisfy the requirements of the audited financials alternative in rule 206(4)-2(b)(4) for the cameroon fund for fiscal years 2014 through 2018 and was therefore obligated to comply with all of the requirements of the custody rule with respect to the cameroon fund during those years, which it also failed to do. TSP also notes that it has described these audit delays of the cameroon fund in its prior amendments to the form ADV. The settlement with the SEC also finds that TSP failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and rules thereunder. While TSP's written policies and procedures referenced the custody rule, TSP was aware of its obligations under the custody rule with respect to the cameroon fund, and TSP attempted to comply with the custody rule with respect to the cameroon fund, the settlement finds that TSP's policies were not reasonably designed to prevent violations of the custody rule because TSP was unable to actually comply with the custody rule as described above.","res":"Settled","sd":"On May 22, 2020 the SEC published a settlement agreement between TSP and the SEC. as part of the settlement, TSP has agreed to pay a $60,000 penalty, and accept a censure.","sm":"Without admitting or denying the findings, TSP has agreed to a cease and desist, censure, and a civil monetary penalty in the amount of $60,000. The cameroon fund is also no longer a client of TSP. No information Filed","ab":"TSP Capital Management Group, LLC","self":true,"firms":[131889],"id":1068},{"d":"2020-05-19","di":"2020-05-19","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Restitution","os":"Cease and desist, censure, review of supervisory procedures, engagement of independent compliance consultant, disgorgement,","st":"Pending","dk":"E-2019-0117","al":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1069},{"d":"2020-05-18","di":"2020-04-21","dr":"2020-05-18","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":101849.0,"dk":"FI DNR 18-3231","al":"By a decision made on April 21, 2020, finansinspektionen has decided that Armistice Capital, LLC shall pay a penalty fee of sek 1,000,000 (US $101,849) for the failure to report changes in holdings of certain shares within the time limit prescribed by law. The original filing trigger date was in March 2017. The registrant, upon discovery of the error, made a late filing with finansinspektionen in December 2017. The registrant has paid the fine.","res":"Decision","sd":"The registrant has paid sek 1,000,000 (US $101,849) to finansinspektionen.","sm":"On April 21, 2020, the Swedish Financial Supervisory Authority (Finansinspektionen) notified via letter to the registrant that it decided to impose fines of US $101,849 on the registrant for failing to report changes in holdings of certain shares within the time limit prescribed. The registrant has paid the fine to finansinspektionen.","ab":"Armistice Capital LLC","self":true,"firms":[168978],"id":1070},{"d":"2020-05-13","di":"2020-05-13","dr":"2020-05-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":150000.0,"dk":"2018058319801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it allowed an executive with its non-FINRA member affiliate to function as a principal in the firm's prime brokerage business without being registered with FINRA. FINRA also alleged that the individual was actively engaged in the management of the firm's prime brokerage business in the United States, and exercised overall management decision-making authority and that the firm allowed the individual to act as a principal of the firm, but did not ensure the individual was registered with FINRA as a principal in violation of NASD rule 1021 and FINRA rules 1220 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm was censured and fined $150,000. In addition, the firm agreed to certify to FINRA that the individual referred to in the AWC is not actively engaged in the management of the firm's securities business, or has obtained the requisite registrations.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1071},{"d":"2020-05-13","di":"2020-04-03","dr":"2020-05-13","k":"Regulatory Action","rg":"Other","reg":"California Department of Financial Protection and Innovation (Formerly, Department of Business Oversight)","san":"Revocation","os":"Administrative fine with reinstatement of lending license.","st":"Final","fine":6500.0,"dk":"FILE NO: 603L286","al":"The California lending license of this private fund client was temporarily revoked on April 3, 2020, due to an administrative oversight involving a delayed annual filing which was rectified allowing reinstatement of the license on May 13, 2020.","res":"Order","sd":"The California lending license of this private fund client was temporarily revoked on April 3, 2020, due to an administrative oversight involving a delayed annual filing which was rectified allowing reinstatement of the license on May 13, 2020, pursuant to a consent order. The entity paid an administrative penalty of $6,500 in connection with that reinstatement.","sm":"The California lending license of this private fund client was temporarily revoked on April 3, 2020, due to an administrative oversight involving a delayed annual filing which was rectified allowing reinstatement of the license on May 13, 2020, pursuant to a consent order. The entity paid an administrative penalty in connection with that reinstatement. No information Filed","ab":"Virage Master LP","firms":[167992],"id":1072},{"d":"2020-05-12","di":"2020-05-12","dr":"2020-05-12","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Censure","os":"Fine","st":"Final","fine":95000.0,"dk":"2017-11-00111","al":"Alleged violation of rule 16 in that Citigroup Global Markets Inc. failed to comply with its due diligence and best execution obligations with respect to its handling of a customer order on October 27, 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and fine of $95,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1073},{"d":"2020-05-12","di":"2020-05-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil and administrative penalty(IES)/fine(s)","st":"Final","fine":5000000.0,"dk":"3-19793","al":"The SEC alleged that Morgan Stanley Smith Barney LLC (\"MSWM\") willfully violated certain sections of the Investment Advisers Act of 1940, specifically sections 206(2) and 206(4) and rule 206(4)-7 thereunder.","res":"Order","sm":"On May 12, 2020, the SEC entered into a settlement order with MSWM settling an administrative action which relates to certain information provided in marketing and client communications to retail advisory clients in MSWM's wrap fee programs with third- party managers and MSWM's policies and procedures related to trades not executed at MSWM. In the applicable wrap fee programs, the third-party manager has the discretion to place orders for trade execution on clients' behalf at a broker-dealer other than Morgan stanley. MSWM permits managers to \"trade away\" from MSWM in this manner in order to seek best execution for trades. The SEC found that, from at least October 2012 through June 2017, MSWM provided incomplete and inaccurate information indicating that MSWM executed most client trades and that, while additional transaction-based costs were possible, clients did not actually incur them in the ordinary course. The SEC found that this information was misleading for certain retail clients because some wrap managers directed most, and sometimes all, client trades to third-party broker-dealers for execution, which resulted in certain clients paying transaction-based charges that were not visible to them. The SEC also found that, on occasion, wrap managers directed trades to MSWM-affiliated broker-dealers in which clients incurred transaction-based charges in violation of MSWM's affiliate trading policies without detection by MSWM. The SEC noted in the order that it considered certain remedial acts undertaken by MSWM in determining to accept the order, including MSWM enhancing its disclosures to clients, implementing training of financial advisors, enhancing relevant policies and procedures, and refunding clients' transaction based charges paid to Morgan stanley affiliates. The SEC found that MSWM willfully violated certain sections of the Investment Advisers Act of 1940, specifically sections 206(2) and 206(4) and rule 206(4)-7 thereunder. MSWM consented, without admitting or denying the findings and without adjudication of any issue of law or fact, to a censure; to cease and desist from committing or causing future violations; and to pay a civil penalty of $5,000,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1074},{"d":"2020-05-11","di":"2020-04-20","dr":"2020-05-11","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority (\"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":801000.0,"al":"BAFIN (the german financial regulator) reached a decision against bim UK for approximately 180 incorrect thresholds filings between August 2018 and October 2018 following brexit restructuring.","res":"Decision","sd":"Decision to impose a 744.000 euro ($801,000 usd) sanction against BlackRock investment management (UK) limited which was paid on May 11, 2020.","sm":"On April 20, 2020 BAFIN (the german financial regulator) reached a decision to impose a sanction of 744.000 euro ($801,000 usd) against BlackRock investment management (UK) limited for approximately 180 incorrect thresholds filings between August 2018 and October 2018 following brexit restructuring. Threshold information eported at the aggregate BlackRock, Inc. level was correct, and the market was not misled. The sanction was paid on May 11, 2020.","ab":"BlackRock, Inc; BlackRock,Inc","firms":[106614,107105,290336],"id":1075},{"d":"2020-05-06","di":"2020-03-03","dr":"2020-05-06","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"ICE CLEAR CREDIT MATTER NO. 2020-404B-004","al":"J.P. Morgan Securities LLC and J.P. Morgan Chase Bank, N.A. failed to submit twenty-seven (27) single name prices in violation of ICE Clear Credit rules 404(b) and 702(e).","res":"Settled","ab":"J.P. Morgan Chase Bank, N.A.","firms":[79],"id":1076},{"d":"2020-04-30","di":"2020-04-30","dr":"2020-04-30","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":125000.0,"dk":"20-005-S","al":"Pursuant to 9 v.s.a § 5602(a), the Vermont department of financial regulation (the \"department\") alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered a June 23, 2016 U.S. Securities and Exchange Commission (the \"SEC\") order instituting cease and desist proceedings pursuant to section 8a of the Securities Act of 1933, making findings and imposing cease and desist order (the \"SEC order\") against Merrill lynch. The conduct investigated related to the purchase by Vermont residents of strategic return notes linked to investable volatility index (\"SRNS\"). The department alleged that the SRNS were purchased by 26 Vermont investors and that the offering materials that were the subject of the SEC order were the same as those available to Vermont investors.","res":"Stipulation and Consent","sm":"Without admitting or denying the findings, except that Merrill lynch entered into a June 23, 2016 U.S. Securities and Exchange Commission (the \"SEC\") order instituting cease and desist proceedings pursuant to section 8a of the Securities Act of 1933, making findings and imposing cease and desist order (the \"SEC order\"), Merrill lynch entered into a stipulation and consent order with Vermont, consenting to sanctions and to the entry of findings that Merrill lynch may be disciplined under 9 V.S.A. § 5412(d)(12) (the \"act\") for being the subject of the SEC order. The firm was ordered to pay an administrative penalty of $125,000 within sixty days of the entry into the stipulation and consent order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1077},{"d":"2020-04-24","di":"2020-04-24","dr":"2020-04-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":650000.0,"dk":"3-19769","al":"The commission finds that from at least July 2012 through August 2017 (the \"relevant period\"), RBC disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC (\"eligible customers\") by failing to ascertain that they were eligible for a less expensive share class, and recommending and selling them more expensive share classes in certain open-end registered investment companies (\"mutual funds\") when less expensive share classes were available. RBC did so without disclosing that it would receive greater compensation from the eligible customers' purchases of the more expensive share classes. Eligible customers did not have sufficient information to understand that RBC had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC recommended and sold these eligible customers class a shares with an up-front sales charge, or class b or class c shares with a back-end contingent deferred sales charge (\"CDSC\") (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these eligible customers were eligible to purchase load-waived class a and/or no-load class r shares. RBC omitted material information concerning its compensation when it recommended the more expensive share classes. RBC also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the eligible customers' investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act.","res":"Order","sm":"RBC has submitted an offer of settlement, which the commission has determined to accept. RBC willfully violated sections 17(a) (2) and 17(a)(3) of the Securities Act. Accordingly, it is ordered that respondent 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. Respondent is censured and shall pay disgorgement of $2,607,676 with prejudgment interest of $631,331, plus a civil monetary penalty of $650,000.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1078},{"d":"2020-04-23","di":"2019-11-07","dr":"2020-04-23","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland","san":"Reprimand","st":"Final","fine":1683.5,"dk":"A 2019/31","al":"Eurex Deutschland initiated a sanction proceeding against Goldman Sachs international (\"GSI\") and a GSI sales trader on 7 November 2019 in relation to a cross trade in the Eurex product euro bund future. Eurex Deutschland alleged the cross trade was in violation of paragraph 2.6 of the conditions for trading at Eurex Deutschland.","res":"Decision","sm":"Gsi responded to Eurex Deutschland on 2 December 2019 setting out the firm's position that (a) the trade in question, which had a legitimate economic rationale, was intended to happen off-exchange using internal flattening controls but instead was inadvertently routed onto the exchange, (b) the named sales trader had no involvement in the decision to flatten the two positions internally that resulted in the on-exchange trade and so should be removed from the scope of the proceedings, and (c) the trade did not have any material impact on the market given that the price of the product in question moved by only eur 0.01 in the minute when the transaction took place (a move of just 0.00558%). On April 23, 2020, Eurex Deutschland issued a reprimand against gsi and required gsi to bear the cost of the regulatory proceeding for the amount of eur 2,000 (approximately usd 1683.50). Gsi paid the eur 2,000 on September 10, 2020.","ab":"Goldman Sachs","firms":[361],"id":1079},{"d":"2020-04-20","di":"2020-04-20","dr":"2020-04-20","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen - Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":365.0,"dk":"FI DNR 18-15926","al":"Sfsa alleged that on July 19, 2018, the adviser submitted a net short filing with respect to a swedish issuer ten minutes after the applicable filing deadline.","res":"Decision","sd":"N/a","sm":"The adviser provided documentation to sfsa demonstrating that the July 19, 2018 filing was submitted ten minutes late because the adviser's outside filing provider experienced technical difficulties. Sfsa acknowledged the extenuating circumstances and assessed a reduced fee equivalent to approximately $365. No additional conditions were imposed on the adviser. No information Filed","ab":"Tiger Global Management, LLC","self":true,"firms":[160318],"id":1080},{"d":"2020-04-17","di":"2020-04-17","dr":"2020-04-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure; disgorgement; undertaking","st":"Final","dk":"3-19753","al":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPFS\" or the \"firm\") consented to the sanctions and to the entry of findings that it breached its fiduciary duty and had inadequate discloses in connection with its mutual fund share class selection practices and the fees the firm received pursuant to rule 12B-1 under the Investment Company Act of 1940. The order finds that the firm charged 12B-1 fees instead of lower-cost share classes of the same funds for which clients were eligible and that the firm received 12B-1 fees in connection with these investments. The order also finds that MLPFS failed to disclose in its form ADV or otherwise its conflicts of interest related to its receipt of the 12B-1 fees and/or its selection of mutual fund share classes that pay such fees.","res":"Order","sm":"Merrill Lynch, Pierce, Fenner & Smith, incorporated (\"Merrill lynch\" or \"firm\"), along with other investment advisers who voluntarily participated in the SEC's share class selection disclosure initiative, consented to the entry of an order instituting administrative and cease-and-desist proceedings pursuant to sections 203(e) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (the \"order\") by the SEC, instituted pursuant to sections 203(e) and 203(k) of the Advisers Act, without admitting or denying the findings therein except those related to jurisdiction and the subject matter of the proceedings. The order entered against Merrill lynch alleged that the firm willfully violated section 206(2) of the Advisers Act as a result of its inadequate disclosure of conflicts of interest related to (a) its receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fee. The SEC did not did not impose a civil penalty against Merrill lynch in recognition of the fact that the firm self-reported the issue to the SEC. however, Merrill lynch was censured, ordered to cease and desist from committing or causing any violations of sections 206(2) of the Advisers Act, pay disgorgement of $297,394 and prejudgment interest of $27,882, and comply with the several undertakings of the terms of the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1081},{"d":"2020-04-16","di":"2019-12-06","dr":"2020-04-16","k":"Regulatory Action","rg":"Other","reg":"Commission de Surveillance du Secteur Financier","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"OPC.20/M207-JDU/JDU S626","al":"The Commission de Surveillance du Secteur Financier found that a sub-fund made available to non-US institutional investors by the firm and liquidated in March 2017, was not managed in accordance with the fund prospectus and therefore was not in compliance with certain provisions of Luxembourg law.","res":"Order","sd":"Monetary fine of $10,000","sm":"On April 16, 2020, Candriam paid the eur 10,000 fine in full.","ab":"Candriam, SociÉTÉ En Commandite Par Actions","self":true,"firms":[173355],"id":1082},{"d":"2020-04-09","di":"2012-01-01","dr":"2020-04-09","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services (\"DFS\")","fine":692000.0,"dk":"2020-0129-S","sm":"The New York State Department of Financial Services (\"DFS\") commenced an investigation for the period of 1/1/2012-5/31/2018. During its investigation, DFS identified a practice arising from the replacement of deferred annuity contracts with immediate income annuity contracts in violation of the disclosure and suitability requirements of New York regulations 60 and 187. It was alleged that massmutual sold or issued 692 replacement contracts to consumers without reasonable bases to believe the annuities at issue were suitable in some instances, and without providing consumers with the required annuitization information for replaced deferred annuities. It was also alleged that massmutual did not establish a supervisory system designed to achieve compliance with rule 187 in connection with the deferred-to-immediate replacements at issue. Massmutual agreed to pay a civil monetary fine in the amount of $692,000. Massmutual and DFS agreed upon restitution and remediation for the affected contract holders of the replacement contracts. Within 30 days, all affected contract holders or beneficiaries will be provided with notices and checks or other payment means approved by the DFS in the required amounts. Massmutual will provide DFS quarterly reports detailing the number of checks mailed, total amount or individual checks, and the number of checks deposited, undelivered, and/or not deposited.","ab":"Massachusetts Mutual Life","firms":[162264],"id":1083},{"d":"2020-04-02","di":"2020-04-02","dr":"2020-04-02","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"RSRH-20-5743","al":"Alleged violation of CME rule 526.f in that Citigroup Global Markets Inc. reported certain block trades late to the exchange on January 28TH and 30TH, 2020.","res":"Decision","sm":"Cgmi consented to a summary fine of $1,500","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1084},{"d":"2020-04-01","di":"2019-05-07","dr":"2020-04-01","k":"Regulatory Action","rg":"Other","reg":"Massachusetts","san":"Cease and Desist","os":"Accounting restitution fine","st":"Final","fine":286622.02,"dk":"2019-0050","al":"Sales practice violations involving short term trading in class a shares of mutual funds by an advisor who left Janney in 2018.","res":"Consent","sd":"The firm agreed to pay an administrative fine of $286,622.02. Payment was made on April 3, 2020.","sm":"On April 1, 2020, Janney entered into a consent order with the state of Massachusetts. Without admitting or denying any findings, the firm agreed to pay an administrative fine of $286,622.02 in connection with an alleged failure to supervise the mutual fund a share sales practices of a former financial advisor under section 204(a)(2)(j) of the mass general laws chapter 110a. The firm further agreed to provide an accounting of impacted customers and subsequently provide written offers of restitution; review its written policies and procedures related to trading of class a shares of mutual funds; accepted a censure and agreed to cease and desist from such alleged violations.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1085},{"d":"2020-03-27","di":"2019-10-25","dr":"2020-03-27","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan Department of Licensing and Regulatory Affairs Corporations, Securities & Commercial Licensing Bureau","san":"Censure","st":"Final","fine":50000.0,"dk":"339092","al":"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.","res":"Stipulation and Consent","sd":"$50,000 civil fine","sm":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1086},{"d":"2020-03-27","di":"2018-01-08","dr":"2020-03-27","k":"Regulatory Action","rg":"Other","reg":"Sweden's Finansinspektionen (Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":33500.0,"al":"In November 2017, Vulcan Value Partners notified the sfsa that its clients' holdings in a publicly traded swedish corporation had decreased below 5% of the corporation's shares. Vulcan self-reported to the sfsa that the notification was not provided within the timeframe required under sfsa regulations.","res":"Decision","sd":"On January 28, 2020, the sfsa issued an administrative fine of sek 340,000 (approximately usd 33,500). Vulcan did not appeal the matter and paid the fine in full on March 27, 2020.","sm":"On January 8, 2018, Vulcan Value Partners received a notice that the sfsa was initiating a matter based on Vulcan's self-reporting. On January 28, 2020, the sfsa issued an administrative fine of sek 340,000 (approximately usd 33,500). Vulcan did not appeal the matter and paid the fine in full on March 27, 2020. No information Filed","ab":"Vulcan Value Partners LLC","self":true,"firms":[151190],"id":1087},{"d":"2020-03-25","di":"2020-03-25","dr":"2020-03-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Censure, fine and written certification","st":"Final","fine":300000.0,"dk":"2015047758201","al":"FINRA alleged that MSSB violated FINRA rules 6730 and 2010 and MSRB rule G-14.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On March 25, 2020, the firm and FINRA entered into an AWC in connection with allegations that the firm failed to timely report certain fixed income transactions to the TRACE or the real-time reporting system (\"RTRS\") between July 1, 2015 and December 31, 2018. Without admitting or denying the findings, the firm consented to a censure and the imposition of a fine in the amount of $300,000. Additionally, the firm agreed to provide a written certification that the firm has reviewed its systems, policies and procedures governing the firm's trade reporting of fixed income securities and, as of the date of the certification, those systems, policies and procedures are reasonably designed to achieve compliance with FINRA rule 6730(a) and MSRB rule G-14.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1088},{"d":"2020-03-24","di":"2020-03-03","dr":"2020-03-24","k":"Regulatory Action","rg":"Other","reg":"Illinois Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":18000.0,"dk":"N/A","al":"The alleged violations included the following: failure to provide the \"notice of availability of the department of insurance\" and failure to provide beneficiaries with a reasonable written explanation of delay of claim payment beyond 45 days, as required by section 50 ill. Adm. Code 919.70(a)(2); and failure to notify beneficiaries of the availability of interest at the time of claim submission, as required by 215 ilcs 5/224(1)(I).","res":"Stipulation and Consent","sd":"On March 2, 2020, the Illinois Department of Insurance (IDI) issued a market conduct examination verified report and stipulation and consent order in connection with a market conduct examination of Teachers Insurance and annuity association of america (\"TIAA\"). Without admitting fault, liability, or wrongdoing, TIAA agreed to a stipulation and consent order (the \"consent order\") finding that it violated sections 50 ill. Adm. Code 919.70(a)(2) for not providing a \"notice of availability of the department of insurance\" and for not providing beneficiaries with a reasonable written explanation of delay of claim payment beyond 45 days; and violated 215 ilcs 5/224(1)(I) for not notifying beneficiaries of the availability of interest at the time of claim submission. The IDI imposed a civil forfeiture of $18,000 for TIAA.","sm":"This matter does not involve Nuveen Fund Advisors, LLC or Nuveen, LLC. No information Filed","ab":"Teachers Insurance and","firms":[104626,107168,155584,175092],"id":1089},{"d":"2020-03-23","di":"2020-03-23","k":"Civil Judicial Action","ab":"Todd, George, C","firms":[7691],"id":1090},{"d":"2020-03-19","di":"2020-03-19","dr":"2020-03-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":160000.0,"dk":"2015046601401","al":"Alleged violation of FINRA rules 7450, 2010, 6282, 3110, and 6191 and NASD rule 3010 in that Citigroup Global Markets Inc. failed to transmit certain reportable order events to the order audit trail system and improperly submitted certain route reports to OATS that the firm was not required to report from October 1, 2014 through August 4, 2017, submitted certain new order reports to OATS that did not require submission from June 11, 2012 through April 15, 2016, transmitted certain roes that contained inaccurate, incomplete or improperly formatted data to OATS from April 7, 2014 through October 31, 2016 and November 7, 2016 through January 9, 2017, submitted certain corresponding trade reports to FINRA's transaction reporting facility and OTC reporting facility that failed to include execution timestamps in milliseconds when the firm's system captured time in milliseconds from November 2014 through October 31, 2016, and the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws and regulations from June 11, 2012 through August 4, 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine of $160,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1091},{"d":"2020-03-09","di":"2020-03-09","dr":"2020-03-09","k":"Regulatory Action","rg":"State regulator","reg":"State of Kentucky Department of Financial Institutions","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":325000.0,"dk":"ADMINISTRATIVE ACTION NO. 2019-AH-00073","al":"On March 9, 2020, J.P. Morgan Securities LLC (\"JPMS\" or the \"respondent\") entered into a settlement with the Kentucky department of financial institutions (\"DFI\") resulting in the DFI issuing an administrative order (the \"order\"). The respondent consented to the entry of the order, which found that JPMS violated KRS 292.320, 808 kar 10:450§2(8)(c) and 808 kar 10:450§2(11)(a). The order found that JPMS negligently failed to disclose, both generally and in form advs filed with the DFI, that from 2008 to 2013: (a) it designed and operated a retail unified managed account program with a preference for proprietary mutual funds; (b) discounted pricing of services provided by an affiliate was tied to the amount of the program's assets that JPMS invested in proprietary mutual funds; and (c) certain proprietary mutual funds purchased for program clients offered less expensive share classes.","res":"Settled","sm":"Without admitting the facts, findings, and conclusions set forth in the order. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1092},{"d":"2020-03-03","di":"2020-02-14","dr":"2020-03-03","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3000.0,"dk":"RSRH-20-5733","al":"CME Group market regulation issued fine as a result of allocation errors following a trade on November 29, 2019, in violation of rule 854 (\"concurrent long and short positions\").","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1093},{"d":"2020-02-27","di":"2020-02-27","dr":"2020-02-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":35000000.0,"dk":"FILE NO. 3-19714","al":"The Securities and Exchange Commission (SEC) charged Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC with willfully violating section 206(4) of the Investment Advisers Act of 1940 (Advisers Act) and rule 206(4)-7 thereunder, failing reasonably to fulfill their supervisory responsibilities within the meaning of section 203(e)(6) of the Advisers Act and failing reasonably to fulfill their supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Securities Exchange Act of 1934 (Exchange Act).","res":"Order","sm":"The commission found that, from April 2012 through September 2019, the firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds (ETFS) without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFS. The commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The commission found that the firms willfully violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of section 203(e) (6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Exchange Act. The firms consented, without admitting or denying the findings contained in the order, to: (a) 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, (b) be censured, and (c) jointly and severally pay a civil monetary penalty in the amount of $35,000,000.","ab":"Wells Fargo Advisors; Wells Fargo Clearing","firms":[11025,19616],"id":1094},{"d":"2020-02-27","di":"2020-02-05","dr":"2020-02-27","k":"Regulatory Action","rg":"Other","reg":"Australian Securities and Investments Commission (ASIC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250500.0,"dk":"R20200000035305","al":"In Q1 2020, amp capital paid a penalty of $250,500 to comply with an infringement notice given to it by ASIC on 5 February 2020 in respect of alleged contraventions by amp capital of its obligations to accurately report information about its reportable transactions and positions under the ASIC derivative transaction rules (REPORTING) 2013. The alleged contraventions related to amp capital in its capacity as trustee of managed investment schemes and accordingly, as a counterparty to over the counter (OTC) derivatives. The alleged contraventions do not relate to amp capital in its capacity as investment manager for itself (in its trustee capacity) or to other amp capital managed funds or SMA clients. Amp capital has been in ongoing discussions with ASIC about the steps we are taking to investigate and rectify the deficiencies which have been identified in respect of our OTC derivative transaction REPORTING service. As our discussions with the regulator are confidential, we are unable to provide any further details.","res":"Other","ab":"Dexus Capital Investors Limited","self":true,"firms":[162793],"id":1095},{"d":"2020-02-21","di":"2020-02-21","dr":"2020-02-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":500000000.0,"dk":"NO. 3-19704","al":"Wells Fargo & Company (\"WFC\") violated section 10(b) of the Exchange Act of 1934 (the \"Exchange Act\") and rule 10B-5 thereunder with respect to its historical community bank sales practices and related disclosures.","res":"Order","sm":"WFC consented to the entry of the SEC order and agreed to pay a civil penalty of $500 million and to be enjoined from future violations of section 10(b) of the Exchange Act and rule 10B-5 thereunder. WFC also agreed to engage outside experienced securities counsel to conduct an assessment of the regulation d policies and procedures of WFC and certain of its subsidiaries and to present to the SEC on the implementation of recommendations made by outside counsel.","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1096},{"d":"2020-02-18","di":"2020-02-18","dr":"2020-02-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"2017053704501","al":"Due to system issues that arose during its transition between third-party order management systems, the firm failed to transmit roes to OATS. The findings stated that due to the same system issues, the firm transmitted roes containing inaccurate, incomplete, or improperly formatted data to OATS.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $30,000. Fine paid in full on 2/19/20.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that due to system issues that arose during its transition between third-party order management systems, the firm failed to transmit roes to OATS. The findings stated that due to the same system issues, the firm transmitted roes containing inaccurate, incomplete, or improperly formatted data to OATS.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1097},{"d":"2020-02-04","di":"2020-02-04","dr":"2020-02-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure; civil money penalty","st":"Final","fine":150000.0,"dk":"3-1968","al":"From 2014 to October 2019, Cannell Capital LLC failed to follow its written policies and procedures by not maintaining a list of securities that members, officers, and employees and their family household members were prohibited from trading after the firm came into possession of potential material nonpublic information. Cannell Capital LLC's written policies and procedures related to the handling of material nonpublic information were not reasonably designed to prevent misuse of material nonpublic information because they did not address any business-specific risks and lacked any guidance regarding when trading in securities should be restricted. As a result, Cannell Capital LLC violated section 204a of the Advisers Act.","res":"Settled","sd":"N/a","sm":"The firm consented to order instituting administrative and cease-and-desist proceedings, pursuant to section 203(e) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (the \"order\"), as required pursuant to the order, the firm paid a civil money penalty of $150,000 to the SEC within 14 days of the entry of the order. No information Filed","ab":"Cannell Capital LLC","self":true,"firms":[158371],"id":1098},{"d":"2020-01-29","dr":"2020-01-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":175000.0,"dk":"2017053034301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to reasonably supervise a former registered representative who excessively traded equity positions in accounts belong to an elderly customer. The findings stated that the customer was 88 years old when the trading commenced and that as a result of the excessive trading she paid at least $300,000 in commissions and other fees. The firm's computer program flagged the customer's accounts for high velocity; however, the firm did not reasonably address these flags. Following its investigation, the firm discharged the representative responsible for the customer's accounts. Ultimately, the firm paid $1 million in restitution to the customer in settlement of a complaint that she filed regarding the activity in her accounts.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1099},{"d":"2020-01-29","di":"2019-10-01","dr":"2020-01-29","k":"Regulatory Action","rg":"Other","reg":"Six Exchange Regulation AG, Swiss Listing Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":425059.38,"dk":"SAKO-RLE-IV/18","al":"SIX exchange regulation AG (\"SIX\"), the swiss listing authority upheld sanctions against Gam Holding AG relating to breaching ifrs accounting standards in connection with its acquisition of CANTAB capital partners LLP (\"CANTAB\") in 2016. In connection with this acquisition, gam holding entered into a contractual obligation to pay a share of future performance fees to the previous owners for an indefinite period of time. Gam holding did not recognize this contractual obligation as a financial liability in the consolidated income statement of the 2017 ifrs financial statements and instead disclosed this obligation as a contingent liability.","res":"Settled","sd":"Additional monetary fine of CHF 100,000 relating to costs of the fine.","sm":"Gam Holding AG held a different point of view in good faith of this technical accounting matter, due in part to external and independent expert advice. However, Gam Holding AG decided to accept the decision made by six's sanctions commission and pay the related financial penalty of CHF 400,000 (converted to usd 425,059.38) and costs of approximately CHF 100,000. As a result of this decision, Gam Holding AG is required to recognise the financial liability relating to the acquisition of cantab at fair value and has restated impacted historical comparative amounts in the following consolidated financial statements. No information Filed","ab":"Gam Holding AG","firms":[110458],"id":1100},{"d":"2020-01-29","di":"2019-10-01","dr":"2020-01-29","k":"Regulatory Action","rg":"Other","reg":"Six Exchange Regulation AG, Swiss Listing Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":425059.39,"dk":"SAKO-RLE-IV/18","al":"SIX exchange regulation AG (\"SIX\"), the swiss listing authority upheld sanctions against Gam Holding AG relating to breaching ifrs accounting standards in connection with its acquisition of CANTAB capital partners LLP (\"CANTAB\") in 2016. In connection with this acquisition, gam holding entered into a contractual obligation to pay a share of future performance fees to the previous owners for an indefinite period of time. Gam holdings did not recognize this contractual obligation as a financial liability in the consolidated income statement of the 2017 ifrs financial statements and instead disclosed this obligation as a contingent liability","res":"Settled","sd":"Additional monetary fine of CHF 100,000 relating to costs of the fine.","sm":"Gam Holding AG held a different point of view in good faith of this technical accounting matter, due in part to external and independent expert advice. However, Gam Holding AG decided to accept the decision made by six's sanctions commission and pay the related financial penalty of CHF 400,000 (converted to usd 425,059.38) and costs of approximately CHF 100,000. As a result of this decision, Gam Holding AG is required to recognise the financial liability relating to the acquisition of cantab at fair value and has restated impacted historical comparative amounts in the following consolidated financial statements.","ab":"Gam Holding AG","firms":[110670],"id":1101},{"d":"2020-01-20","di":"2020-01-20","k":"Regulatory Action","dk":"FILE NO. OBS 3809-A","ab":"Tosha, Stephen, Patrick","firms":[7691],"id":1102},{"d":"2020-01-16","di":"2020-01-16","dr":"2020-01-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"2017053173601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it misreported its short positions in equity securities that must be reported pursuant to FINRA rule 4560. The findings stated that the firm reported a total of 1,911 short positions totaling 23,640,682 shares but should have reported only 1,704 short positions totaling 21,157,936 shares. Thus, it overstated its short positions by a total of 2,482,746 shares and overstated the number of accounts with short positions by 207.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $90,000.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it misreported its short positions in equity securities that must be reported pursuant to FINRA rule 4560. The findings stated that the firm overstated its short positions and overstated the number of accounts with short positions.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1103},{"d":"2020-01-16","di":"2019-12-17","dr":"2020-01-16","k":"Regulatory Action","rg":"Other","reg":"Bank of Italy","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1447940.0,"dk":"BANK OF ITALY NO. 1526250/19","al":"Weakness in the AML customer due diligence and suspicious activity reporting processes. The shortcomings have been remedied.","res":"Settled","sd":"Shortcomings have been remedied and a dedicated action plan completed. The action plan was defined on the back of the weaknesses identified in 2018 by the Bank of Italy which led to a monetary fine of 1.3 million eur that has been paid by Banca Monte Dei Paschi Di siena S.P.A. Without challenging it in the court of appeal.","ab":"Banca Monte Dei Paschi Di","firms":[139138],"id":1104},{"d":"2020-01-14","di":"2020-01-14","dr":"2020-01-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":225000.0,"dk":"2015045325201","al":"Alleged violation of SEC rules 201(b) and 203(b) of Regulation SHO, FINRA rules 6182, 6624, 3110, and 2010 and NASD rule 3010 in that Citigroup Global Markets Inc. failed to obtain locates for certain short sale transactions and failed to establish, maintain and enforce written polices and procedures reasonably designed to prevent the execution or display of a short sale order in a covered security subject to a short sale circuit breaker at a price at or below the national best bid between June 2010 and September 2016 and failed to report accurately certain transactions to a FINRA trade reporting facility with a short sale or short sale exempt indicator and failed to establish, maintain and enforce a supervisory system, including supervisory procedures, with respect to SEC rule 201(b) of Regulation SHO, SEC rule 203(b)(1) or Regulation SHO, and accurate short sale transaction reporting between June 2012 and November 2016.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $225,000, and an undertaking to revise the supervisory system and written supervisory procedures","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1105},{"d":"2020-01-13","di":"2020-01-13","dr":"2020-01-13","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","st":"Final","fine":31666.67,"dk":"2017053129504","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $95,000, of which $31,666.67 shall be paid to the exchange.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1106},{"d":"2020-01-13","di":"2020-01-13","dr":"2020-01-13","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","st":"Final","fine":7500.0,"dk":"2017053129502","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $95,000, of which $7,500 shall be paid to the exchange.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1107},{"d":"2020-01-13","di":"2020-01-13","dr":"2020-01-13","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","st":"Final","fine":31666.66,"dk":"2017053129503","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $95,000, of which $31,666.66 shall be paid to the exchange.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1108},{"d":"2020-01-13","di":"2020-01-13","dr":"2020-01-13","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","st":"Final","fine":24166.67,"dk":"2017053129501","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $95,000, of which $24,166.67, shall be paid to the exchange.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1109},{"d":"2020-01-09","di":"2020-01-09","dr":"2020-01-09","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Commission","san":"Cease and Desist","os":"Censure, disgorgement, pre-judgment interest, and civil penalty","st":"Final","fine":1500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-19639","al":"On January 9, 2020, J.P. Morgan Securities LLC (\"JPMS\" or the \"respondent\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an administrative order (the \"order\"). The respondent consented to the entry of the order, which found that JPMS violated section 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The order found that JPMS negligently omitted to state from at least January 2010 through December 2015 that (a) it received greater compensation from eligible customers' purchases of more expensive mutual fund share classes, resulting in eligible customers not having sufficient information to understand that JPMS had a conflict of interest from sales of the more expensive share classes; and (b) the purchase of the more expensive share classes, when the customers were otherwise eligible for less expensive share classes, would negatively impact the overall return on the eligible customers' investments, in light of the different fee structures for the different fund share classes. The order also found that JPMS did not have adequate systems and controls in place to determine whether eligible customers were eligible to purchase the less expensive share classes.","res":"Settled","sm":"Solely for the purpose of settling this proceeding, the respondent consented to the order, without admitting or denying the findings set forth in the order. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1110},{"d":"2020-01-08","di":"2020-01-08","dr":"2020-01-08","k":"Regulatory Action","rg":"Other","reg":"Ohio Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3000.0,"dk":"N/A","al":"The Ohio Department of Insurance (\"department\") found LPL Financial LLC failed to timely report administrative actions to the department, in violation of section 3905.22(a) pursuant to title 39 of the revised code.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1111},{"d":"2020-01-03","di":"2020-01-03","dr":"2020-01-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"2016049250601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it executed a municipal securities' transaction with a customer in an amount below the issue's minimum denomination without an exception. The findings stated that the firm provided evidence that it offered to rescind the transactions to all the firm's customers that continued to hold the position. The findings also stated that the firm failed to disclose to its customer all material facts concerning some municipal securities transactions at or prior to the time of trade. Specifically, the findings stated that the firm failed to inform its customer, orally or in writing, that the municipal securities transaction was in an amount below the issue's minimum denomination and that this may adversely affect the position's liquidity.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $150,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1112},{"d":"2020-01-02","di":"2019-09-26","dr":"2020-01-02","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"FI DNR 17-12674","al":"Connor, clark & lunn investment management LTD.(\"CC&l\") failed to report a short position in eltel ab within the required time period. The reporting was due on July 6, 2017 and was submitted by CC&l's 3RD party service provider on July 7, 2017. The delay was the result of the service provider having incorrect shares outstanding information combined with time zone differences between CC&l (CANADA), the regulator (SWEDEN) and the service provider (AUSTRALIA). The late filing was identified by CC&l on July 6, 2017 and the report was filed by the service provider the following day.","res":"Decision","sm":"By a decision made on September 26, 2019, Finansinspektionen has decided that Connor, clark lunn investment management LTD. shall pay a penalty fee of sek 5 000 for the failure to report a new short position in eltel ab within the time limit prescribed by law. The appeal period for the penalty fee expired on October 17, 2019; an invoice for the penalty fee has been received and paid.","ab":"Connor Clark & Lunn Investment Management Ltd","self":true,"firms":[107557],"id":1113},{"d":"2020-01-02","di":"2019-09-26","dr":"2020-01-02","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"FI DNR 17-12670","al":"Connor, clark & lunn investment management LTD. (\"CC&l\") failed to report a short position in recipharma ab within the required time period. The reporting was due on July 10, 2017 and was submitted by CC&l's 3RD party service provider on July 12, 2017. The delay was the result of the service provider having incorrect shares outstanding information combined with time zone differences between CC&l (CANADA), the regulator (SWEDEN) and the service provider (AUSTRALIA). The late filing was identified by CC&l on July 11, 2017 and the report was filed by the service provider the following day.","res":"Decision","sm":"By a decision made on September 26, 2019, Finansinspektionen has decided that Connor, clark & lunn investment management LTD. shall pay a penalty fee of sek 5 000 for the failure to report a new short position in recipharm ab within the time limit prescribed by law. The appeal period for the penalty fee expired on October 17, 2019; an invoice for the penalty fee has been received and paid.","ab":"Connor Clark & Lunn Investment Management Ltd","self":true,"firms":[107557],"id":1114},{"d":"2019-12-26","di":"2019-12-26","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":200000.0,"dk":"2017053791901","al":"On December 26, 2019, FINRA issued a letter of acceptance, waiver and consent to J.P. Morgan Securities LLC which found that the firm failed to establish, maintain and enforce written supervisory procedures to take into account any changes in the authority of custodians of accounts established under the uniform gifts to minors act and/or the uniform transfers to minors act to effect transactions on behalf of the beneficiaries of those accounts, once the beneficiaries reached the age of majority. FINRA recognized the firm's extraordinary cooperation based upon the firm's review and enhancements to internal supervisory policies and procedures relating to utma accounts.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In connection with the AWC, the firm agreed to certify to FINRA that its policies, systems and procedures are reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules, including FINRA rule 2090.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1115},{"d":"2019-12-26","di":"2019-12-19","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":130000.0,"dk":"2017053432301","al":"On December 19, 2019, the Financial Industry Regulatory Authority (\"FINRA\") accepted a letter of acceptance, waiver and consent (\"AWC\") in which without admitting or denying the findings, Goldman Sachs & Co. LLC (\"Goldman\") consented to the sanctions and to the entry of findings. The findings issued by FINRA name a violation of municipal securities rulemaking board (\"MSRB\") rule g- 15(f) and state that Goldman effected on a discretionary basis customer sale transactions of municipal bonds in amounts lower than the minimum denominations of the respective issues. Goldman generally relied on data it received from third-party vendors to determine whether a transaction was below an issue's minimum denomination, and the violative transactions are primarily attributable to inaccuracies in that vendor data. Goldman has already voluntarily rescinded the violative transactions or otherwise reimbursed affected customers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 19, 2019 FINRA accepted an AWC in which FINRA imposes the sanctions censure and a fine of $130,000 for a violation of MSRB rule G-15(f). The fine was paid by Goldman by wire on December 26, 2019.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1116},{"d":"2019-12-26","di":"2019-12-26","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Undertakings","st":"Final","fine":300000.0,"dk":"2018058621001","al":"During the relevant time periods of January 1, 2014 through September 30, 2018, LPL Financial LLC (\"firm\") did not establish reasonable systems or procedures related to the obligation to timely transfer control over the custodial property to the beneficiary of uniform transfers to minors act (\"UTMA\") accounts. As a result, UTMA account custodians authorized transactions in at least 5,249 UTMA accounts held at LPL in which the beneficiaries had reached the age of trust termination. Accordingly, the firm failed to establish and maintain a system, and establish, maintain, and enforce written supervisory procedures with respect to its uniform gift to minors act and/or UTMA accounts.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1117},{"d":"2019-12-26","di":"2019-12-26","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":300000.0,"dk":"2018060039001","al":"Alleged violation of NASD rules 3010(a) and 3010(b) and FINRA rules 3110(a), 3110(b), and 2010 where Citigroup Global Markets Inc. allegedly failed to establish, maintain, and enforce supervisory systems and procedures to take into account any changes in the authority of custodians of uniform gift to minors act/uniform transfer to minors act accounts to effect transactions on behalf of the beneficiaries of those accounts from September 1, 2014 through September 6, 2018.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a $300,000 fine, and an undertaking to review the firm's policies, systems, and procedures regarding the supervision of custodial accounts and guardianship accounts where the beneficiary was a minor","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1118},{"d":"2019-12-26","di":"2019-12-26","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":300000.0,"dk":"2018059381801","al":"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 written supervisory procedures with respect to its uniform gifts to minors act and/or the uniform transfers to minors act (UTMA) accounts. The firm did not establish reasonable systems or procedures related to the custodians' obligation to timely transfer control over the custodial property to the beneficiary. As a result, UTMA account custodians authorized transactions in at least 15,366 UTMA accounts held at Merrill lynch in which the beneficiaries had reached the termination age.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 26, 2019, the firm agreed to enter into an acceptance, waiver & consent (AWC) with FINRA without admitting to denying the findings. In the AWC, 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 written supervisory procedures with respect to its uniform gifts to minors act and/or the uniform transfers to minors act (UTMA) accounts. The AWC finds that the firm did not establish reasonable systems or procedures related to the custodians' obligation to timely transfer control over the custodial property to the beneficiary. According to the AWC, the foregoing constituted violations of NASD rule 3010 (a) and 3010(b), and FINRA rules 3110(a), 3110(b), and 2010. Under the AWC, the firm was censured, fined $300,000, ordered to certify to FINRA within 180 days that it has completed a review of its policies, systems and procedures regarding the supervision of custodial and guardianship accounts for which the guardianship is defined by the age of the protected party, and ensure its policies, systems and procedures are reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1119},{"d":"2019-12-26","di":"2019-12-26","dr":"2019-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":300000.0,"dk":"2018060038701","al":"Without admitting or denying the findings, the firm consented to the entry of findings that it failed to establish and maintain a supervisory system, and failed to establish, maintain, and enforce written supervisory procedures with respect to its uniform gifts to minors act and/or the uniform transfers to minors act (UTMA) accounts. Specifically, the firm did not establish reasonable systems or procedures related to the custodians' obligation to timely transfer control over the custodial property to the beneficiary.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 26, 2019, without admitting or denying the findings, the firm consented to a censure, a fine of $300,000, and to the entry of findings that it failed to establish and maintain a supervisory system, and failed to establish, maintain, and enforce written supervisory procedures with respect to its uniform gifts to minors act and/or the uniform transfers to minors act (UTMA) accounts. The firm must also certify to FINRA that is has completed a review of its policies, systems and procedures regarding the supervision of custodial and guardianship accounts where the beneficiary is a minor and which terminate upon age of majority pursuant to state statute or a court order, and must certify that such policies, systems, and procedures are reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1120},{"d":"2019-12-23","di":"2019-12-19","dr":"2019-12-23","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Disgorgement","st":"Final","fine":15000.0,"dk":"CME 19-1168-BC","al":"In July 2019, accounts managed by gmo temporarily held positions in lean hog futures contract in excess of the position limits established by the Chicago Mercantile Exchange (\"CME\") for such contracts. While the overage was relatively small and promptly corrected the following day, the CME sanctioned gmo $15,000 for exceeding the position limits and required disgorgement of profits resulting from the positions held in excess of the limits.","res":"Decision","sd":"Fine of $15,000 and disgorgement of $314,160","sm":"In accordance with the settlement offer, gmo has been ordered to pay a fine in the amount of $15,000 and ordered disgorgement of the profit in the amount of $314,160 to be paid by January 7, 2020. No information Filed","ab":"Grantham Mayo van Otterloo & Co LLC","self":true,"firms":[106220],"id":1121},{"d":"2019-12-20","di":"2019-12-20","dr":"2019-12-20","k":"Regulatory Action","rg":"Department of Labor","reg":"South Dakota Division of Insurance, Department of Labor and Regulation","san":"Other","os":"For sanctions, refer to item 12 below.","st":"Final","al":"In connection with a complaint by a South Dakota public customer, the South Dakota Division of Insurance, Department of Labor and Regulation alleged that Edward jones failed to supervise a single financial advisor in connection with that financial advisor's recommendation of certain mutual funds to the customer in violation of the South Dakota Securities Act and FINRA rules 2010 and 3110.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1122},{"d":"2019-12-20","di":"2019-11-26","dr":"2019-12-20","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000000.0,"dk":"20-10","al":"On November 26, 2019, the Commodity Futures Trading Commission (\"CFTC\") issued an order requiring Goldman Sachs & Co. LLC (\"Goldman\") to pay a $1,000,000 civil monetary penalty and to cease and desist from further violations of certain CFTC regulations. During an investigation by the CFTC's division of enforcement (\"division\"), the division requested that Goldman produce certain audio recordings from January 2014. Goldman was unable to produce many of the recordings requested due to a malfunction which occurred during the course of a system upgrade which affected recordings of the phone lines of a trading and sales desk in one of Goldman's offices for twenty calendar days in January and February 2014. Goldman's inability to produce these recordings impeded the division's ongoing investigation, because the division was unable to obtain the information that should have been captured in many of the recordings through any other means. Based on the foregoing, the CFTC found that Goldman violated regulations 23.202(a)(1), (b)(1), and 23.203(b)(2), 17 C.F.R. §§ 23.202(a)(1), (b)(1) (2018), 23.203(b)(2) (2017).","res":"Order","sm":"Goldman submitted an offer of settlement, which the CFTC accepted. Without admitting or denying the violations, Goldman consented to the entry of the order by the CFTC, pursuant to which Goldman: (a) shall cease and desist from violating regulations 23.202(a)(1), (b)(1), and 1.31(b)(2), 17 C.F.R. §§ 23.202(a)(1), (b)(1), 1.31(b)(2) (2018); and (b) pay a civil monetary penalty in the amount $1,000,000. In addition, as part of the settlement, Goldman represented to the CFTC that it had made certain changes in its surveillance programs. The fine was paid by Goldman by wire on December 20, 2019.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1123},{"d":"2019-12-19","di":"2019-09-20","dr":"2019-12-19","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen - Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7430.13,"al":"On September 20, 2019 the Swedish financial supervisory authority (finansinspektionen - \"sfsa\") imposed an administrative fine on Goldman Sachs Group, Inc. (\"GS group\") in the amount of 70,000 Swedish krona (SEK) (approximately usd 7,200). Sfsa alleges a violation by GS group of chapter 6, section 3 a, subsection 1 of the financial instruments trading act due to a delay in notifying a relevant change in GS group's holding of shares and other financial instruments in fingerprint cards ab.","res":"Consent","sm":"GS group paid the fine of 70,000 sek on December 19, 2019 to the sfsa by wire. While the actual payment of the fine was made in sek, based on the foreign exchange rate of 1 usd: 9.4211 sek as of December 19, 2019, the equivalent U.S. dollar value was approximately 7,430.13 usd, which amount is reflected in item 12.a. Above.","ab":"Goldman Sachs Group, Inc.","firms":[361],"id":1124},{"d":"2019-12-19","di":"2019-09-20","dr":"2019-12-19","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Finansinspektionen - Sfsa)","st":"Final","fine":7430.13,"al":"On September 20, 2019 the Swedish financial supervisory authority (finansinspektionen - \"sfsa\") imposed an administrative fine on the Goldman Sachs Group, Inc. (\"GS group\") in the amount of 70,000 Swedish krona (SEK) (approximately usd 7,200). Sfsa alleges a violation by GS group of chapter 6, section 3 a, subsection 1 of the financial instruments trading act due to a delay in notifying a relevant change in GS group's holding of shares and other financial instruments in fingerprint cards ab.","res":"Consent","sd":"\"Goldman Sachs Group, Inc. paid the fine of 70,000 sek on December 19, 2019 to the sfsa by wire. While the actual payment of the fine was made in sek, based on the foreign exchange rate of 1 usd: 9.4211 sek as of December 19, 2019, the equivalent U.S. dollar value was approximately 7,430.13 usd, which amount is reflected in item 12.a. Above.\"","ab":"Goldman Sachs Group, Inc.","firms":[283221,286067],"id":1125},{"d":"2019-12-18","di":"2019-12-18","dr":"2019-12-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000000.0,"dk":"3-19624","al":"MetLife, Inc. previously disclosed errors in its accounting for reserves associated with certain annuities, and remediated these errors as of December 31, 2018. The U.S. Securities and Exchange Commission charged MetLife, Inc. with violating the books and records and internal accounting controls provisions of the federal securities laws relating to these errors. Without admitting or denying the commission's findings, MetLife agreed to pay a civil penalty.","res":"Settled","ab":"MetLife, Inc.","firms":[142463],"id":1126},{"d":"2019-12-10","di":"2019-11-13","dr":"2019-12-10","k":"Regulatory Action","rg":"Other","reg":"Australia Securities Exchange (Asx)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":34189.0,"dk":"2019001","al":"On November 13, 2019, the Australia securities exchange (\"ASX\") imposed a fine on Goldman Sachs Australia pty LTD (\"GSA\") in the amount of 50,000 australian dollars (AUD). ASX cited violations of ASX clear (FUTURES) operating rule 46.1 and rule 46.5 in relation to FUTURES clearing and the daily close out of back-to-back FUTURES positions, in particular for physically settled bank bills FUTURES contracts.","res":"Settled","sm":"The fine imposed by asx was in the amount of 50,000 aud, which was paid by gsa by wire on December 10, 2019. Asx intends to publish a public notice on 16 December, 2019 concerning the contravention.","ab":"Goldman Sachs Australia","firms":[361],"id":1127},{"d":"2019-12-10","di":"2019-08-28","dr":"2019-12-10","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"The final judgment specifies circumstances when Third Point must file a notification under the hart-scott-rodino antitrust","st":"Final","fine":609810.0,"al":"Three funds controlled by Third Point acquired the voting securities of dow inc. prior to its merger with E.I. Du pont de nemours & company. In connection with the acquisition of the dow shares, the three funds made the required HSR filings. Once the merger was finalized on August 31, 2017, the dow shares converted to shares of the newly formed dowdupont inc. according to the FTC's position, as a result of that conversion, the Third Point funds were required to make another HSR filing for the shares of the newly formed company. The three Third Point funds made corrective filings with the federal antitrust authorities on nov. 8, 2017, and the waiting period for those corrective filings expired on December 8, 2017.","res":"Judgment Rendered","sd":"On December 18, 2019, Third Point LLC paid $609,810 in full satisfaction of a single civil penalty ordered against three of the funds it manages. Third Point is also required to comply with the terms of the final judgment, described in section 13(b) above, during the five years starting on December 10, 2019, unless either (a) after three years from the date of entry, the final judgment is terminated upon notice by the DOJ to the court and to Third Point that the civil penalty has been paid and that the continuation of the final judgment is no longer necessary or in the public interest, or (b) a specified event occurs before the expiration of such five-year period, in which case the final judgment may be terminated upon the occurrence of such event and upon notice by the DOJ, to be provided in DOJ's sole discretion after receiving a request from Third Point to do so, to the court that the continuation of the final judgment is no longer necessary or in the public interest.","ab":"Third Point LLC","self":true,"firms":[137927],"id":1128},{"d":"2019-12-04","di":"2019-11-27","dr":"2019-12-04","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (CBOT)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"CBOT 19-1109-BC","al":"The Chicago board of trade (\"CBOT\") imposed a fine on Goldman Sachs & Co. (\"Goldman\") in the amount of $15,000. CBOT cited violations of CBOT rule 538.c. In relation to an exchange for related position (\"EFRP\") package executed in the ten -year Treasury note futures and options markets on July 19, 2018, where the related position components of the exchange for risk (\"EFR\") transaction did not have a reasonable degree of price correlation and did not have opposing market bias to the exchange component. Further, the related component of the exchange of option for option (\"EOO\") transaction was not reasonably equivalent to the exchange component. The EFRP package was therefore non-bona fide and in violation of CBOT rule 538.c.","res":"Settled","sm":"Without admitting or denying the rule violation or the factual allegations upon which the penalty is based, Goldman submitted an offer of settlement, which was accepted, and it became effective on November 27, 2019. The fine imposed by CBOT was in the amount of $15,000, which was paid by Goldman by wire on December 4, 2019.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1129},{"d":"2019-12-02","di":"2019-12-02","dr":"2019-12-02","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Other","os":"N/a","st":"Final","fine":15300.0,"dk":"2016048771303","al":"Without admitting or denying the findings, RBC Capital Markets, LLC (\"RBC\", the \"firm\", or \"respondent\") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1130},{"d":"2019-11-28","di":"2015-07-08","dr":"2019-11-28","k":"Civil Judicial Action","san":"Injunction","os":"Settled.","st":"Final","al":"This DRP describes civil litigation related to Elliott's (as hereinafter defined) decision not to tender its shares of norbert dentressangle SA (\"ND\") in a tender offer conducted by xpo logistics, inc. and xpo logistics France (collectively, \"xpo\"). Xpo has alleged that Elliott capital advisors, L.P. and certain funds managed by Elliott management corporation (together with their affiliates, \"Elliott\") are in violation of french law surrounding tender offers and that xpo would suffer significant damage as a result. Elliott held approximately 7.6% of the outstanding shares of ND. Elliott has alleged that xpo likely had taken or had imminent plans to take action that was manifestly contrary to the corporate interests of ND and the minority shareholders of ND in order to pursue the proposed merger and thereby ignore that xpo does not own 100% of ND's shares.","res":"Settled","sd":"Settled.","ab":"Elliott International, L.P.","firms":[307151],"id":1131},{"d":"2019-11-26","di":"2018-05-28","dr":"2019-11-26","k":"Regulatory Action","rg":"Other","reg":"Bank of Italy","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Carlyle Real Estate SGR s.p.a voluntarily agreed to pay a fine in the aggregate amount of 60,000 euros. All values referred to in","st":"Final","fine":60000.0,"dk":"1431635","al":"The Bank of Italy raised the below technical allegations against Carlyle Real Estate SGR S.P.A., a non-U.S. advisory affiliate that currently manages one real assets-related fund vehicle: - certain procedural shortcomings in carrying out the review of certain beneficial owners up certain investors' ownership chains (none of which resulted in the admission of any disqualified investors) and - in connection with the sale to a third party of a condominium unit of a residential property owned by a fund vehicle, the late filing of a suspicious activity report (I.E., report not made at the time of deposit, but rather in connection with the transaction closing).","res":"Other","sd":"Fine of 60,000 euros was paid by Carlyle Real Estate SGR s.p.a on January 9, 2020","sm":"Carlyle Real Estate SGR s.p.a voluntarily agreed to resolve the matter by paying a fine of 60,000 euros in the aggregate. There was no further action required to resolve the matter once payment was made on January 9, 2020.","ab":"Carlyle Real Estate SGR","firms":[111128],"id":1132},{"d":"2019-11-22","di":"2019-11-22","dr":"2019-11-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease-and-desist; and censure","st":"Final","fine":50000.0,"dk":"3-19605","al":"Alleged violation related to section 206(4) and rule 206(4)-7 of the Investment Advisers Act of 1940.","res":"Settled","sd":"Channing Capital Management LLC (\"Channing capital\") entered into a voluntary settlement resolution reached with the SEC that included a limited negotiated civil monetary penalty fine of $50,000, paid on December 3, 2019. Also the Channing capital agreed to a civil regulatory cease-and-desist order and related censure.","sm":"On November 22, 2019, Channing Capital Management LLC (\"Channing capital\") entered into a voluntary consent settlement with the SEC, without admitting or denying any SEC findings, for the purpose of voluntarily resolving claims that it had failed to appropriately implement its trade aggregation and allocation compliance policy/procedure regarding a certain portion of its block trades in violation of section 206(4) and SEC rule 206(4)-7 under the Investment Advisers Act of 1940. Specifically from January 2014 to January 2018, Channing capital's written trade aggregation and allocation policies and procedures required it to allocate the transaction costs associated with block trades on a pro-rata basis amongst all clients participating in the same block trade. A separate written compliance policy/procedure (as per SEC standards governing investment portfolio and trading compliance) required Channing capital to follow the requirements and restrictions set forth in each client's investment management agreement, including client trading-brokerage guidelines and restrictions or limitations placed on trading commissions or commission rates. 2 of Channing capital's then 35-45 institutional clients placed restriction limitations or caps on the amount they were willing to pay in commission rates for execution of their brokerage trades. In adhering to such clients' restrictions, Channing capital routinely conveyed those 2 clients' commission cap restrictions to executing brokers and requested that such brokers also observe lower commission rates of a half-cent to 1 cent per share for those 2 clients while permitting them to participate in certain block trades with Channing capital's other institutional clients. This practice resulted in 2 clients with a total of 4 client accounts participating in a certain portion of the same block trades while paying differential commission rates of a half-cent to 1 cent per share. This block trading practice was voluntarily ended and ceased as of mid-January 2018 (approximately 2 years ago), as Channing capital voluntarily changed its internal block trading practices to avoid and eliminate block trades being executed with differential commission rates. In reaching this settlement resolution, the SEC also took into account this voluntary corrective action along with the firm's other voluntary remedial steps promptly undertaken regarding this matter and the voluntary cooperation afforded to the SEC staff by the firm. The key terms of the voluntary settlement resolution required the firm to pay a civil penalty fine of $50,000 and to cease from committing or causing any future violations. The firm paid the agreed upon fine promptly after the settlement was approved and finalized by the SEC commission in Washington, D.C. No information Filed","ab":"Channing Capital Management, LLC","self":true,"firms":[128450],"id":1133},{"d":"2019-11-18","di":"2019-11-18","dr":"2019-11-18","k":"Regulatory Action","rg":"Other","reg":"De Nederlandsche Bank N.V.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35479.0,"dk":"N/A","al":"On November 18, 2019, De Nederlandsche Bank N.V. (\"DNB\") imposed a 31,875 euro administrative fine on Wilshire Associates europe B.V. (\"Wilshire europe\") for violating article 3:72, paragraph one, of the financial supervision act for failure to submit within the required time period its quarterly report for investment firms for the fourth quarter of 2018. Wilshire europe did not violate any other provisions of the financial supervision act in connection with this decision.","res":"Decision","sd":"Pursuant to the decision, DNB imposed an administrative fine of 31,875 euros to be paid within six weeks of resolution date. No portion of the penalty was waived. The administrative fine was paid on January 9, 2020.","sm":"The decision was final and no further action was taken by DNB upon payment of the administrative fine by Wilshire europe. No information Filed","ab":"Wilshire Associates","firms":[6210],"id":1134},{"d":"2019-11-08","di":"2019-11-08","dr":"2019-11-08","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil and administrative penalty(IES), undertakings, and restitution.","st":"Final","fine":10000000.0,"dk":"CFTC DOCKET NO 20-08","al":"The CFTC found that Wells fargo bank, N.A. (WFBNA) mispriced a foreign exchange transaction executed on behalf of a counterparty in August 2014, because WFBNA did not have a system in place to accurately track trades used to fill a counterparty's orders and did not implement procedures designed to ensure that accurate information was provided to the counterparty. Accordingly, the CFTC found that the bank violated section 4s(h)(1)(b) and (3)(c) of the Commodity Exchange Act, 7 U.S.C. SEC. 6s(h)(1)(b) and (3)(c) (2012), and regulations 23.4.02(a)(1)(I) and (2) and 23.433, 17 C.F.R. Secs. 23.402(a)(1)(I) and (2) and 23.433 (2019). Without admitting or denying the findings, WFBNA consented to entry of the CFTC's order.","res":"Order","ab":"Wells Fargo Bank, N. A..","firms":[11025,19616],"id":1135},{"d":"2019-11-07","di":"2019-11-07","dr":"2019-11-07","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil and administrative, penalty(IES)/fine(s), disgorgement, other - prejudgment interest","st":"Final","fine":1500000.0,"dk":"3-19599","al":"The SEC found that from at least July 2009 through December 2016, the firm, in connection with investment recommendations to certain retirement plan and charitable organization brokerage customers (\"eligible customers\"), recommended and sold the eligible customers more expensive share classes when less expensive share classes were available, contrary to the firm's representations to the eligible customers, due to three issues with its share class selection calculator. The SEC found that, in relation to the foregoing, the firm willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933.","res":"Order","sm":"The firm has completed full remediation of approximately 99% of the overcharges to customers, by crediting the accounts of current customers and mailing reimbursement checks or otherwise directing payments as instructed by former customers. Despite reasonable efforts, the firm is unable to locate and/or contact 226 former account holders, representing $45,758.99 in remediation proceeds. The firm has also corrected the flaws with its share class selection calculator.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1136},{"d":"2019-11-06","dr":"2019-11-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution; interest","st":"Final","dk":"2015044526701","al":"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 WSPS reasonably designed to supervise recommendations of particular share classses of 529 plans offered by state sponsors (referred to herein as the state 529 plans). The findings stated that the firm failed to have a reasonably designed supervisory system and WSPS regarding the sale of 529 plans, including the suitability of unit class recommendations. The firm's supervisory system, including WSPS, was not reasonably designed to ensure that its representatives were considering how the age of the beneficiary may factor into the unit class suitability determination in the context of 529 plan investments. The firm's supervisory system did not require registered representatives or supervisors to evaluate beneficiary age and the number of years until expected withdrawals, combined with the different fees and expenses of the available unit classes, to assess the reasonableness of the unit class recommendation. The firm's supervisory system also did not include reasonable measures to require registered representatives to consider sales charge discounts and/or waivers based on aggregate customer investments when making unit class recommendations. The firm's training materials did not provide guidance to its registered representatives on these issues and thus were also unreasonable. The findings also stated that the firm voluntarily adopted new policies and procedures concerning 529 plan unit class recommendations. Among other changes the firm generally limited its registered representatives to recommending class a units for 529 plan customers with designated benefficiaries under a certain age or customers investing $250,000 or more. The firm's customers remain free to direct their unit class selection. The firm also enhanced its training to detail unit class fees and expenses and implemented several compliance reports-altering supervisors to contributions outside the firm's unit class policies or class c unit contributions near or exceeding potential break point discounts. The firm also instituted an annual disclosure process through which it notifies certain 529 plan customers that they may benfit from a different unit class selection for future purchases.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm agreed to pay restitution estimated to be at least $4 million relating to the sale of class c units to certain state 529 plan customers. Firm customers invested in the state 529 plans sponsored by Illinois, Iowa, Michigan, Nebraska, Rhode Island, Washington, D.C., and Wisconsin will not be entitled to remediation under the AWC, due to the respective fee structures and/or share class conversion features of those plans. In resolving this matter without a monetary fine, FINRA credits the firm for its extraordinary cooperation, proposal of broad remediation to customers, and its implementation, prior to regulatory intervention of corrective measures including extablishing certain policies procedures and disclosures concerning unit class suitability with respect to 529 plans available for purchase through the firm. FINRA recognizes the firm's settlement with the state of Maine office of securities and the approximately $19 million in restitution provided under the consent order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated; Raymond James Financial","self":true,"firms":[705,7691],"id":1137},{"d":"2019-11-06","di":"2016-01-29","dr":"2019-11-06","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Other","os":"Special fee","st":"Final","fine":41450.0,"dk":"FI DNR 14-6113; 6882-18","al":"The firm self-reported to the sfsa the net short position in the shares of a single Swedish issuer. The filing was made inadvertently later than the next day filing deadline.","res":"Decision","sd":"The sfsa decided to require the firm to pay a special fee of 400,000 Swedish krona (approximately $41,450 usd).","sm":"Appeal was denied.","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":1138},{"d":"2019-11-06","di":"2018-01-25","dr":"2019-11-06","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Other","os":"Special fee","st":"Final","fine":518.0,"dk":"FI DNR 16-4010; 6883-18","al":"The firm self-reported to the sfsa the net short position in shares of a single Swedish issuer. The filing was inadvertently later than the next filing day.","res":"Decision","sd":"The sfsa decided to require the firm to pay a special fee of 5,000 Swedish krona (approximately $518 usd)","sm":"Appeal was denied.","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":1139},{"d":"2019-11-05","di":"2019-11-05","dr":"2019-11-05","k":"Regulatory Action","rg":"Other","reg":"The Options Clearing Corporation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2019-14","al":"The Options Clearing Corporation (OCC) found that the firm breached the letters of credit threshold limits in violation of OCC rule 604.02.","res":"Decision","sm":"Without admitting or denying the allegations contained in the charges, the firm consented to the entry of a final decision providing for the imposition of a sanction against the firm in the amount of $10,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1140},{"d":"2019-10-29","di":"2019-03-31","dr":"2019-10-29","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":37500.0,"dk":"2019.04.0041","al":"Without admitting or denying the findings, RBC Capital Markets, LLC (the \"firm\") consented to the sanctions and to the entry of findings that during the period February 14, 2017 through December 31, 2017, the firm violated Nasdaq rules 4613(a), 3010 and 2010a.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1141},{"d":"2019-10-29","di":"2019-10-29","dr":"2019-10-29","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Massachusetts, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":200000.0,"dk":"E-2016-0041","al":"The Commonwealth of Massachusetts, Securities Division alleged that the firm failed to supervise a financial advisor who engaged in excessive trading in the accounts of four Massachusetts investors.","res":"Consent","sm":"On October 29, 2019, Morgan Stanley Smith Barney LLC (firm) and the Commonwealth of Massachusetts securities division entered into a consent order in connection with allegations that, from January 1, 2010 through May 1, 2014, the firm failed to supervise a financial advisor who engaged in excessive trading in four investors' accounts. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to the imposition of an administrative fine of $200,000, and agreed to make offers of restitution totaling $182,500 to four Massachusetts investors.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1142},{"d":"2019-10-23","di":"2019-10-23","dr":"2019-10-23","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":9000.0,"dk":"STAR NO. 20160487713, FILE NO. USE-1710","al":"Without admitting or denying the findings, RBC Capital Markets, LLC (\"RBC\", the \"firm\", or \"respondent\") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1143},{"d":"2019-10-18","di":"2019-10-18","dr":"2019-10-18","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27000.0,"dk":"USE-1710 / STAR NO. 20160487713","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm (I) failed to record accurate order receipt times for ten of the twenty sampled manual customer option orders reviewed that were routed to and executed on CBOE; (II) failed to record accurate order transmission times for eight of the twenty sampled manual customer options orders reviewed that were routed to and executed on CBOE; (III) failed to record an accurate order receipt time for one of twenty-one sampled manual customer option orders that were routed to and executed (or partially executed) on CBOE; and (IV) failed to establish, maintain and enforce written supervisory procedures, and a system for applying such procedures, reasonably designed to prevent and detect violations of CBOE rule 15.1; and section 17(a) of the Exchange Act and rule 17A-3 thereunder, in connection with the conduct described. Violation of exchange rules 4.2, 4.24 and 15.1; section 17(a) of the Securities Exchange Act of 1934, as amended and rule 17A-3, thereunder. Sanction: a censure and a monetary fine of $27,000.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1144},{"d":"2019-10-17","di":"2019-10-17","dr":"2019-10-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2900000.0,"dk":"2015046652401","al":"Without admitting or denying the findings, the firm entered into a letter of acceptance, waiver and consent with FINRA that found that from March 2008 to June 2016, the firm failed to deliver prospectuses to customers in connection with approximately 165,000 ETF and etn purchases and at least hundreds of thousands of mutual fund purchases. The AWC also found that the firm failed to design, implement, and enforce a reasonable supervisory system, controls and procedures to comply with the prospectus delivery rules for ETFS, etns and mutual funds. RBC failed to have in place a system to supervise its manual coding of software to trigger the delivery of an ETF or etn prospectus. Although the firm instituted a surveillance procedure to identify prospectus delivery coding issues after discovering certain coding errors, RBC failed to properly implement that process. With respect to mutual funds, RBC relied upon third-party software to automatically code mutual fund purchases for prospectus delivery. Due to a design flaw, the software did not code certain mutual fund purchases for prospectus delivery as required. RBC's supervisory system included a written procedure to designate an employee to conduct periodic supervisory reviews to determine whether mutual funds were properly coded for prospectus delivery. The firm did not assign these supervisory duties. Therefore, these duties were not performed during the relevant period. As a result, issues with the coding was not discovered until FINRA's investigation in this matter. RBC failed to perform an audit, review or other testing to verify that it was delivering prospectuses. The firm also did not test the system modifications and surveillance procedures put in place to address the ETF and etn coding errors it had previously discovered. In determining the appropriate sanction in this matter, FINRA took into account (I) the firm's prior disciplinary history; (II) the more than eight years over which the violations occurred; (III) the extent of the supervisory deficiencies; (IV) the lack of supervisory controls and testing; (v) that the firm voluntarily undertook a comprehensive review of its ETF and etn prospectus delivery processes upon discovery of the issues and disclosed its findings from that exercise to FINRA; (VI) the firm's extensive testing of its non-ETF/etn prospectus delivery processes to assist FINRA in understanding the scope of the issue; and (VII) certain firm corrective actions cited in the settlement.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1145},{"d":"2019-10-02","di":"2019-05-14","dr":"2019-10-02","k":"Regulatory Action","rg":"Other","reg":"ICE Futures Europe","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":153912.5,"dk":"4140","al":"The ICE Futures Europe (\"the exchange\") conducted an investigation of the firm's pre- and post-trade controls. As a result of its findings in the investigation, the exchange alleges that the timing and nature of certain orders was manipulative, violating exchange rules A.11.1 (d), E.2.1(b), E.2.2 (a)(VI), (XIII) and (XIV), E.2.2A and G.20.","res":"Settled","sm":"The exchange's assertions were referred to the authorisation, rules and conduct (ARC) committee. Without admitting or denying the assertions, gsco entered a settlement agreement with the exchange. On October 4, 2019, the exchange issued a disciplinary notice: settlement of disciplinary proceedings against gsco, confirming the terms of the settlement were 1) on the occasion described, gsco had not acted in compliance with the exchange's rules, specifically rules A.11.1(d), E.2.2(a)(XIII) and (XIV), and G.20., and 2) gsco paid a total settlement amount of £125,000, inclusive of a discretionary 1/3 discount from £187,500. Gsco paid the £125,000 by submission of a wire on October 2, 2019.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1146},{"d":"2019-10-02","di":"2019-10-02","dr":"2019-10-02","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7138.0,"dk":"2016050933606","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1147},{"d":"2019-10-02","di":"2019-10-02","dr":"2019-10-02","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market -The Nasdaq Options Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5687.0,"dk":"2016050933605","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1148},{"d":"2019-10-02","di":"2019-10-02","dr":"2019-10-02","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6721.0,"dk":"2016050933604","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1149},{"d":"2019-10-02","di":"2019-10-02","dr":"2019-10-02","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":28271.0,"dk":"USRI-7935: STAR NO. 20160509336","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1150},{"d":"2019-09-30","di":"2019-09-30","dr":"2019-09-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Disgorgement","st":"Final","dk":"3-19553","al":"Ia release 5386, September 30, 2019: the Securities and Exchange Commission deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be instituted against Wedbush Securities, inc. (\"respondent\"). On the basis of this order and respondent's offer, the commission finds that these proceedings arise out of breaches of fiduciary duty and inadequate disclosures by the respondent in connection with its mutual fund share class selection practices and the fees it received. At times during the relevant period, respondent purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. Respondent received 12B-1 fees in connection with these investments. Respondent failed to disclose in its form ADV or otherwise the conflicts of interest related to (a) its receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. During the relevant period, respondent received 12B-1 fees for advising clients to invest in or hold such mutual fund share classes. As a result of the conduct, respondent willfully violated section 206(2) of the Advisers Act.","res":"Order","sd":"Wedbush shall cease and desist from committing or causing any violations and any future violations of section 206(2) of the Advisers Act. Wedbush is censured, shall pay disgorgement of $1,703,194.38 and prejudgment interest of $149,346.59, and shall comply with the undertakings enumerated in the offer of settlement.","sm":"Wedbush has submitted an offer of settlement which the commission has determined to accept. In view of the foregoing, the commission deems it appropriate, and in the public interest to impose the sanctions agreed to in Wedbush's offer. Accordingly, it is ordered that Wedbush shall cease and desist from committing or causing any violations and any future violations of section 206(2) of the Advisers Act. Respondent is censured, shall pay disgorgement of $1,703,194.38 and prejudgment interest of $149,346.59, and shall comply with the undertakings enumerated in the offer of settlement. Wedbush self-reported to the commission the violations discussed in this order pursuant to the division of enforcement's share class selection disclosure initiative (\"SCSD initiative\"). Accordingly, this order and Wedbush's offer are based on the information self-reported by Wedbush. Wedbush acknowledges that the commission is not imposing a civil penalty based upon Wedbush's self-report in the SCSD initiative.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1151},{"d":"2019-09-30","di":"2019-09-30","dr":"2019-09-30","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000000.0,"dk":"19-47","al":"It is alleged that the firm engaged in at least 385 non-competitive, fictitious wash exchange-for-physical transactions. It is further alleged that the firm failed to meet supervisory obligations, resulting in additional violations include failures to prepare and timely file quarterly risk exposure reports, failures to disclose material non-compliance issues, and failures to maintain and timely produce required records.","res":"Order","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1152},{"d":"2019-09-30","di":"2019-09-30","dr":"2019-09-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5509.0,"dk":"2016050933608","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1153},{"d":"2019-09-30","di":"2019-09-30","dr":"2019-09-30","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4098.0,"dk":"2016050933607","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1154},{"d":"2019-09-30","di":"2019-10-01","dr":"2019-09-30","k":"Regulatory Action","rg":"Other","reg":"United Kingdom Financial Services Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":28890000.0,"dk":"139793","al":"The FCA's enforcement division has concluded that, between 1 July 2008 and 30 September 2017, prudential failed to take reasonable care in relation to non-advised sales of annuities to existing customers who were approaching retirement and who may have been eligible for a better annuity rate on the open market than the one they got from prudential assurance company. The FCA found that prudential assurance company had failed to take reasonable care to organise and control its affairs responsibly and effectively, thus failing to treat customers fairly. It also found that the call documentation and incentives provided to front-line sales staff increased the risk of customer detriment.","res":"Consent","sm":"FCA enforcement have completed their investigation and published their findings on 30 September 2019. £23.9m fine, inc 30% discount for early settlement, to be paid by 14 October 2019. No information Filed","ab":"The Prudential Assurance","firms":[114527,283173,307488],"id":1155},{"d":"2019-09-24","di":"2018-10-22","dr":"2019-09-24","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia, State Corporation Commission, Division of Securities and Retail Franchising (\"Division\")","st":"Final","al":"The division alleges violation of rule 21VAC5-20-260 supervision of agents in that the firm failed to diligently supervise the activities of victor m. Dandridge, III (CRD #5884409). The division also alleges the firm failed to establish, maintain and enforce written procedures, specifically the frequent examination of all customer accounts to detect and prevent irregularities or abuses.","res":"Other","sm":"The division's 2/8/2019 letter to the firm stated that it would allow the firm to employ an independent third-party compliance company to conduct a review of the firm policies and procedures. The letter further stated that if the firm agreed to conduct the exam, \"the open case will be concluded by an affidavit signed by an authorized Thompson davis officer.\" The affidavit was signed by the CEO and returned to the division the same day. The firm was given a deadline of November 8, 2019, to engage a third- party to complete the aforementioned examination, with a copy of the report to be provided to the division within 60 days of exam completion. On September 24, 2019, the firm provided the division with the report and a summary of the results and any changes that were implemented. No information Filed","ab":"Thompson Davis & Co., Inc.","self":true,"firms":[41353],"id":1156},{"d":"2019-09-18","di":"2019-09-10","dr":"2019-09-18","k":"Regulatory Action","rg":"Other","reg":"ICE Futures US, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2019-032","al":"The market regulation department of ICE futures U.S., inc. (\"ICE\") determined that Goldman Sachs & Co. LLC (\"the firm\") violated ICE rule 2.22 by reporting inaccurate open interest for the September 2019 fcoj-a futures contract for the trade dates of August 29, 2019, August 30, 2019 and September 2, 2019. ICE imposed a fine on the firm in the amount of $10,000, which was paid by submission of a wire on September 18, 2019.","res":"Consent","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1157},{"d":"2019-09-17","di":"2019-09-17","dr":"2019-09-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censured, disgorgement, and civil money penalty.","st":"Final","fine":3000000.0,"dk":"3-19464","al":"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.","res":"Order","sd":"\"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","sm":"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.","ab":"Raymond James &; Raymond James Financial","firms":[705,149018],"id":1158},{"d":"2019-09-17","di":"2019-09-17","k":"Regulatory Action","dk":"19A-033-INS","ab":"Hancock, Elizabeth, Louisa","firms":[7691],"id":1159},{"d":"2019-09-17","di":"2019-09-17","dr":"2019-09-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure","st":"Final","fine":225000.0,"dk":"3-19467","al":"The Securities and Exchange Commission (SEC) alleged that the firm recommended 135 \"swap' transactions to its retail customers that appeared to provide no economic benefit to the customer. The SEC alleged that the firm willfully violated MSRB rules G-8, g- 17, G-19 and G-27 and section 15(b)(c)(1) of the Securities Exchange Act of 1934 (Exchange Act).","res":"Order","sm":"Without admitting or denying the findings, the firm consented to a censure, to cease and desist from committing or causing any violations and any future violations of section 15b(c)(1) of the Exchange Act and MSRB rules G-8, G-17, G-19 and G-27, and to pay a civil money penalty in the amount of $225,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1160},{"d":"2019-09-16","dr":"2019-09-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Civil and administrative penalty(IES)/fine(s), undertaking","st":"Final","fine":1100000.0,"dk":"FINRA AWC NO. 2015047127703","al":"On September 16, 2019, FINRA issued a letter of acceptance, waiver, and consent (\"AWC\") to J.P. Morgan Securities LLC (\"JPMS\") relating to the firm's disclosure of information on Form U5 in response to questions 7b and 7f. Specifically, the AWC found that the firm failed to (a) disclose on Form U5, or disclosed more than 60 days late, 89 internal reviews or allegations involving fraud, wrongful taking of property, or violations of investment-related statutes, regulations, rules or industry standards of conduct by the firm's current or former registered representatives; (b) establish and maintain reasonably designed supervisory systems and written supervisory procedures for disclosing information in response to questions 7b and 7f on Form U5; and (c) reasonably train or provide guidance to employees about the circumstances in which 7b and 7f disclosures were required. The AWC found that the firm violated article v, sections 3(a) and (b) of the FINRA by-laws of the corporation, FINRA rules 1122, 2010 and 3110 and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In connection with the AWC, the firm agreed to an undertaking to submit a certification regarding the implementation of reasonably designed procedures.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1161},{"d":"2019-09-16","di":"2019-09-16","dr":"2019-09-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure; monetary penalty","st":"Final","fine":2700000.0,"dk":"3-19458","al":"The order alleged that Stifel willfully violated the recordkeeping and reporting requirements of section 17(a)(1) of the Exchange Act and rule 17A-4(j) thereunder by failing to furnish promptly true and complete trading information in response to electronic blue sheet (\"EBS\") requests made by SEC staff over a period of approximately four years. In addition, the order alleged that Stifel willfully violated Exchange Act rule 17A-25 by failing to submit electronically certain securities transaction information to the SEC through the EBS system in response to requests made by the SEC.","res":"Order","sm":"In September 2019, an order instituting administrative and cease-and-desist proceedings, pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 and section 203(e) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (the \"order\") was entered against Stifel by the SEC in connection with Stifel's failure to submit complete and accurate data in response to electronic blue sheets (\"EBS\") requests from the SEC, resulting in the reporting of EBS that was incomplete or deficient. As a result of the order, Stifel was censured and ordered to (a) cease and desist from committing or causing any violations and any future violations of section 17(a)(1) of the Exchange Act and rules 17a- 4(j) and 17A-25 promulgated thereunder; and (b) pay a civil monetary penalty in the amount of $2,700,000 that was paid on September 18, 2019. As detailed in the order, Stifel engaged in voluntary remedial efforts to correct and improve its EBS process and control environment, including but not limited to increased compliance staff and remedial expertise, enhanced EBS submission review procedures and controls, and increased budgets for EBS compliance.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1162},{"d":"2019-09-10","di":"2019-09-10","dr":"2019-09-10","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking; conditions","st":"Final","fine":300000.0,"dk":"CFTC DOCKET NO. 19-21","al":"The Commodity Futures Trading Commission (\"commission\") found that for nearly three years, the firm, at that time a registered futures commission merchant, failed to promptly produce reliable audit trail data requested by the division of enforcement and failed to develop and diligently administer adequate procedures for responding to routine regulatory requests. In violation of section 4g of the act and regulations 1.31, 1.35 and 166.3.","res":"Other","sm":"Without admitting or denying any of the findings or conclusions, the firm consented to (1) cease and desist from violating section 4g of the act, 7 U.S.C. 6g, and regulations 1.31, 1.35, and 166.3, 17 C.F.R. 1.31, 1.35, and 166.3 (2018), (2) pay a civil monetary penalty for $300,000, and (3) comply with the conditions and undertakings set forth in the offer.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1163},{"d":"2019-09-06","di":"2018-12-10","dr":"2019-09-06","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen - Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15416.0,"dk":"FI DNR 17-142","al":"Balyasny Europe Asset management LLP (\"BEAM\")made a late submission of a net short filing notification to the swedish regulator sfsa.","res":"Decision","sd":"The total settlement amount of $15,416 was levied against the relying advisor Balyasny Europe Asset management LLP. The settlement amount was paid on November 5, 2020.","sm":"Sfsa determined that beam made a late net short position notification to the sfsa. Beam appealed the decision. However, the appeal was unsuccessful. The appeal was decided on 06 September 2019; however, beam was not notified of the decision. As a result, the matter was not concluded until such time beam was made aware of the final decision.","ab":"Balyasny Europe Asset","firms":[138111],"id":1164},{"d":"2019-09-05","dr":"2019-09-05","k":"Regulatory Action","rg":"Other","reg":"National Stock Exchange of India Limited","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Penalty levied for observation raised upon inspection conducted","st":"Final","fine":6950.0,"dk":"NOT APPLICABLE","al":"Nse vide its letter dated September 5, 2019 has communicated the decision made by the member selection committee (\"MSC\") of the exchange and levied a penalty of RS.5,00,000/- ($6950) for continued to remain connected to the fallback / secondary server of the exchange through the co-location facility provided during May 2012 to July 2014. Matter closed","res":"Settled","sd":"Monetary fine paid RS. 5,00,000/- ($6950)","ab":"JM Financial Services Limited","firms":[293667],"id":1165},{"d":"2019-09-04","di":"2017-05-02","dr":"2019-09-04","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority of Germany (Bundesanstalt FÜR Finanzdienstleistungsaufsicht ­ \"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":882000.0,"dk":"GZ: WA 17-WP 3120-2016/0060","al":"On May 2, 2017 Federal Financial Supervisory Authority of Germany (Bundesanstalt FÜR Finanzdienstleistungsaufsicht ­ \"BAFIN\") has alleged certain breaches by Goldman Sachs international (\"GSI\") in May 2016 of sections 21(1) and 25(1) of the german securities trading act (wertpapierhandelsgesetz - \"WPHG\") as a result of GSI's late submission of a shareholder voting rights notification. On August 12, 2019 BAFIN imposed an administrative fine on GSI in the amount of 800,000 euros for a breach of section 130(1) of the german act of breaches of administrative regulations in conjunction with section 25(1) of the german securities trading act. This fine concluded cases wa 17-WP 3121-2017/0003 and wa 17-WP 3120-2016/0060.","res":"Settled","sm":"The fine imposed by BAFIN was in the amount of 800,000 eur, which was paid by gsi by wire on September 4, 2019.","ab":"Goldman Sachs","firms":[361],"id":1166},{"d":"2019-09-04","di":"2017-09-19","dr":"2019-09-04","k":"Regulatory Action","rg":"Other","reg":"BAFIN - the Federal Financial Supervisory Authority of Germany","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":882000.0,"dk":"GZ: WA 17-WP 3121-2017/0003","al":"On September 19, 2017 federal financial supervisory authority of Germany (bundesanstalt fÜr finanzdienstleistungsaufsicht ­ \"BAFIN\") has alleged certain breaches by Goldman Sachs international (\"GSI\") in March 2017 of sections 21(1) and 25(1) of the german securities trading act (wertpapierhandelsgesetz - \"WPHG\") as a result of GSI's late submission of a shareholder voting rights notification. On August 12, 2019 BAFIN imposed an administrative fine on GSI in the amount of 800,000 euros for a breach of section 130(1) of the german act of breaches of administrative regulations in conjunction with section 25(1) of the german securities trading act. This fine concluded cases wa 17-WP 3121-2017/0003 and wa 17-WP 3120-2016/0060.","res":"Settled","sm":"The fine imposed by BAFIN was in the amount of 800,000 eur, which was paid by gsi by wire on September 4, 2019.","ab":"Goldman Sachs","firms":[361],"id":1167},{"d":"2019-08-30","di":"2019-08-23","dr":"2019-08-30","k":"Regulatory Action","rg":"State regulator","reg":"Ontario Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10338117.0,"al":"Failure to have sufficient supervision and controls in its FX trading business.","res":"Decision & Order of Offer of Settlement","ab":"Royal Bank of Canada","firms":[31194],"id":1168},{"d":"2019-08-28","di":"2019-08-22","dr":"2019-08-28","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":36592.0,"dk":"USRI-7935 / STAR NO. 20160509336","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1169},{"d":"2019-08-28","di":"2019-08-22","dr":"2019-08-28","k":"Regulatory Action","rg":"Cboe","reg":"CBOE C2 Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5984.0,"dk":"USRI-7935 / STAR NO. 20160509336","al":"Without admitting or denying the findings, RBC capital makets, LLC (\"RBC\" or the \"firm\") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1170},{"d":"2019-08-27","di":"2019-08-27","dr":"2019-08-27","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"2019-023","al":"Alleged violation of ICE rule 6.15(a) in that Citigroup Global Markets Inc. reported inaccurate large trader date for the July 2019 sugar no. 11 futures contract for trade date June 27, 2019 and for the March 2019 sugar no. 11 futures contract for trade date February 26, 2019, as well as the misreporting of large trader positions and open interest for the July 2019 and October 2019 sugar no. 11 futures contracts for trade date June 14, 2019.","res":"Decision","sm":"The firm consented to a summary fine in the amount of $7,500","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1171},{"d":"2019-08-26","di":"2019-08-08","dr":"2019-08-26","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (CME) Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"RSRH-19-5521","al":"Pursuant to CME rule 526.f., all block trades must be reported to the exchange in a timely manner. Three block trades (CBOT and comex trades) reported by JPMorgan securities LLC in June 2019 were reported late to the exchange.","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1172},{"d":"2019-08-26","di":"2019-08-26","dr":"2019-08-26","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Undertaking","os":"Cease and desist, censure, civil and administrative fine","st":"Final","fine":450000.0,"dk":"2018-0090","al":"The Massachusetts Securities Division alleged certain WFCS supervisors required to be registered in Massachusetts and WFCS agents had a lapse in Massachusetts registration for some period during the relevant time period of January 1, 2016 to June 28, 2018.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1173},{"d":"2019-08-22","di":"2019-08-22","dr":"2019-08-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, disgorgement","st":"Final","fine":3000000.0,"dk":"FILE NO. 3-19373","al":"The SEC alleged that Deutsche Bank AG (\"DBAG\") provided employment to the relatives of foreign government officials as a personal benefit to those officials in order to influence them to assist DBAG in obtaining or retaining business or other benefits between 2006 and 2014. The SEC alleged that DBAG's 2010 asia-pacific hiring policy did not apply to all categories of hires and was not effectively enforced by DBAG to detect and prevent its employees from offering temporary employment to candidates referred by current or potential clients to detect and prevent corrupt hiring practices. The SEC alleged that DBAG employees created false books and records that concealed these hiring practices and failed to accurately document and record certain related expenses. The SEC also alleged that DBAG failed to devise and maintain a system of internal accounting controls around its hiring practices sufficient to provide reasonable assurances that its employees did not violate anti-bribery laws.","res":"Order","sm":"On August 22, 2019, dbag, without admitting or denying the findings or conclusions therein, entered into a settlement with the SEC. the SEC approved the settlement in its order instituting cease-and-desist proceedings pursuant to section 21c of the Securities Exchange Act of 1934, making findings, and imposing a cease-and-desist order, including the following terms and conditions. Dbag agreed to cease and desist from violating sections 13(b)(2)(a) and 13(b)(2)(b) of the Exchange Act and to pay disgorgement of $10,785,900, prejudgment interest of $2,392,950, and a civil money penalty of $3,000,000, which was paid on September 3, 2019.","ab":"Deutsche Bank AG","firms":[300838],"id":1174},{"d":"2019-08-09","di":"2019-08-09","dr":"2019-08-09","k":"Regulatory Action","rg":"NFA","reg":"National Futures Association","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500000.0,"dk":"19-BCC-010","al":"Without admitting the allegations, Wells Fargo Bank, N.A. (\"WFBNA\") consented to a settlement in which it was alleged and found to have violated NFA compliance rule 2-49(a) by failing to communicate with a counterparty in a fair and balanced manner as required under Commodity Futures Trading Commission regulation 23-433. WFBNA agreed to pay a civil money penalty of $2,500,000.00 to the National Futures Association within 30 days.","res":"Decision","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1175},{"d":"2019-08-06","di":"2019-08-06","dr":"2019-08-06","k":"Regulatory Action","rg":"State regulator","reg":"Georgia Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"ENSC-190782","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Georgia Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Georgia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Georgia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1176},{"d":"2019-08-02","di":"2019-07-11","dr":"2019-08-02","k":"Regulatory Action","rg":"Other","reg":"Alabama Department of Insurance","san":"Suspension","os":"Licensee provided evidence of her timely completion of the required continuing education and requested reinstatement of her","st":"Final","al":"In an order dated July 11, 2019, the commissioner of insurance suspended licensee's insurance producer license for alleged failure to comply with the continuing education requirements during the license cycle August 1, 2016 to July 31, 2018. It was later determined that licensee did comply with those requirements but that the electronic system utilized by the Alabama Department of Insurance (the \"department\") failed to reflect that compliance.","res":"Consent","sm":"The licensee and the department subsequently entered into a consent order on August 2, 2019. The licensee paid a reduced administrative assessment of $250 and acknowledged the terms of the consent order. The department then reinstated the licensee's insurance producer license to active status.","ab":"Green, Sonya, Hudmon","firms":[250],"id":1177},{"d":"2019-08-01","di":"2019-07-02","dr":"2019-08-01","k":"Regulatory Action","rg":"Other","reg":"Akk ­ ÁLlamadÓSSÁG Kezelo KÖZpont ZÁRTKÖRuen MukÖDo RÉSZVÉNytÁRsasÁG","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1710.5,"al":"Akk ­ ÁLlamadÓSSÁG Kezelo KÖZpont ZÁRTKÖRuen MukÖDo RÉSZVÉNytÁRsasÁG alleged that during the first half of the calendar year 2019, Goldman Sachs international (\"GSI\") failed to meet its primary dealer quoting obligations in accordance with the agency contract between GSI and akk and the relevant market making rules.","res":"Decision","sm":"The akk imposed a fine on gsi in the amount of huf 500,000, which was paid by submission of a wire on August 1, 2019.","ab":"Goldman Sachs","firms":[361],"id":1178},{"d":"2019-07-29","di":"2019-07-29","dr":"2019-07-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":1250000.0,"dk":"2017054329501","al":"Alleged violation of section 17(f) and 17F-2 thereunder and 17(a) and rule 17A-3 thereunder of the Exchange Act , FINRA by-laws, article III, section 3(b), NASD rules 3010 and 3110 and FINRA rules 3110, 4511 and 2010 in that Citigroup Global Markets Inc. failed to conduct timely or adequate background checks on certain non-registered associated persons. The firm failed to fingerprint certain non-registered associated persons until after they began to work for cgmi and was unable to determine whether it timely fingerprinted others because it failed to locate any documentation. In addition, certain individuals who were subject to a statutory disqualification were allowed to associate with cgmi and the firm was unable to determine whether certain associated persons were subject to a statutory disqualification because their association had ended or they were on leave. The firm failed to maintain a reasonable supervisory system or procedures to identify and properly screen all individuals who became associated with the firm in a non-registered capacity from January 2010 through May 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $1,250,000, and undertakings to review systems and procedures regarding the identification, fingerprinting, and screening of non-registered associated persons and to certify to FINRA that the firm has completed a retrospective review to identify non-registered associated persons who were not previously fingerprinted and/or screened under the Exchange Act, and to fingerprint and screen those individuals under the Exchange Act.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1179},{"d":"2019-07-22","di":"2019-07-22","dr":"2019-07-22","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"18-0018","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the West Virginia Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in West Virginia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any West Virginia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1180},{"d":"2019-07-17","di":"2019-05-17","dr":"2019-07-17","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire, Department of State Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"I-2019000013","al":"Atlas Enhanced Fund, L.P. made a late submission of the notice filing for its first sale of securities in the state of New Hampshire.","res":"Settled","sd":"The total settlement amount of $2,500.00 was levied against the advisory affiliate (Atlas Enhanced Fund, L.P.). The settlement amount was paid on July 17, 2019.","ab":"Atlas Enhanced Fund, L.P.","firms":[138111],"id":1181},{"d":"2019-07-15","di":"2019-05-16","dr":"2019-07-15","k":"Regulatory Action","rg":"State regulator","reg":"The Bureau of Securities Regulation, Department of State, State of New Hampshire","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Under the consent order, the firm has agreed to pay an administrative fine of $2,500, to pay the notice filings fees for the period","st":"Final","fine":2500.0,"dk":"INV2019-00017","al":"Pursuant to rsa 421-b under New Hampshire law, an SEC-registered investment adviser with a single client resident in the state of New Hampshire is deemed to be transacting business in the state and is generally required to make a notice filing with the state. The firm has had a single client in New Hampshire since 2016 but did not notice file with the state until March 2019, when it became aware of the state's filing requirements.","res":"Order","sd":"The total amount of the fine is $2,500.","sm":"PLEASE SEE #12 ABOVE No Information Filed","ab":"Claret Asset Management Corp","self":true,"firms":[110453],"id":1182},{"d":"2019-07-10","di":"2019-07-10","dr":"2019-07-10","k":"Regulatory Action","rg":"Other","reg":"Tennessee Department of Commerce and Insurance","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"19-016","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Tennessee Department of Commerce and Insurance (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Tennessee; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Tennessee statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1183},{"d":"2019-07-08","di":"2019-07-08","dr":"2019-07-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":55000.0,"dk":"2014043477301","al":"Alleged violation of FINRA rule 2360(b)(5) in that Citigroup Global Markets Inc. failed to report and inaccurately reported reportable listed options positions to the large options position reporting system during the period between January 4, 2010 and March 11, 2016.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine of $55,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1184},{"d":"2019-06-28","di":"2019-06-28","dr":"2019-06-28","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Attorney General of the State of New York","san":"Other","os":"Assurance of discontinuance; civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"19-067","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Attorney General of the State of New York (OAG) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; and certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure.","res":"Settled","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the oag and LPL agreed that the assurance would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the oag and LPL agreed that nothing in the assurance is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the assurance is not intended to be a final order based upon violations of any jurisdiction's statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1185},{"d":"2019-06-26","di":"2019-06-26","dr":"2019-06-26","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Undertaking","os":"Cease and desist, censure, civil and administrative fine","st":"Final","fine":1100000.0,"dk":"E-2019-0041","al":"During the relevant time period of March 1, 2013 to April 4, 2019, the Massachusetts Securities Division found LPL failed to timely register with the division certain agents required to be registered in Massachusetts. LPL also failed to properly and timely amend forms U4 and U5 for agents who were registered in Massachusetts that subsequently became materially inaccurate or in complete.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1186},{"d":"2019-06-21","di":"2019-06-21","dr":"2019-06-21","k":"Regulatory Action","rg":"U.K. FCA","reg":"UK Financial Conduct Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45500000.0,"al":"Bank of Scotland failed to alert the then regulator (the financial services authority) of suspicions of fraud in its reading branch within the impaired assets ('iar') team, after identifying suspicious conduct in early 2007. The suspicious conduct related to a director (lynden scourfield) sanctioning limits and additional lending facilities beyond the scope of his authority for at least 3 years. Bank of Scotland notified the FCA in 2009. The FCA found that this caused delays in investigations conducted by the FCA and thames valley police and that it risked prejudicing the investigation by thames valley police.","res":"Settled","sm":"A fine of £45,500,000 was levied for breaching principle 11 and subsequently paid. The matter is now settled. No information Filed","ab":"Bank of Scotland PLC","firms":[161257],"id":1187},{"d":"2019-06-20","di":"2019-06-20","dr":"2019-06-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, restitution plus interest","st":"Final","fine":225000.0,"dk":"2016050947701","al":"Alleged violation of FINRA rules 2010, 3110, and NASD rule 3010 in that Citigroup Global Markets Inc. failed to identify and apply sales charge discounts to certain eligible purchases of unit investment trusts (\"UITS\"), failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably deisgned to achieve compliance, and failed to establish, maintain and enforce a supervisory system reasonably designed to supervise uit trading from February 2011 to February 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $225,000, and restitution in the amount of $152,488.59 plus interest","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1188},{"d":"2019-06-19","di":"2019-06-19","dr":"2019-06-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":40000.0,"dk":"2018056422401","al":"FINRA alleged that Edward jones violated FINRA rules 1122 and 2010 and article v, section 2 of FINRA's by-laws by filing forms U4 containing misleading information about the amount of alleged damages in customers' complaints. FINRA further alleged that the firm's disclosures to FINRA of customer complaints understated the customers' alleged damages, and resulted from a misunderstanding by certain of its associates about the applicable requirements for disclosures regarding customers' complaints. When FINRA identified the inaccuracies, Edward jones promptly updated the forms U4 at issue to reflect the specific amounts of the customers' alleged damages, provided additional training to its associates, and instituted additional safeguards for its process of disclosing customers' complaints.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1189},{"d":"2019-06-18","di":"2019-06-18","dr":"2019-06-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":2434536.0,"dk":"3-19205","al":"SEC admin releases 33-10650, 34-86133 / June 18, 2019: the Securities and Exchange Commission deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be instituted against Wedbush Securities, inc., (\"Wedbush\" or \"respondent\"). On the basis of this order and respondent's offer, the commission finds that these proceedings arise out of Wedbush's improper practices with respect to securities lending transactions involving pre-released american depositary receipts (\"ADRS\"). Only brokers (or other market participants) that have entered into pre-release agreements with a depositary (\"pre-release agreements\") can obtain pre-released ADRS from the depositary. The pre-release agreements, consistent with the deposit agreements, require the broker receiving the pre-released ADRS (\"pre-release broker\"), or its customer on whose behalf the pre-release broker is acting, to beneficially own the ordinary shares represented by the ADRS, and to assign all beneficial rights, title, and interest in those ordinary shares to the depositary while the pre-release transaction is outstanding. In effect, the pre-release broker or its customer becomes the temporary custodian of the ordinary shares that would otherwise have been delivered to the custodian. From at least November 2011 until approximately September 2013, Wedbush was a pre-release broker that obtained pre-released ADRS directly from four depositaries pursuant to pre-release agreements. Contrary to certain provisions in the pre-release agreements and the deposit agreements, associated persons on Wedbush's securities lending desk regularly obtained pre-released ADRS from depositaries and loaned them to counterparties without taking reasonable steps to determine whether the requisite number of ordinary shares was owned and custodied by Wedbush or its counterparties. The result of this conduct was the issuance of ADRS that in many instances were not backed by ordinary shares as required by the deposit agreements. This conduct violated section 17(a)(3) of the Securities Act. In addition, Wedbush failed to establish and implement effective policies and procedures to address whether Wedbush's associated persons complied with the firm's obligations in connection with pre-release transactions, such as determining ownership of the underlying ordinary shares. As a result, Wedbush's supervisory policies and procedures were not reasonably designed and implemented to provide effective oversight of associated persons to prevent and detect their violations of Securities Act section 17(a)(3), and Wedbush failed reasonably to supervise its associated persons within the meaning of section 15(b)(4)(e) of the Exchange Act. As result of the conduct, respondent violated section 17(a)(3) of the Securities Act. Wedbush was responsible for supervising its securities lending desk personnel to address whether they were borrowing and lending pre-released ADRS that were not backed by underlying ordinary shares. Wedbush failed reasonably to fulfill such supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Exchange Act. In determining to accept the offer, the commission considered the cooperation afforded the commission and its voluntary remediation efforts in discontinuing pre-release activity before the start of the s commission's investigation.","res":"Order","sd":"Respondent has submitted an offer of settlement (the offer) which the commission has determined to accept. In view of the foregoing, the commission deems it appropriate in the public interest to impose the sanctions agreed to in the respondent's offer. Accordingly, it is hereby ordered that respondent shall cease and desist from committing or causing any violations and any future violations of section 17(a)(3) of the Securities Act. Respondent is censured. Respondent shall pay disgorgement of $4,869,072 and prejudgment interest of $805,641. Respondent shall pay a civil money penalty of $2,434,536.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1190},{"d":"2019-06-13","di":"2019-06-13","dr":"2019-06-13","k":"Regulatory Action","rg":"Other","reg":"Iowa Insurance Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"98196","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Iowa Insurance Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Iowa; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Iowa statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1191},{"d":"2019-06-10","di":"2019-06-10","dr":"2019-06-10","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","os":"Fine, undertaking","st":"Final","fine":100000.0,"dk":"2016051144701","al":"Alleged violation of Nasdaq rules 4613(a), 3010 and 2010a in that Citigroup Global Markets Inc. failed to maintain a continuous two-sided trading interest, during regular market hours, at prices within certain percentages away from the nbbo in certain instances and the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to market maker quoting obligations during the period January 1, 2015 through March 31, 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $100,000, and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1192},{"d":"2019-06-07","di":"2019-06-07","dr":"2019-06-07","k":"Regulatory Action","rg":"Other","reg":"Financial Services Agency of Japan","san":"Undertaking","st":"Final","dk":"N/A","al":"Alleged violation of article 123(1)(XII) of cabinet office order on financial instruments and exchange, etc. based on article 40(2) of the financial instruments and Exchange Act in that Citigroup Global Markets Japan inc. had failures in market derivatives trading control system in that some transaction data necessary for trade surveillance were not delivered to trade surveillance system, had failures in trade surveillance system in that the company inappropriately narrowed down the coverage of trade surveillance, and had deficiencies in trade surveillance framework in that the company inadequately overlooked and executed order of the spoofing transactions in JGB futures market on October 26 and 29, 2018.","res":"Order","sm":"The firm was issued a business improvement order to enhance and strengthen the company's business management/internal control framework","ab":"Citigroup Global Markets","firms":[7059],"id":1193},{"d":"2019-06-07","di":"2019-06-07","k":"Regulatory Action","rg":"Other","reg":"Financial Services Agency of Japan","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"N/A","al":"Alleged violation of the financial instruments and Exchange Act in that a trader formerly employed by Citigroup Global Markets limited placed a series of orders for 10-year JGB futures listed on the osaka exchange on October 26 and 29, 2018 which were deemed to constitute market manipulations of such JGB futures.","res":"Order","sm":"Administrative monetary penalty payment order of 133.37 million yen","ab":"Citigroup Global Markets","firms":[7059],"id":1194},{"d":"2019-06-07","di":"2019-06-07","dr":"2019-06-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":150000.0,"dk":"2017052842901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it published seven research reports about an issuer without disclosing that the research analyst who authored the reports was engaged in employment discussions with the issuer that constituted an actual, material conflict of interest. The findings stated that the research analyst's candidacy for employment at the issuer was clearly viable, and the issuer and the research analyst had expressed mutual interest and taken concrete steps in furtherance of their employment discussions. During these employment discussions, the research analyst authored and the firm published the seven research reports on the issuer without disclosing that the research analyst was engaged in the employment discussions with it. The firm's failure to disclose the actual, material conflict of interest arising from the research analyst's employment discussions with the issuer in the research reports authored by him and published by the firm made those reports misleading.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $150,000.00","sm":"In response to this matter, baird took proactive measures to reiterate compliance policies pertaining to research disclosures on material conflicts. This involved the publication of policy reminders, discussions at monthly research department meetings, enhancement of research analyst new hire orientation, amendments to the research associate and research supervisory compliance manuals and edits to procedures regarding review of research. The firm also enhanced its research department firm element training and held discussions on relevant policy and practice at periodic research analyst meetings. Going forward, baird will continue to monitor adherence to relevant policies and will continue to appropriately educate and remind research analysts of their responsibilities. Any potential for disclosure due to similar circumstances will be reviewed by the firm's management as well as the legal and compliance department.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1195},{"d":"2019-06-04","di":"2016-07-22","dr":"2019-06-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure fines undertaking","st":"Final","fine":5250000.0,"dk":"3-19190","al":"On June 4, 2019, the investment manager and MR. Burg entered into an order (the \"order\") with the Securities and Exchange Commission (the \"SEC\"). Without admitting or denying the findings in the order, the SEC found that from at least October 2012 through December 2015 (the \"relevant period\"), the investment manager's policies failed to address sufficiently how to conform the firm's valuations with generally accepted accounting principles (\"GAAP\"). Further, the SEC found the investment manager's policies were not reasonably designed for its business practices, given its use of valuation models and pricing vendors, and the potential conflict of interest arising from traders' ability to determine the fair value of a portion of the positions they manage. Moreover, the order states that the investment manger failed to implement its existing policy. In accordance with GAAP, the investment manager's valuation policy included a requirement to maximize the use of relevant observable inputs. During the relevant period, however, the investment manager, at times failed to ensure that certain residential mortgage-backed securities (\"RMBS\") were valued in accordance with GAAP. Specifically, the investment manager may have undervalued certain client assets by failing to maximize relevant observable inputs, such as trade prices. The SEC found that MR. Burg was a cause of the investment manager's failure to implement the valuation policy that required maximizing observable inputs.","res":"Settled","sd":"Monetary fine/amount: Deer Park Road Management Company, LP-$5,000,000.00. Date paid-June 10, 2019 scott edward Burg- $250,000.00. Date paid-June 10, 2019. No part of these fines were waived.","sm":"On June 4, 2019, the investment manager and MR. Burg entered into an order (the \"order\") with the Securities and Exchange Commission (the \"SEC\"). Without admitting or denying the findings in the order, the SEC found that from at least October 2012 through December 2015 (the \"relevant period\"), the investment manager's policies failed to address sufficiently how to conform the firm's valuations with generally accepted accounting principles (\"GAAP\") and that MR. Burg was a cause of this violation. The firm was fined $5,000,000, ordered to cease and desist further violations, censured and agreed to undertakings as described in the response to question 12 (b) above. MR. Burg was fined $250,000 and ordered to cease and desist further violations. Further, details are provided in the response to question 7, above. No information Filed","ab":"Burg, Scott, Edward","firms":[140370],"id":1196},{"d":"2019-05-31","di":"2018-11-05","dr":"2019-05-31","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3344.7,"dk":"H 9-2018","al":"A breach of organizational duties by forwarding unflagged orders transmitted by one of our customers via direct electronic access to the xetra trading platform of the Frankfurt Stock Exchange. This is specifically in reference to section 3 (1) of the conditions for business transactions. A further breach of the organizational duties of the party as the indirect trading participant were not aware of the FWB's cross-trade rules shows that the party did not inform or only inadequately informed its customer of the FWB's stock exchange rules. This is specifically in reference to section 37 (3) of the exchange rules for the frankfurter wertpapierbÖrse.","res":"Consent","sm":"The fine imposed by FWB was in the amount of 3,000 eur, which was paid by gsi by wire on May 31, 2019.","ab":"Goldman Sachs","firms":[361],"id":1197},{"d":"2019-05-30","di":"2019-04-29","dr":"2019-05-30","k":"Regulatory Action","rg":"Other","reg":"Financial Services Commission (FSC) - Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40500.0,"al":"Late to deliver short sale of 1 listed equity by 1 day","res":"Decision","sm":"NMCL PAID THE FINE. No Information Filed","ab":"Nine Masts Capital Limited","self":true,"firms":[162024],"id":1198},{"d":"2019-05-28","di":"2019-03-29","dr":"2019-05-28","k":"Regulatory Action","rg":"Other","reg":"Bank of Spain","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8884880.0,"al":"As a result of an inspection of a 2014 mortgage portfolio, the Bank of Spain cited Banco Santander, S.A. With excessive charging of commissions and failure to provide sufficient information to consumers to allow them to make an informed decision on the purchase of said portfolios.","res":"Settled","sd":"Banco Santander, S.A. Was fined euro 8,000,000 - usd amount above is an estimate as of 08/27/2019. Banco Santander, S.A. Paid a reduced amount of eur 6,400,000 availing itself of the 20% reduction for prompt payment allowance.","ab":"Banco Santander, S.A.","firms":[143883],"id":1199},{"d":"2019-05-28","di":"2018-07-25","dr":"2019-05-28","k":"Regulatory Action","rg":"Other","reg":"Bank of Spain","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"On appeal","fine":4997745.0,"al":"As a result of an inspection of a 2014 mortgage portfolio, the Bank of Spain cited Banco Santander, S.A. With excessive charging of commissions and failure to provide sufficient information to consumers to allow them to make an informed decision on the purchase of said portfolios. Banco Santander, S.A. Is accountable for the fine as Banco popular was acquired by Banco Santander, S.A. In 2017.","res":"Other","sd":"Banco Santander, S.A. Has paid a fine for citations related to Banco popular prior to being acquired by Banco Santander, S.A. In the amount of euro 4,500,000 - usd amount above is an estimate as of 08/27/2019.","ab":"Banco Santander, S.A.","firms":[143883],"id":1200},{"d":"2019-05-23","di":"2019-05-23","dr":"2019-05-23","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"19-014","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Ohio Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Ohio; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Ohio statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1201},{"d":"2019-05-20","di":"2019-05-20","dr":"2019-05-20","k":"Regulatory Action","rg":"State regulator","reg":"Wyoming Secretary of State","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"18-04","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Wyoming Secretary of State alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Wyoming; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the Wyoming Secretary of State and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the Wyoming Secretary of State and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Wyoming statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1202},{"d":"2019-05-20","di":"2019-05-20","dr":"2019-05-20","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"2017056712301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to maintain a continuous two-sided trading interest during regular market hours at prices within certain percentages away from the national best bid or offer (\"NBBO\"). The findings stated that the firm failed to maintain a quote for the entire market hours. The violations occurred as a result of system related coding issues involving the sending of market maker peg orders (\"MMPO\") to Nasdaq for new securities that were issued with the same symbol as previously inactive securities (E.G., as a result of a name change, relisting, new listing, etc.). In these situations, the firm's systems failed to append the proper codes that were used to match the symbols in which the firm was market maker and obtain market data for sending a MMPO, which was due to the fact that the codes for these symbols were still associated with the inactive securities. The conduct described in this paragraph consitutes separate and distinct violations of Nasdaq rule 4613(a). The findings also stated that the firm's supervisory system was not reasonably desgined to achieve compliance with Nasdaq quoting obligations. Specifically, the firm's supervision system failed to include a review for Nasdaq symbols for which it was a registered market maker and where the firm's relevant system did not generate MMPO quotes for securities that were issued with the same symbol as previously inactive securities. As a result, the firm did not detect the system related coding issues that occurred during the review period. The conduct described in this paragraph constitutes a violation of Nasdaq rules 2010a and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Subsequent to the review period, the firm updated its supervisory systems by implementing a report designed to identify symbols in which the firm did not generate a mmpo quote, which includes quotes in previously inactive securities. Therefore, enforcement is not recommending an undertaking.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1203},{"d":"2019-05-20","di":"2019-05-20","dr":"2019-05-20","k":"Regulatory Action","rg":"Other","reg":"Brazil Comissao de Valores Mobiliarios (CVM)","san":"Other","os":"Payment to CVM for benefit of the securities market","st":"Final","dk":"19957.006602/2018-37","al":"The CVM staff alleged that Morgan Stanley administradora de carteiras S.A. (MSAC) engaged in irregular trading outside the stock exchange on November 28, 2013 involving certain interest rate swaps.","res":"Consent","sm":"On May 20, 2019, Morgan Stanley administradora de carteiras S.A. (MSAC) became subject to a consent order with the Brazil Comissao de Valores Mobiliarios (CVM) in connection with allegations of irregular trading outside the stock exchange on November 28, 2013 involving certain interest rate swaps. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm consented to making a payment of BRL 400,000 (approximately $100,000) to CVM for the benefit of the securities market.","ab":"Morgan Stanley","firms":[149777],"id":1204},{"d":"2019-05-16","di":"2016-10-27","dr":"2019-05-16","k":"Regulatory Action","rg":"Other","reg":"European Commission","san":"Other","st":"Final","fine":310776000.0,"dk":"AT.40135","al":"On May 16, 2019, the commission adopted a decision finding Citigroup liable for sharing sensitive information and occasionally coordinating trading strategies with competitors at UBS, barclays, RBS, and JPM between December 18, 2007 and January 31, 2013. The commission found that, through this conduct, Citigroup had violated article 101 of the treaty on the functioning of the European union. The decision imposed a fine on Citigroup of eur 310,776,000. This fine includes a 20% reduction for cooperation within the European Commission's leniency process and a 10 % discount for accepting to settle the case, as well as immunity from fines for a period of 27 months for which Citigroup was the first bank to provide evidence.","res":"Settled","ab":"Citibank, NA","firms":[7059],"id":1205},{"d":"2019-05-08","di":"2019-05-08","k":"Regulatory Action","dk":"2018058794401","ab":"Tosha, Stephen, Patrick","firms":[7691],"id":1206},{"d":"2019-05-07","di":"2019-04-08","dr":"2019-05-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","st":"Final","fine":3000.0,"dk":"2017055792103","al":"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 Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state 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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1207},{"d":"2019-05-07","di":"2019-04-08","dr":"2019-05-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc","st":"Final","fine":15000.0,"dk":"2017055792102","al":"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 Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state 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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1208},{"d":"2019-05-07","di":"2019-04-08","dr":"2019-05-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","st":"Final","fine":12000.0,"dk":"2017055792101","al":"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 Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state 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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1209},{"d":"2019-05-03","di":"2019-05-03","dr":"2019-05-03","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"RSRH-19-5437","al":"Alleged violation of CME rule 811 in that Citigroup Global Markets Inc. inaccurately reported certain open interest positions to the exchange between February 1, 2019 and February 27, 2019.","res":"Decision","sm":"Cgmi consented to a summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1210},{"d":"2019-05-03","di":"2019-05-03","dr":"2019-05-03","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"RSRH-19-5437","al":"Alleged violation of NYMEX rule 811 in that Citigroup Global Markets Inc. inaccurately reported certain open interest positions to the exchange between February 1, 2019 and February 27, 2019.","res":"Decision","sm":"Cgmi consented to summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1211},{"d":"2019-05-03","di":"2019-05-03","dr":"2019-05-03","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000.0,"dk":"RSRH-19-5437","al":"Alleged violation of CBT rules 807 and 811 in that Citigroup Global Markets Inc. overreported long positions eligible for delivery in certain futures contracts on trade dates February 27 and February 28, 2019 and inaccurately reported certain open interest positions to the exchange between February 1, 2019 and February 27, 2019.","res":"Decision","sm":"Cgmi consented to a summary fine in the amount of $7,000 which consisted of $5,000 for violation of rule 807 and $2,000 for violation of rule 811","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1212},{"d":"2019-04-30","di":"2019-04-30","dr":"2019-04-30","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"N/A","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the New Jersey Bureau of Securities (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Jersey; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Jersey statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1213},{"d":"2019-04-29","di":"2019-03-25","dr":"2019-04-29","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet (Danish Financial Supervisory Authority)","san":"Reprimand","os":"Order","st":"Final","dk":"6376-0196","al":"Following a self-initiated internal review in October 2018, Squarepoint identified issues with its european short sale notification calculations and processes. As the process was centralized to satisfy all european jurisdictions, this impacted historical notifications, at that point in time, to a number of european regulatory authorities, including the danish Finanstilsynet. On March 25, 2019, Squarepoint voluntarily contacted the danish FSA to notify them of the issues and to correct historical records. The identified errors affecting danish issuers were corrected by January 2019.","res":"Decision","sd":"None","sm":"Historical notifications were corrected and actions taken to mitigate re-occurance and after issuing an order and reprimand letter, the Finanstilsynet determined no further action was necessary.","ab":"Squarepoint Ops LLC","self":true,"firms":[172116],"id":1214},{"d":"2019-04-26","di":"2017-10-03","dr":"2019-04-26","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"p","st":"Final","fine":61000.0,"dk":"MC 18-87","al":"The State of Connecticut Insurance Department conducted a market conduct examination for the period January 1, 2014 through December 31, 2016 of Massachusetts Mutual Life insurance company (\"massmutual\"). Massmutual is the parent of MML investment advisers, LLC. at the conclusion of the examination, the State of Connecticut Insurance Department alleged that massmutual violated subsections 38A-15 and 38A-702M of the Connecticut general statutes.","res":"Stipulation and Consent","sd":"Massmutual agreed to provide the State of Connecticut Insurance Department with a summary of actions taken to comply with the recommendations in the market conduct report within 90 days and massmutual agreed to pay a fine in the amount of $61,000.","sm":"During the period under examination (January 1, 2014-December 31, 2016), the State of Connecticut Insurance Department alleged that massmutual, in certain instances, failed to follow established practices and procedures to ensure compliance with statutory requirements resulting in: 35 producers acting as agents without being appointed; 1 instance where it failed to return premium in a timely manner; 5 instances where it failed to provide documentation for regulatory review; and 1 instance where it failed to respond timely to a written request for information.","ab":"Massachusetts Mutual Life","firms":[106006],"id":1215},{"d":"2019-04-26","di":"2019-04-11","dr":"2019-04-26","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":19473.8,"dk":"NONE","al":"The Bangko Sentral NG Pilipinas (BSP) approved the imposition of a monetary penalty on the firm for non-compliance with the 100.0 percent expanded/foreign currency deposit unit (e/fcdu) asset cover requirement.","res":"Other","sm":"The monetary board imposed a penalty in the amount of PHP1,011,442 (USD19,473.80) on the firm. Pursuant to the BSP's rules, the firm's demand deposit account with the BSP shall be automatically debited the above referenced amount upon the lapse of fifteen calendar days from receipt of the final billing letter. Therefore, the amount may be debited no earlier than April 26, 2019.","ab":"Bank of America, National","firms":[142558],"id":1216},{"d":"2019-04-26","di":"2017-10-03","dr":"2019-04-26","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","sm":"The State of Connecticut Insurance Department conducted a market conduct examination for the period January 1, 2014, through December 31, 2016, of Massachusetts Mutual Life insurance company (\"massmutual\"). Massmutual is the parent of MML investment advisers, LLC. at the conclusion of the examination, the State of Connecticut Insurance Department alleged that massmutual violated subsections 38A-15 and 38A-702M of the Connecticut general statutes. - During the period under examination (January 1, 2014-December 31, 2016), the State of Connecticut Insurance Department alleged that massmutual, in certain instances, failed to follow established practices and procedures to ensure compliance with statutory requirements resulting in: 35 producers acting as agents without being appointed; 1 instance where it failed to return premium in a timely manner; 5 instances where it failed to provide documentation for regulatory review; and 1 instance where it failed to respond timely to a written request for information.","ab":"Massachusetts Mutual Life","firms":[162264],"id":1217},{"d":"2019-04-24","di":"2017-03-06","dr":"2019-04-24","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Market Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":52960.0,"dk":"1/746/01.21.2016","al":"The Hellenic Capital Market Commission (HCMC) alleged that Morgan Stanley committed market manipulation pursuant to article 7, par. 2(c) of law 3340/2005 by disclosing that the firm, through various subsidiaries, had acquired more than 5% of alpha bank, however 4.16% of the holding was held by a subsidiary as custodian on behalf of a customer.","res":"Decision","sd":"The 50,000 euro (approximately $52,960 usd) summary fine was paid on June 28, 2017.","sm":"The 50,000 euro (approximately $52,960 usd) summary fine was appealed on March 6, 2017, but the appeal was rejected and the summary fine became final on April 24, 2019.","ab":"Morgan Stanley","firms":[104859,105922,110353,126896,134366,149777,158959,309263],"id":1218},{"d":"2019-04-22","di":"2019-04-22","dr":"2019-04-22","k":"Regulatory Action","rg":"State regulator","reg":"Virginia State Corporation Commission","san":"Cease and Desist","os":"Offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"SEC-2018-00027","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Virginia State Corporation Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Virginia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Virginia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1219},{"d":"2019-04-18","di":"2019-04-18","dr":"2019-04-18","k":"Regulatory Action","rg":"Other","reg":"Hong Kong Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":152900.0,"al":"Failure to deliver short sale of 1 listed equity","res":"Decision","sm":"NMCL paid the fine.","ab":"Nine Masts Capital Limited","self":true,"firms":[162024],"id":1220},{"d":"2019-04-16","di":"2019-04-16","dr":"2019-04-16","k":"Regulatory Action","rg":"Other","reg":"Alaska Division of Banking and Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"17-170-S","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Alaska Division of Banking and Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alaska statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1221},{"d":"2019-04-16","di":"2019-04-16","dr":"2019-04-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada, Office of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12000.0,"dk":"CI15-024","al":"Non-registration as branch offices under Nevada law of personal residences of associated persons in Nevada used as alternative work locations in compliance with FINRA rules","res":"Consent","sm":"Applicant entered into an administrative consent order effective as of April 16, 2019, which provided that applicant \"will cease from violating the [Nevada uniform securities] act, and the regulations adopted thereunder, and will comply with said act and regulations in the future;\" applicant \"shall obtain a branch office license for all places of business in the state of Nevada from which one or more sales representatives transact business in accordance with NRS 90.360(2) and nac 90.392;\" and applicant will pay \"a civil penalty in the amount of twelve thousand dollars and no cents ($12,000.00).\"","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1222},{"d":"2019-04-11","di":"2019-04-11","dr":"2019-04-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":10000.0,"dk":"2016048551101","al":"While under prior ownership as euro pacific capital in January 2016, a corporate customer was alleged to have been charged $6,000 for filing a Form 211 in violation of FINRA rule 5250 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine was $10,000, levied against applicant and paid on 3/6/2019.","sm":"On April 11, 2019, FINRA approved a letter of acceptance waiver and consent which neither admitted nor denied the allegation that while under prior ownership as euro pacific capital in January 2016, a corporate customer had been charged $6,000 for filing a Form 211 in violation of FINRA rule 5250 and 2010. The AWC provided for sanctions consisting of a censure and a $10,000 fine.","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":1223},{"d":"2019-04-10","di":"2019-04-10","dr":"2019-04-10","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"IC19-CAF-01","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Texas State Securities Board (board) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Texas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the board and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the board and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Texas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1224},{"d":"2019-04-08","di":"2019-04-08","dr":"2019-04-08","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"17 SEC 053","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the North Carolina Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in North Carolina; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any North Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1225},{"d":"2019-04-05","di":"2019-04-05","dr":"2019-04-05","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Commissioner of Securities and Insurance, Montana State Auditor","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"SEC-2018-147","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Commissioner of Securities and Insurance, Montana State Auditor (CSI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Montana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the csi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the csi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Montana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1226},{"d":"2019-04-02","di":"2019-03-07","dr":"2019-04-02","k":"Regulatory Action","rg":"Other","reg":"Financial Services Commission of the Republic of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":63615.48,"al":"The Financial Services Commission of the Republic of Korea (\"FSC\") has imposed an administrative fine on Goldman Sachs India investments (SINGAPORE) pte. LTD. (\"KRPL\") for violation of certain short sale restrictions as set out in article 180(1) of the financial investment services and capital markets act (the \"act\") with respect to certain of KRPL's short sale orders on October 31, 2017 and January 9, 2018. The fine was imposed pursuant to article 449 of the act, article 390 of the enforcement decree of the act, and articles 26 and 48 of the regulation on sanctions against financial institutions.","res":"Decision","sm":"The fine imposed by the FSC was in the amount of 72,000,000 south korean won (\"KRW\"), which was paid by KRPL by wire on April 2, 2019.","ab":"Goldman Sachs India","firms":[361],"id":1227},{"d":"2019-04-02","di":"2019-04-02","dr":"2019-04-02","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Kansas Securities Commissioner","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"19E079/2018-6509","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Kansas Securities Commissioner (KSC) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Kansas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the KSC and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the KSC and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Kansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1228},{"d":"2019-04-01","di":"2018-04-12","dr":"2019-04-01","k":"Regulatory Action","rg":"Other","reg":"Spanish National Securities Markets Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":174034.0,"dk":"SANCTIONS PROCEEDING NO. 8/2018","al":"The Spanish National Securities Markets Commission determined that Renaissance Technologies LLC (\"Renaissance\") had entered into trades on behalf of funds that it manages in violation of a Spanish short selling ban on the securities of LIBERBANK, S.A. (\"LIBERBANK\") in 2017. Renaissance reduced long positions in LIBERBANK after the short selling ban had taken effect.","res":"Decision","sd":"Renaissance paid the Spanish National Securities Markets Commission a fine equal to 150,000 euros on June 26, 2019. (The monetary fine in 12(a) was converted into U.S. dollars using the exchange rate on the date of payment.)","sm":"The Spanish National Securities Markets Commission (the \"CNMV\") determined that in 2017, Renaissance on behalf of its funds traded in violation of a Spanish short selling ban on the securities of LIBERBANK, S.A. (\"LIBERBANK\"). Although Renaissance had not engaged in any short sales of LIBERBANK, the CNMV determined that Renaissance's reduction of long positions in LIBERBANK violated the short sale ban because it resulted in an increase in the funds' net short position in LIBERBANK. Renaissance's appeal of the CNMV's determination to the Spanish ministry of economy and enterprise was rejected on April 1, 2019. Renaissance paid the CNMV a fine equal to 150,000 euros on June 26, 2019. (The monetary fine in 12(a) was converted into U.S. dollars using the exchange rate on the date of payment.) Renaissance's appeals to the Spanish national high court and the Spanish Supreme Court were rejected on June 18, 2020, and July 7, 2021, respectively.","ab":"Renaissance Technologies LLC","self":true,"firms":[106661],"id":1229},{"d":"2019-03-28","di":"2019-03-28","dr":"2019-03-28","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority (FCA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":44768316.4,"dk":"142888","al":"The FCA has imposed a financial penalty of £34,344,700 on Goldman Sachs international (\"GSI\") for failure to provide accurate and timely information in relation to certain reportable transactions to the financial conduct authority (\"FCA\") in alleged violation of sup 17.4.1EU, sup 17.1.4r and sup 15.6.1r. GSI also failed to take reasonable care to organise and control its affairs responsibly and effectively in respect of its transaction reporting in alleged violation of principle 3 of the FCA's principles for businesses. The fine was imposed pursuant to section 206 of the financial services and markets act 2000.","res":"Settled","sm":"The fine imposed by the financial conduct authority was in the amount of £49,063,900. However, Goldman Sachs international agreed to resolve the case and therefore qualified for a 30% discount in the overall penalty reducing the fine to £34,344,700. The fine was paid by wire on April 2, 2019. While the actual payment of the fine was made in pound sterling, the equivalent U.S. dollar value on the date of the wire was $44,768,316.4, which amount is reflected in item 12.a. Above.","ab":"Goldman Sachs","firms":[361],"id":1230},{"d":"2019-03-27","di":"2019-03-11","dr":"2019-03-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, disgorgement and restitution.","st":"Final","fine":38991.35,"dk":"LA4958","al":"Failure to fully disclose receipt of 12B1 payments in connection with the advisory clients' investments.","res":"Decision & Order of Offer of Settlement","sd":"Same information as 12(a). Date paid is pending.","sm":"Client accounts are coding to rebating 12B1 to their accounts.","ab":"Syndicated Capital, Inc.","self":true,"firms":[29037],"id":1231},{"d":"2019-03-27","di":"2012-12-27","dr":"2019-03-27","k":"Regulatory Action","rg":"Other","reg":"AutoritÉ Des MarchÉS Financiers","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":22000000.0,"dk":"DEC-DEJI/2010.65","al":"On December 28, 2012, Elliott Advisors (UK) limited (\"EAUK\") received a letter of grievance from the french financial market regulator, the AutoritÉ Des MarchÉS Financiers (the \"AMF\"), stating that EAUK may have purchased the stock of autoroutes paris rhin­RHÔne (\"APRR\") based on material nonpublic information relating to a potential sale of Elliott's APRR stake to eiffarie, APRR's majority owner. The AMF also stated that Elliott's APRR purchases during the relevant period may have caused the APRR stock price to be artificially inflated. On January 31, 2013, Elliott management corporation (\"EMC\") received a substantially identical letter of grievance from the AMF. The letter to EMC did not assert any new statements or set forth any new facts.","res":"Decision","sd":"The sanctions commission of the AMF assessed a penalty of 8 million euros against emc (approximately $11 million) and 8 million euros against eauk.","sm":"On May 5, 2014, eauk and emc received a written decision in an administrative proceeding from the sanctions commission of the AMF in France. The written decision (the \"AMF decision\") related to allegations by the AMF that Elliott purchased stock of aprr based on material nonpublic information and that Elliott manipulated the stock of aprr. In the AMF decision, the sanctions commission found that Elliott used material nonpublic information in the purchase of aprr shares between May 28, 2010 and June 11, 2010 but held that Elliott did not commit market manipulation or artificially inflate the price of aprr shares. The sanctions commission assessed a penalty of 8 million euros against emc and 8 million euros against eauk. Elliott disagrees with the findings against emc and eauk in this administrative proceeding. It remains Elliott's position that its trading in aprr's securities was lawful at all times. Elliott's purchases of aprr stock were made as part of a longstanding trading strategy dating back to 2005. Elliott purchased aprr stock on over 300 trading days between December 2005 and June 2010. Elliott has longstanding policies and procedures in place to prevent the misuse of material nonpublic information. Consistent with those procedures, Elliott had a chinese wall in place with respect to aprr during the period in question, and no material nonpublic information was transmitted to the personnel who directed the purchases of aprr stock. Despite an investigation which included extensive reviews of emails, audiotaped trading lines and interviews with witnesses, the AMF offered no evidence that Elliott's chinese wall was breached, but instead simply concluded that the circumstances supported their inference that the chinese wall was breached. Emc and eauk appealed the AMF decision to the paris Court of Appeals. On January 14, 2016, the paris Court of Appeals affirmed the AMF decision. Elliott disagrees with the decision of the paris Court of Appeals and emc and eauk appealed the decision to the french Supreme Court, the cour de cassation. On March 27, 2019, the cour de cassation affirmed the AMF decision. Elliott disagrees with the decision of the cour de cassation. On February 6, 2020, the european court of human rights declined to hear the application of emc and eauk. Emc and eauk subsequently submitted an application to the european commission regarding, among other things, the incorrect application of EU law, with a view to appealing the decision of the french courts. On June 21, 2021, Elliott was notified that the european commission had rejected the application. None of the costs associated with this matter (including the penalty assessed by the sanctions commission and the cost of the appeal) have been or will be borne by the Elliott funds, and Elliott continues to believe that this matter did not have an adverse impact on the funds.","ab":"Elliott Advisors (UK)","firms":[307151],"id":1232},{"d":"2019-03-22","di":"2019-03-22","dr":"2019-03-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":27500.0,"dk":"2016051140601","al":"On March 21, 2019, the firm entered into an AWC with Nasdaq. Without admitting or denying any findings by Nasdaq, the firm agreed to a fine of $27,500 with respect to its failure between 2015 and 2017 to maintain a continuous two-sided trading interest during regular market hours at prices within certain percentages away from the national best bid or offer (NBBO).","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $27,500.","sm":"Case no. 20160511406 (includes 20170545706 (includes 20170567114) and 20180594816). Subsequent to the review period, the firm updated its supervisory systems, including t+1 surveillance and an intraday review, therefore, enforcement is not recommending an undertaking.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1233},{"d":"2019-03-22","dr":"2019-03-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement; prejudgment interest","st":"Final","fine":2891389.48,"dk":"3-19114","al":"SEC admin release 34-85395 / March 22, 2019: the Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to section 15(b)(4) of the Securities Exchange Act of 1934 (\"Exchange Act\"), against Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill\" or \"respondent\"). The commission finds that these proceedings arise out of Merrill's improper practices with respect to securities lending transactions involving pre-released american depositary receipts (\"ADRS\"). ADR facilities, which provide for the issuance of ADRS, are established by a depositary bank (\"depositary\") pursuant to a deposit agreement (\"deposit agreement\"). Typically, a depositary issues ADRS to a market participant that contemporaneously delivers the corresponding number of foreign securities to the depositary's foreign CUSTODIAN (\"CUSTODIAN\"). However, in certain situations, deposit agreements may provide for \"pre- release\" transactions in which a market participant can obtain newly issued ADRS from the depositary before delivering ordinary shares to the CUSTODIAN. Only brokers (or other market participants) that have entered into pre-release agreements with a depositary (\"pre-release agreements\") can obtain pre-released ADRS from the depositary. The pre-release agreements, consistent with the deposit agreements, require the broker receiving the pre-released ADRS (\"pre-release broker\"), or its customer on whose behalf the pre-release broker is acting, to beneficially own the ordinary shares represented by the ADRS, and to assign all beneficial rights, title, and interest to those ordinary shares to the depositary while the pre-release transaction is outstanding. In effect, the pre-release broker or its customer becomes the temporary CUSTODIAN of the ordinary shares that would otherwise have been delivered to the CUSTODIAN. From at least June 2012 until approximately November 2014, Merrill received pre-released ADRS from pre-release brokers that had been issued by depositaries where neither the pre-release brokers nor Merrill had taken reasonable steps to satisfy the pre-release brokers' obligations under the pre-release agreements. Merrill, which was not a pre-release broker, understood that the ADRS that Merrill borrowed from pre-release brokers may have been sourced from depositaries pursuant to pre-release agreements. Merrill also understood that the beneficial ownership and other representations that pre-release brokers were required to make to depositaries in order to obtain pre-released ADRS. Merrill also understood the conduit nature of pre-release brokers' securities lending business, which under the circumstances should have indicated that the pre-release brokers did not own underlying ordinary shares. Merrill's associate persons on its securities lending desk, by obtaining ADRS from pre-release brokers in circumstances where they should have known that such ADRS likely had been pre-released without compliance with the pre-release brokers' obligations under the pre-release agreements, violated section 17(a)(3) of the Securities Act of 1933 (\"Securities Act\"). Merrill's supervisory policies and procedures were not reasonably designed and implemented to provide sufficient oversight of associated persons to prevent and detect their violations of section 17(a)(3) of the Securities Act. As a result, Merrill failed reasonably to supervise its associated persons within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"Merrill submitted an offer of settlement (the \"offer\") which the commission has determined to accept. Merrill failed reasonably to fulfill its supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Exchange Act. Solely for the purpose of settling these proceedings, Merrill consented to the order without admitting or denying the findings in the order, except as to the SEC's jurisdiction over it and the subject matter. The SEC ordered that Merrill is censured and shall pay disgorgement of $4,448,291.52 together with prejudgment interest of $724,795.40 and a civil money penalty of $2,891,389.48.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1234},{"d":"2019-03-21","di":"2019-03-21","dr":"2019-03-21","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Office of the Attorney General of South Carolina","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"MATTER NO. 20181123","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the Office of the Attorney General of South Carolina (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in South Carolina; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1235},{"d":"2019-03-21","di":"2019-03-21","dr":"2019-03-21","k":"Regulatory Action","rg":"Other","reg":"BAFIN (Bundesanstalt FÜR Finanzdienstleistungsaufsicht)","san":"Other","os":"Notification-no further action","st":"Final","dk":"WA L3-WP 5320-40001085-2019/0008","al":"On thursday, March 21, 2019, BAFIN, the german federal financial supervisory authority, notified black creek that it failed to notify BAFIN and an issuer in a timely fashion when a prescribed disclosure threshold had been crossed as required under section 33 et seq of the german securities trading act. BAFIN has notified black creek that it does not intend to take any further action at this time.","res":"Other","sd":"N/a","sm":"BAFIN has notified black creek that it does not intend to take any further action at this time. No information Filed","ab":"Black Creek Investment Management Inc.","self":true,"firms":[161344],"id":1236},{"d":"2019-03-20","di":"2019-01-31","dr":"2019-03-20","k":"Regulatory Action","rg":"Other","reg":"Oregon Division of Financial Regulation","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"CASE NO. S-18-0034","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Oregon Division of Financial Regulation (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Oregon; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Oregon statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1237},{"d":"2019-03-18","di":"2019-03-18","dr":"2019-03-18","k":"Regulatory Action","rg":"Other","reg":"Oklahoma Department of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"ODS FILE NO. 18-094","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Oklahoma Department of Securities (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Oklahoma; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Oklahoma statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1238},{"d":"2019-03-13","di":"2018-03-27","dr":"2019-03-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","st":"Final","fine":250000.0,"dk":"3-18411","al":"SEC admin release 34-82954 / March 27, 2018: the Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to sections 15(b) of the Securities Exchange Act of 1934 (\"Exchange Act\") against Wedbush Securities, inc. (\"Wedbush\" or \"respondent\"). The division of enforcement alleges that Wedbush failed reasonably to supervise one of its registered representatives who engaged in manipulative trading activity of penny stocks over multiple years, as detailed below. Wedbush was aware of certain aspects of the registered representative's activity in 2012 and 2013 but its supervisory policies and implementation systems failed reasonably to guide staff on how to investigate the activity. Specifically, in late 2012 and early 2013, the registered representative's supervisors: (1) reviewed an email outlining her role in fraudulent transactions involving penny stocks; (2) received copies of two FINRA arbitrations filed by her customers outlining serious allegations of her role in their investments in the same penny stock issuers; (3) learned of a FINRA inquiry into her personal trading in one of those penny stock issuers; and (4) learned of a separate FINRA inquiry into the allegations underlying the customer arbitrations. Wedbush had no clear process for how to handle red flags of potential market manipulation. As a result of the conduct described, Wedbush failed reasonably to supervise an individual with a view to preventing and detecting violations of sections 17(a)(1) and (3) of the Securities Act, sections 9(a)(2) and 10(b) of the Exchange Act and rule 10B-5(a) and (c) thereunder.","res":"Order","sd":"Wedbush is censured and shall pay a civil money penalty in the amount of $250,000.","sm":"Respondent has submitted an offer of settlement (the \"offer\") which the commission has determined to accept. In view of the foregoing, the commission deems it appropriate to impose the sanctions agreed to in respondent's offer. Accordingly, it is hereby ordered that respondent is censured and shall pay a civil money penalty in the amount of $250,000. On May 31, 2018, the former president of Wedbush was succeeded by two new co-presidents. Since that time, the co-presidents have taken certain remedial measures to improve Wedbush's supervision of its registered representatives.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1239},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","dk":"3-19087","al":"In June of 2018, the firm voluntarily self-reported that some customers eligible to purchase mutual funds which did not charge 12B-1 fees did not receive the available less expensive share class. As a result, the firm estimated that eligible customers were overcharged $215,761 plus pre judgement interest for mutual fund purchases made since January 1, 2014. The firm agrees to pay restitution plus interest, as well as to review its related disclosures and procedures. The firm has had procedures in place intended to address this issue for more than a decade.","res":"Other","sd":"The firm has submitted an offer of settlement, which has been accepted by the commission. The firm shall cease and desist from committing or causing any violations and any future violations of sections 206(2) and 207 of the Advisers Act. Respondent is censured, shall pay disgorgement of $215,761.17 and prejudgment interest of $25,465.87, and shall comply with the undertakings enumerated in the offer of settlement.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1240},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","dk":"3-19092","al":"The SEC alleged that Stifel willfully violated sections 206(2) and 207 of the Investment Advisers Act of 1940 (the \"Advisers Act\") as a result of (a) its inadequate disclosure of conflicts of interest related to (a) the selection of mutual fund share classes that charged 12B-1 fees, which are recurring fees deducted from fund's assets, when an alternative share class was available that did not charge a 12B-1 fee; and (b) the receipt of 12B-1 fees in connection with these investments.","res":"Order","sm":"In March 2019, Stifel, along with 78 other investment advisers who voluntarily participated in the SEC's share class selection disclosure initiative, consented to the entry of an order instituting administrative and cease-and-desist proceedings pursuant to sections 203(e) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (the \"order\") by the SEC instituted pursuant to sections 203(e) and 203(k) of the Advisers Act without admitting or denying the findings therein except those related to jurisdiction and the subject matter of the proceedings. The order entered against Stifel alleged that Stifel willfully violated sections 206(2) and 207 of the Advisers Act as a result of its inadequate disclosure of conflicts of interest related to (a) the selection of mutual fund share classes that charged 12B-1 fees, which are recurring fees deducted from fund's assets, when an alternative share class was available that did not charge a 12B-1 fee; and (b) the receipt of 12B-1 fees in connection with these investments. The SEC did not impose a civil penalty against Stifel in recognition of the fact that Stifel self-reported the issue to the SEC. however, Stifel was censured and ordered to cease-and-desist from committing or causing any violations and future violations of sections 206(2) and 207 of the Advisers Act, pay disgorgement and pre-judgment interest in the amount of $6,037,175.98 to affected investors, and comply with several undertakings related to notifying affected investors of the terms of the order.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1241},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","dk":"FILE NO. 3-19099","al":"The order alleges Stephens Inc. breached its fiduciary duty to clients and violated sections 206(2) and 207 of the Advisers Act in that Stephens Inc. purchased, recommended or held for client accounts mutual fund share classes that paid Stephens Inc. 12B-1 fees but failed to adequately disclose conflicts of interest with these share classes in that cheaper share classes of the same funds were available to clients which did not pay 12B-1 fees.","res":"Order","sd":"Stephens Inc. was ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 207 of the Investment Advisers Act of 1940. Further, Stephens Inc. was censured and ordered to pay disgorgement of $5,000,738.11 and prejudgment interest of $488,381.23 and ordered to comply with the undertakings enumerated in the offer of settlement.","sm":"Within the space provided). Stephens Inc. voluntarily participated in the SEC's share class selection disclosure initiative which related to mutual fund shares sold to Stephens Inc. advisory clients. The order alleged that Stephens Inc. did not adequately disclose conflicts of interest related to the selection of mutual fund share classes for advisory clients which paid Stephens Inc. 12B-1 fees when less expensive share classes of the same fund were available which did not pay Stephens Inc. these 12B-1 fees. Stephens agreed to restitution to affected clients of these fees in the amount of $5,000,738.11 plus prejudgment interest of $488,381.23. (Ia release number 40-5196, March 11, 2019).","ab":"Stephens Inc.","self":true,"firms":[3496],"id":1242},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","dk":"3-19039","al":"The securities exchange commission (\"commission\") found that at times during the relevant period, LPL Financial LLC (\"LPL\") purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. LPL also failed to disclose in its form ADV or otherwise the conflicts of interest related to (a) its receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. As a result of this aforementioned conduct, it was determined LPL willfully violated sections 206(2) and 207 of the Advisers Act.","res":"Order","sm":"LPL submitted an offer of settlement which the commission accepted. In view of the foregoing, the commission deemed it appropriate in the public interest to impose the sanctions agreed to in LPL's offer. LPL self-reported to the commission the violations discussed in this order pursuant to the division of enforcement's share class selection disclosure initiative (\"SCSD initiative\"). Accordingly, the order and LPL's offer are based on the information LPL self-reported.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1243},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"FILE NO. 52367","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Minnesota Department of Commerce (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Minnesota; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Minnesota statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1244},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Censure","os":"Cease and desist","st":"Final","dk":"3-19035","al":"During the period January 1, 2014, to March 27, 2014, Commonwealth purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. Commonwealth and its associated persons received 12B-1 fees in connection with these investments. The Securities and Exchange Commission (\"SEC\") found that Commonwealth failed to disclose in its form ADV or otherwise the conflicts of interest related to its receipt of 12B-1 fees and/or its selection of mutual fund share classes that pay such fees. As a result of these disclosure failures, the SEC found that Commonwealth violated sections 206(2) and 207 of the Advisers Act.","res":"Order","sd":"Without admitting or denying guilt Commonwealth consented to a cease and desist, censure, and disgorgement of $1,426,700.16 and prejudgment interest of $210,603.29.","sm":"Pursuant to the division of enforcement's share class selection disclosure initiative, Commonwealth self-reported these violations to the SEC. on March 11, 2019, the SEC accepted Commonwealth's offer of settlement and entered an administrative order.","ab":"Commonwealth Equity Services, LLC","self":true,"firms":[8032],"id":1245},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","dk":"3-19051","al":"Ia release 40-5148, March 11, 2019: the Securities and Exchange Commission deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be instituted against Robert W. Baird & Co. Incorporated (\"respondent\"). On the basis of this order and respondent's offer, the commission finds that these proceedings arise out of breaches of fiduciary duty and inadequate disclosures by the respondent in connection with its mutual fund share class selection practices and the fees it received. At times during the relevant period, respondent purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. Respondent received 12B-1 fees in connection with these investments. Respondent failed to disclose in its form ADV or otherwise the conflicts of interest related to (a) its receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. During the relevant period, respondent received 12B-1 fees for advising clients to invest in or hold such mutual fund share classes. As a result of the conduct, respondent willfully violated sections 206(2) and 207 of the Advisers Act.","res":"Order","sd":"The respondent shall cease and desist from committing or causing any violations and any future violations of sections 206(2) and 207 of the Advisers Act. Respondent is censured, shall pay disgorgement of $3,946,606.10 and prejudgment interest of $212,561.34, and shall comply with the undertakings enumerated in the offer of settlement.","sm":"Robert W. Baird & Co. Incorporated (BAIRD), along with many other investment advisory firms, voluntarily participated in the SEC's share class selection disclosure (or SCSD) initiative. Under the SCSD initiative, investment advisory firms were offered the opportunity to voluntarily self-report violations of the federal securities laws relating to mutual fund share class selection and related disclosure issues and agree to standardized settlement terms imposed by the SEC, including returning money to affected investors. The central issue identified by the SEC in establishing the SCSD initiative was that, in many cases, investment advisory firms bought for or recommended to their clients mutual fund share classes that had distribution or service fees (commonly known as 12B-1 fees) paid out of fund assets to the firms when lower-cost share classes were available to those clients, and the investment advisory firms did not adequately disclose the conflict of interest associated with those share classes. On March 11, 2019, the SEC issued orders under the SCSD initiative to a total of 79 investment advisers (including BAIRD) reflecting the standardized settlement terms. Additional orders are expected to be issued to more firms. The order pertains to BAIRD's private wealth management (PWM) investment advisory business. BAIRD's asset management business and the BAIRD funds were not subject to the order. In response to the SEC's share class selection disclosure initiative, BAIRD has made changes to its PWM investment advisory programs in which mutual funds available in those programs do not include share classes that pay 12b- 1 fees. The mutual fund share classes available to clients in BAIRD's investment advisory programs are generally those that are lowest cost share classes most widely offered by each mutual fund family across its various funds to most types of eligible investors.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1246},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Disgorgement","os":"Censure, cease and desist","st":"Final","dk":"3-19102","al":"Pursuant to the SEC share class selection disclosure initiative and without admitting or denying the SEC's findings, Wells Fargo Clearing Services LLC (\"WCFS\") and Wells Fargo Advisors Financial Network, LLC (\"respondents\"), jointly and severally, consented to the entry of a SEC order alleging that respondents willfully violated section 206(2) of the Investment Advisers Act of 1940 (\"Advisers Act\") and section 207 of the Advisers Act, in that respondents did not adequately disclose to their clients in either their forms ADV or otherwise their conflicts of interest relating to (a) their receipt of 12B-1 fees and (b) their selection of mutual fund share classes that pay such fees.","res":"Order","sm":"The firm self-reported to the commission the violations in the order pursuant to the division of enforcement's (the \"division\") share class selection disclosure initiative.","ab":"Wells Fargo Advisors Financial Network, LLC; Wells Fargo Clearing Services, LLC","self":true,"firms":[11025,19616],"id":1247},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","dk":"3-19101","al":"The SEC alleged that RBCCM, during the period January 1, 2014 through March 27, 2017, failed to make adequate disclosures, in its form ADV or otherwise, regarding its mutual fund share class selection practices, and the 12B-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBCCM purchased, recommended or held in advisory accounts mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes in the same fund. The SEC alleged that RBCCM failed to adequately disclose the receipt of the 12B-1 fees and the conflict created thereby, thereby allegedly willfully violating sections 206(2) and 207 of the Investment Advisers Act.","res":"Order","sm":"The firm has submitted an offer of settlement which the commission has determined to accept. In view of the foregoing, the commission deems it appropriate in the public interest to impose the sanctions agreed to in the respondent's offer. Respondent self-reported to the commission the violations discussed in this order pursuant to the division of enforcement's share class selection disclosure initiative (\"SCSD initiative\"). Accordingly, this order and respondent's offer are based on the information self-reported by respondent.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1248},{"d":"2019-03-11","di":"2019-03-11","dr":"2019-03-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, disgorgement, prejudgment interest, and undertakings","st":"Final","dk":"ADMIN. PROCEEDING FILE NO. 3-19029","al":"Raymond James Financial Services Advisors, Inc. (\"RJFSA\") entered into a settlement with the U.S. Securities and Exchange Commission (\"SEC\") pursuant to the SEC's share class selection disclosure initiative. Pursuant to the SEC's order dated March 11, 2019, the SEC found that at times between January 1, 2014, to February 16, 2018, RJFSA purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible, and did not disclose adequately in its form ADV or otherwise the conflicts of interest related to (a) its associated persons' receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. As a result of that conduct, the SEC found that RJFSA willfully violated sections 206(2) and 207 of the Advisers Act.","res":"Settled","sd":"The order requires rjfsa to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 207 of the Advisers Act. In addition, the order censured rjfsa and ordered it to pay to affected investors disgorgement of $6,181,028.07 and prejudgment interest of $696,020.04, which had already been paid by February 12, 2019. Lastly, the order caused rjfsa to review and correct as necessary all relevant disclosure documents, evaluate whether clients should be moved to a lower-cost share class and move client as necessary, evaluate, update, and review policies and procedures, and notify affected investors of the settlement terms.","sm":"Rjfsa self-reported the conduct discussed in the order pursuant to the SEC's share class selection disclosure initiative. Without admitting or denying the SEC's findings, rjfsa submitted an offer of settlement, which the SEC accepted, that consented to the entry of the order. In determining to accept rjfsa's settlement offer, the SEC considered that rjfsa had self-reported its conduct to the SEC. the allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"Raymond James Financial Services Advisors, Inc","self":true,"firms":[149018],"id":1249},{"d":"2019-03-05","di":"2019-01-15","dr":"2019-03-05","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"N/A","al":"The securities and exchange board of india (\"SEBI\") alleged that JPMorgan Asset management (asia pacific) limited (jpmam(AP)), then known as JF asset management limited, violated regulation 19(2) of the securities contracts (regulation) (stock exchanges and clearing corporations) regulations, 2012 rescinded and replaced with securities contracts (regulation) (stock exchanges and clearing corporations) regulations, 2018.","res":"Other","sm":"On March 5, 2019 the securities and exchange board of india (\"SEBI\") passed a settlement order regarding the late application to acquire shares in multi commodity exchange of india limited (\"MCX\"), a recognized stock exchange in india. Pursuant to regulation 19(2) of the securities contracts (regulation) (stock exchanges and clearing corporations) regulations, 2012 rescinded and replaced with securities contracts (regulation) (stock exchanges and clearing corporations) regulations, 2018, jpmam(AP) was required to apply for SEBI's approval within fifteen days of its aggregated shareholding representing greater than 2% of MCX. Jpmam(AP), on behalf of certain client accounts, acquired shares representing in aggregate greater than 2% of MCX on January 27, 2017 and, upon realizing the inadvertent omission in seeking approval from SEBI, jpmam(AP) submitted the application for approval on February 28, 2018. SEBI granted approval on April 23, 2018. On January 15, 2019 SEBI issued a notice of summary settlement regarding the above matter. On February 11, 2019, jpmam(AP) accepted the proposed settlement and paid the settlement amount of 515,625 rupees (approximately $7,500).","ab":"JPMorgan Asset","firms":[79],"id":1250},{"d":"2019-03-04","di":"2019-03-04","dr":"2019-03-04","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3500.0,"dk":"20140406430","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of enforcement on behalf of NYSE regulation alleged that Goldman Sachs execution and clearing, L.P. (\"GSEC\"), a former affiliate of Goldman Sachs & Co. LLC (the \"firm\") failed to establish and maintain a supervisory system reasonably designed to ensure compliance with section 15(c)(3) of the Securities Exchange Act of 1934 and rule 15C3-5 thereunder in alleged violation of NYSE ARCA equities rule 6.18. On June 12, 2017, GSEC and the firm consummated a merger of GSEC with and into the firm (the \"merger\"), with the firm surviving the merger and assuming any remaining GSEC assets, liabilities and operations. On June 13, 2017, GSEC filed a uniform request withdrawal from broker-dealer registration (form BDW) with the Securities and Exchange Commission, which became effective on August 11, 2017.","res":"Consent","sm":"FINRA imposed a fine for minor rule violations in the amount of $3,500, which was paid by the submission of a wire on March 19, 2019.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1251},{"d":"2019-03-04","di":"2019-03-04","dr":"2019-03-04","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Bureau of Securities Regulation","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"INV2018-000222","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the New Hampshire Bureau of Securities Regulation (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Hampshire; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Hampshire statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1252},{"d":"2019-02-25","di":"2019-02-25","dr":"2019-02-25","k":"Regulatory Action","rg":"Other","reg":"Reserve Bank of India (\"Rbi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":144952.0,"dk":"EFD.CO.SO/590/02.03.044/2018-19","al":"The Reserve Bank of India (\"Rbi\") alleged that the firm's reconciliation of logs generated from swift was not sufficient and violated the direction of the RBI.","res":"Order","sm":"The rbi ordered the firm to pay a monetary penalty in the amount of INR10,000,000, which is approximately usd $144,952.00.","ab":"Bank of America, National","firms":[142558],"id":1253},{"d":"2019-02-21","di":"2017-11-29","dr":"2019-02-21","k":"Regulatory Action","rg":"U.K. FCA","reg":"U.K. Financial Conduct Authority","san":"Other","os":"No sanctions were imposed","st":"Final","dk":"CMP/01-2016/CA98","al":"On 21 February 2019, the UK financial conduct authority (\"FCA\") found that Newton Investment Management limited (\"NIM\"), through the actions of a former employee in 2014 and 2015, shared information with three other UK investment advisers in relation to two initial public offerings and one placing by UK issuers by disclosing the price it intended to pay, or accepting such information, or both, shortly before the share prices were set. The FCA found that parts of this conduct violated the UK competition act 1998. NIM self-reported this matter to the FCA following identification of the issue. The former employee's actions contravened NIM's code of conduct and ethical standards, and the employee has since been dismissed. The Bank of New York Mellon Corporation (\"BNYM\") was found jointly and severally liable by reason of being NIM's ultimate parent company. Neither BNYM nor any of its employees was involved in any aspect of the relevant conduct and there has been no allegation nor negative finding by the FCA in respect of the conduct of BNYM.","res":"Order","sd":"Not applicable","sm":"Provided). The FCA issued their decision on 21 February 2019. The FCA will publish a non-confidential version of its decision under the competition act 1998 in due course.","ab":"The Bank of New York; The Bank of New York Mellon; The Bank of New York Mellon Corporation","firms":[231,105642,111208,145995],"id":1254},{"d":"2019-02-18","di":"2019-02-18","dr":"2019-02-18","k":"Regulatory Action","rg":"State regulator","reg":"Rhode Island Division of Business Regulation Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"18-SC-002","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Rhode Island Division of Business Regulation Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Rhode Island; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Rhode Island statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1255},{"d":"2019-02-14","di":"2019-02-14","dr":"2019-02-14","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Office of the Attorney General of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"20167652","al":"The Securities Division of the Office of the Attorney General of South Carolina (division) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of S.C. Code ann. Section 35-1-411(c)(1) and S.C. Code of regulations section 13-405(a)(1).","res":"Consent","sm":"Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1256},{"d":"2019-02-13","di":"2018-01-29","dr":"2019-02-13","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Cease and Desist","os":"Civil penalties","st":"Final","fine":8750.0,"dk":"98079","al":"Failure to timely complete state notice registration, file required state notice filings and pay all associated fees in the state of Florida upon meeting de minimis requirements","res":"Consent","sd":"Total civil penalty of $8750.00. Payment of $5500.00 settlement recorded paid on 2/13/2019","sm":"Action arose from routine examination by state of Florida regulatory agency in which it was determined that the firm and jay Malik failed to timely amend MR. Malik's investment advisor representative U-4 application concerning material changes of MR. Malik's investment advisory activity in the state of Florida.","ab":"Malik, Jay","firms":[137080],"id":1257},{"d":"2019-02-04","dr":"2019-02-04","k":"Regulatory Action","rg":"Other","reg":"Foreign - Commissione Nazionale Per Le Societa E la Borsa (Consob)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":180000.0,"dk":"RESOLUTION NO. 20749","al":"Pursuant to regulation (EU) no. 236/2012 on short selling (the \"regulation\"), merian global investors (UK) limited (\"MGI\") is required to file net short position reports (the \"reports\") with the commissione nazionale per le societa e la borsa (\"CONSOB\") when certain prescribed thresholds are crossed. In November 2017, MGI's compliance function identified an error in the monitoring of such thresholds. MGI immediately commenced an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. On January 10 2018, MGI notified the CONSOB of its inadvertent failure to file the reports during the period between July 2014 and January 2018. MGI filed the delinquent reports and put appropriate controls in place to mitigate the risk of the error reoccurring. CONSOB subsequently found that MGI breached the regulation by failing to file such reports. In making its determination, CONSOB noted that the breach did not mislead investors or generate any profit for MGI. Additionally, MGI adopted a collaborative approach with CONSOB and did not have any previous violations sanctioned by CONSOB concerning financial matters.","res":"Consent","sd":"See details in number 13 below","sm":"On December 13 2018, consob issued an admisntrative sanction that determined that mgi breached the regulation and imposed a fine of eur 160,000 (approximately usd 180,000). Mgi paid the fine in full effective February 4 2019. No information Filed","ab":"Jupiter Investment","firms":[306863],"id":1258},{"d":"2019-02-01","di":"2019-02-01","dr":"2019-02-01","k":"Regulatory Action","rg":"Other","reg":"Hawaii Department of Commerce and Consumer Affairs","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"SEU-2018-014","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Hawaii Department of Commerce and Consumer Affairs (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Hawaii; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Hawaii statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1259},{"d":"2019-01-31","di":"2019-01-31","dr":"2019-01-31","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Division of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"2017-0591","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Maryland Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Maryland; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Maryland statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1260},{"d":"2019-01-28","di":"2019-01-28","dr":"2019-01-28","k":"Regulatory Action","rg":"Other","reg":"U.S. Virgin Islands Division of Banking, Insurance and Financial Regulation","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"N/A","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the U.S. Virgin Islands Division of Banking, Insurance and Financial Regulation (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in the U.S. virgin islands; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any U.S. virgin islands statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1261},{"d":"2019-01-24","dr":"2019-01-24","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"SD-18-0041","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Utah Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Utah; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Utah statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1262},{"d":"2019-01-22","di":"2019-01-22","dr":"2019-01-22","k":"Regulatory Action","rg":"State regulator","reg":"Wisconsin Division of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"S-238691(LX)","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Wisconsin Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Wisconsin; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Wisconsin statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1263},{"d":"2019-01-22","di":"2019-01-22","dr":"2019-01-22","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"S-16-0069-OR02","al":"The Arkansas Securities Department (department) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements, in violation of rule 306.01 of the Arkansas securities commissioner.","res":"Consent","sm":"Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arkansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1264},{"d":"2019-01-17","di":"2019-01-17","k":"Regulatory Action","dk":"PLBS 12640-A","ab":"Mckay, Michael, David","firms":[7691],"id":1265},{"d":"2019-01-11","di":"2019-01-11","dr":"2019-01-11","k":"Regulatory Action","rg":"Other","reg":"Arizona Corporation Commission","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"S-21062A-18-0365","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Arizona Corporation Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Arizona; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arizona statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1266},{"d":"2019-01-10","di":"2019-01-10","dr":"2019-01-10","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Division of Securities","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"2018-CDS-062","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Colorado Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Colorado; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Colorado statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1267},{"d":"2019-01-08","di":"2017-10-16","dr":"2019-01-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000000.0,"dk":"2016-07-01264","al":"Failure to oversee and supervise the trading activities of its president","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured, fined $1,000,000 (($900,000 of which is payable jointly and severally) and required to complete the undertakings as stated in the offer of settlement, including to hire an outside auditing firm, not unacceptable to NYSE regulation staff, to assist its internal audit department in conducting internal audits. Wedbush Securities shall (I) complete a comprehensive review of the firm's compliance program; (II) implement changes and enhancements; and (III) work together with an independent consultant concerning the areas to be reviewed. Wedbush Securities shall also hire an additional permanent, full-time, senior employee with relevant regulatory experience to work in these areas.","sm":"Without admitting or denying the allegations, Wedbush Securities Inc. (\"Wedbush\" or the \"firm\") consented to the sanctions and to the entry of findings","ab":"Wedbush, Edward William","firms":[877],"id":1268},{"d":"2019-01-08","di":"2017-10-16","dr":"2019-01-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":1000000.0,"dk":"2016-07-01264","al":"Wedbush Securities Inc. (the firm, wedb, or respondent) was named a respondent in a FINRA complaint alleging that it knew and systemically failed to oversee and supervise the trading activities of its principal, edward w. Wedbush (\"MR. Wedbush\"). The complaint alleges that in addition to serving as the president of wedb and the chairman of wedb's parent company, Wedbush, inc., MR. Wedbush spent several hours each trading day actively managing and trading in more than 70 accounts (collectively, the \"ew controlled accounts\"). Despite MR. Wedbush's active trading in dozens of customer, personal, and proprietary accounts, respondents failed to implement any process to monitor or supervise MR. Wedbush's order entry, trade executions, or trade allocations in the ew controlled accounts, including for potential conflicts of interest and potential manipulative activity. The absence of monitoring or supervision of his trading activities allowed MR. Wedbush to handle the ew controlled accounts in an unfettered manner that was not permitted for other traders at the firm. For example, MR. Wedbush regularly instructed a firm employee to enter orders under a general account, waiting until the end of the trading day to allocate executed trades among the various ew controlled accounts (I.E., to customers, personal accounts, or proprietary accounts). MR. Wedbush's post-execution allocations were determined based entirely on his own discretion, and the firm had no process to ensure that trade allocations among the ew controlled accounts were not being made to steer profitable trades to preferred ew controlled accounts or for other improper purposes. MR. Wedbush's orders for the ew controlled accounts were made and executed on a separate trading platform, not used by other wedb traders. And no other Wedbush employees, besides MR. Wedbush, were allowed to make post-execution allocations. The complaint also alleges that in managing the ew controlled accounts, MR. Wedbush: (I) handled various customer accounts together with proprietary and personal accounts, in the same securities at the same time; (II) \"bunched\" orders for the ew controlled accounts; (III) failed to record account names or designations prior to trade execution and thereby wedb willfully violated section 17(a) of the Securities Exchange Act of 1934, and rules 17A-3 and 17A-4 thereunder; and (IV) waited until after trade execution to allocate trades among the ew controlled accounts. The complaint further alleges that wedb and MR. Wedbush failed to mark proprietary orders with the appropriate designator. The firm, however, took no meaningful action to address a co-CCO's compliance concerns about the lack of supervision of MR. Wedbush's trading with the audit committee of wedb's board of directors. Wedb's supervisory systems and procedures were inadequate and were not reasonably designed for its business as it related to the ew controlled accounts. The firm failed to establish, implement, and enforce adequate supervisory systems and procedures, including WSPS, reasonably designed to supervise MR. Wedbush and the ew controlled accounts to achieve compliance with the federal securities laws and exchange rules, respondents violated NYSE ARCA rules.","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured, fined $1,000,000 (($900,000 of which is payable jointly and severally) and required to complete the undertakings as stated in the offer of settlement, including to hire an outside auditing firm, not unacceptable to NYSE regulation staff, to assist its internal audit department in conducting internal audits. Wedbush Securities shall (I) complete a comprehensive review of the firm's compliance program; (II) implement changes and enhancements; and (III) work together with an independent consultant concerning the areas to be reviewed. Wedbush Securities shall also hire an additional permanent, full-time, senior employee with relevant regulatory experience to work in these areas.","sm":"Without admitting or denying the allegations, Wedbush Securities Inc. (\"Wedbush\" or the \"firm\") consented to the sanctions the firm was censured, fined $1,000,000 (($900,000 of which is payable jointly and severally) and required to complete the undertakings as stated in the offer of settlement, including to hire an outside auditing firm, not unacceptable to NYSE regulation staff, to assist its internal audit department in conducting internal audits. Wedbush Securities shall (I) complete a comprehensive review of the firm's compliance program; (II) implement changes and enhancements; and (III) work together with an independent consultant concerning the areas to be reviewed. Wedbush Securities shall also hire an additional permanent, full-time, senior employee with relevant regulatory experience to work in these areas.","ab":"Wedbush, Edward William","firms":[877],"id":1269},{"d":"2019-01-02","di":"2017-11-30","dr":"2019-01-02","k":"Regulatory Action","rg":"Other","reg":"California Department of Insurance","san":"Other","os":"Administrative proceeding initiated","st":"Final","fine":10345816.0,"dk":"LA2016000665-AP","al":"The California Department of Insurance filed a disciplinary action for alleged improper sales practices between 2008 and 2016 concerning the bank's online insurance referral program for renters and simplified-issue term life insurance. The insurance products were offered by referral through third-party carriers american modern insurance group, assurant, great west financial, and prudential insurance company. The California Department of Insurance alleges that Wells fargo's actions are grounds for suspending or revoking the insurance licenses for Wells Fargo Bank, N.A. and Wells fargo insurance, inc.","res":"Settled","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1270},{"d":"2018-12-31","di":"2018-12-31","dr":"2018-12-31","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"2018-7-03","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Idaho Department of Finance (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Idaho; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Idaho statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1271},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - California","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":148733525.16,"dk":"18-ST-CV-09856","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1272},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Alaska","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1486804.01,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1273},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Wisconsin","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8565813.31,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1274},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - West Virginia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1652275.25,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1275},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Vermont","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1984047.03,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1276},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Washington","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":16147093.34,"dk":"18-2-06490-34","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1277},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Utah","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10232596.05,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1278},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Virginia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":11546080.48,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1279},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Tennessee","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4989322.01,"dk":"19C69","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1280},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Texas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":47378217.69,"dk":"D-1-GN-18-007683","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1281},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - South Dakota","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1827596.64,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1282},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6788785.83,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1283},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Rhode Island","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1216915.47,"dk":"PC-2018-9401","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1284},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Pennsylvania","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":16526551.91,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1285},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Oklahoma","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2640251.14,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1286},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Ohio","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2974953.32,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1287},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - North Dakota","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1215310.89,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1288},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - North Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15174791.4,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1289},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - New York","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":11854349.87,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1290},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - New Jersey","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":16989709.6,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1291},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - New Hampshire","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1167689.76,"dk":"217-2018-CV-00811","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1292},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Alabama","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7945123.52,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1293},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - New Mexico","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6449106.0,"dk":"D-101-CV-2018-02395","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1294},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Michigan","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5235475.56,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1295},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Wyoming","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1603894.35,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1296},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Oregon","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":9766546.95,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1297},{"d":"2018-12-28","di":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Nebraska","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5210423.09,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1298},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Nevada","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":13363512.8,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1299},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Montana","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2779651.69,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1300},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Mississippi","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2538491.41,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1301},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Missouri","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5616485.55,"dk":"18AC-CC00516","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1302},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Minnesota","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":9361299.85,"dk":"62-CV-18-8322","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025],"id":1303},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Maryland","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7916350.19,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1304},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6182546.05,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1305},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Maine","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1136559.61,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1306},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Louisiana","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1911733.65,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1307},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Kentucky","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3675446.17,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1308},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Kansas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2307874.13,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"State Attorney General -; Wells Fargo & Company","firms":[11025,19616],"id":1309},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Iowa","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6180941.33,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1310},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5202676.45,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1311},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Illinois","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10857474.49,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1312},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Idaho","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5276628.87,"dk":"CV01-18-23986","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1313},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Hawaii","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1468038.75,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1314},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Georgia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":16346293.31,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1315},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Florida","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":28301139.58,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1316},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - District of Columbia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1112853.08,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1317},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Delaware","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2007548.53,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1318},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5242279.59,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1319},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Colorado","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":21476334.34,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1320},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Arizona","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":37136571.08,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1321},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Arkansas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1298019.87,"al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1322},{"d":"2018-12-28","di":"2018-12-28","dr":"2018-12-28","k":"Regulatory Action","rg":"State regulator","reg":"State Attorney General - Minnesota","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000000.0,"dk":"62-CV-18-8322","al":"Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.","res":"Settled","ab":"Wells Fargo & Company","firms":[19616],"id":1323},{"d":"2018-12-27","di":"2018-12-18","dr":"2018-12-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":100000.0,"dk":"3-18937","al":"In 2018 Ancora Advisors LLC discovered, through a routine SEC review, that some employee contributions, over the $350 allowable limit and not in compliance with rule 206(4)-5, were made.","res":"Decision & Order of Offer of Settlement","sd":"Ancora Advisors LLC satisfied the fine of $100,000 on 12/27/2018.","sm":"Ancora Advisors LLC satisfied the fine of $100,000 on 12/27/2018. No information Filed","ab":"Ancora Advisors LLC","self":true,"firms":[124674],"id":1324},{"d":"2018-12-26","di":"2018-12-26","dr":"2018-12-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":10000000.0,"dk":"2014041196601","al":"FINRA alleged that MSSB violated FINRA rules 3310(a) and 2010 and NASD rule 3010(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 26, 2018, the firm and FINRA entered into an AWC in connection with allegations that the firm failed to: (1) develop and implement an anti-money laundering (AML) program that was reasonably designed to achieve and monitor the firm's compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations, including the failure to establish and implement policies and procedures that were reasonably designed to detect and cause the reporting of potentially suspicious activity in certain respects; (2) establish and maintain a supervisory system reasonably designed to achieve compliance with section 5 of the Securities Act of 1933 (Securities Act) and applicable rules and regulations; and (3) implement its policies, procedures, and internal controls reasonably designed to achieve compliance with the BSA and its implementing regulations by failing to conduct risk-based reviews of the correspondent accounts of certain foreign financial institutions, as required by the BSA and its implementing regulations and the firm's policies and procedures. Without admitting or denying the findings, the firm consented to the entry of findings, the imposition of a fine in the amount of $10,000,000 and a censure.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1325},{"d":"2018-12-26","di":"2018-12-26","dr":"2018-12-26","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":400000.0,"dk":"ADMINSTRATIVE PROCEEDING FILE NO. 3-18958","al":"According to the order, Lightyear failed to properly allocate certain expenses (I) to the employee funds which invest side-by- side on a proportional basis with certain private equity funds advised by Lightyear and its affiliates (the \"flagship funds\") and (II) to certain co-investors that were permitted at times to invest in particular portfolio companies of the flagship funds. According to the order, Lightyear failed to properly offset management fees in connection with undisclosed fee-sharing agreements with certain co-investors. The order states that Lightyear failed to adopt written policies and procedures reasonably designed to prevent these violations of the Advisers Act and also failed to adopt and implement written policies and procedures related to a representation made in each of the limited partnership agreements of its flagship funds which stated that Lightyear would seek to have prospective portfolio companies bear the cost of broken deal expenses.","res":"Settled","sd":"Pursuant to the order, the civil penalty will be paid within 10 days of the entry of the order.","sm":"Without admitting or denying the findings in the SEC's order, Lightyear Capital LLC made an offer of settlement which the SEC accepted. The SEC administrative order is final. Pursuant to the order, the civil penalty will be paid within 10 days of the entry of the order. No information Filed","ab":"Lightyear Capital LLC","self":true,"firms":[156781],"id":1326},{"d":"2018-12-24","di":"2018-12-24","dr":"2018-12-24","k":"Regulatory Action","rg":"CME Group","reg":"CME Market Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"18-9774","al":"J.P. Morgan Securities LLC (\"JPM\") failed to maintain a complete electronic audit trail for a minimum of 5 years, in violation of rule 536.B.2 (\"globex order entry - electronic audit trail requirements for electronic order routing/front-end systems\").","res":"Decision","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1327},{"d":"2018-12-21","di":"2018-12-21","dr":"2018-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":560000.0,"dk":"2014040051801","al":"On December 21, 2018, FINRA issued a letter of acceptance, waiver, and consent (\"AWC\") to J.P. Morgan Securities LLC (\"JPMS\") relating to the firm's compliance with regulation NMS rules 605 and 606 reporting requirements and the supervisory systems and procedures relating to those rules. Specifically, the AWC found that the firm's supervisory system, including its written supervisory procedures, were not reasonably designed to achieve compliance with laws and regulations as a result of certain technology-driven issues. The AWC also identified deficiencies in related order audit trail system reporting, deficiencies in trade confirmation accuracy and delivery and the supervisory frameworks relating to the same. The AWC found that JPMS therefore violated rules 605 and 606 of regulation NMS and FINRA rule 2010; FINRA rule 7450; SEC rule 10B-10 and rule 2010; and FINRA's supervisory requirements under NASD rule 3010 (for the period prior to December 1, 2014), FINRA rule 3110 (for the period after November 30, 2014), and rule 2010, with regard to rules 605 and 606, rule 7450, and rule 10B-10.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The allegations, dispositions, findings and sanctions of the AWC are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1328},{"d":"2018-12-20","di":"2018-12-20","dr":"2018-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement; interest","st":"Final","fine":5500000.0,"dk":"2014043580203","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that over an eight year period, the firm made at least 1,462 sales of initial public offering (IPO) shares in 325 different offerings to 149 customer accounts in which restricted persons held a beneficial interest. The findings stated that all of the restricted persons who improperly received IPO allocations from the firm were associated persons of broker-dealers and/or immediate family members of financial advisors (FAS) at the firm. Among the ipos improperly sold to these accounts were highly anticipated and sought after stocks. At least 120 different FAS located in 79 of the firm's branch offices effected the prohibited IPO sales. The findings also included that these transactions occurred because the firm failed to implement supervisory systems and procedures reasonably designed to achieve compliance with FINRA rule 5130. The findings stated that the firm also failed to (1) reasonably respond when it learned that it had repeatedly sold ipos to immediate family members of firm FAS, and (2) train any of its employees on rule 5130 from at least January 2010 to September 2014, even though it depended on its employees to help the firm comply with the rule's requirements, and that when the firm did start offering training, that it did not offer the training to many key employees who were integrally involved in effecting IPO transactions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $5,500,000 and ordered to pay disgorgement of the revenues the firm received on the violative transactions, which is ordered to be paid to FINRA in the amount of $490,530, plus interest.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1329},{"d":"2018-12-19","di":"2018-12-19","dr":"2018-12-19","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Massachusetts","san":"Cease and Desist","st":"Final","fine":300000.0,"dk":"E-2018-0013","al":"Without admitting or denying the alleged violations and statement of facts, the firm consented to the entry of a cease and desist order (\"order\") by the Commonwealth of Massachusetts (the \"Commonwealth\") in which the firm was found to have violated section 204(a)(2)(j) of mass. Gen. Laws CH. 110a by failing to reasonably supervise a registered representative's activities in connection with directed brokerage accounts that were managed by a third party investment adviser that is registered with the Commonwealth","res":"Consent","sm":"On December 19, 2018, the Commonwealth entered a consent order against the firm in which the firm was censured and ordered to (a) pay a fine in the amount of $300,000 that was paid by submission of a wire on December 20, 2018, (b) cease and desist from further conduct in violation of the act and corresponding regulations thereunder, and (c) complete the aforementioned undertakings by the deadlines prescribed in the order","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1330},{"d":"2018-12-18","di":"2018-06-25","dr":"2018-12-18","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Massachusetts, Office of the Secretary of the Commonwealth - Securities Division, Enforcement Section","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000000.0,"dk":"E-2017-0119","al":"MetLife, Inc. is alleged to have made materially misleading statements in its public filings regarding the effectiveness of its internal controls over financial reporting for its pension risk transfer business and the sufficiency of its reserves for group annuity contracts.","res":"Consent","sd":"On December 18, 2018 a consent order was issued, with MetLife, Inc. neither admitting nor denying the findings contained in the order (except as to MetLife, Inc.'s corporate identity and organization). The consent order provides for a cease and desist, a censure, the provision of information to the MSD regarding certain annuitants in Massachusetts, undertaking several measures with respect to outreach and payment of benefits to those annuitants, and the payment by MetLife, Inc. of a $1 million administrative fine.","sm":"On December 17, 2018, MetLife, Inc. submitted an offer of settlement to the Massachusetts securities division (\"MSD\") in connection with the MSD's administrative complaint filed on June 25, 2018. On December 18, 2018 a consent order was issued, with MetLife, Inc. neither admitting nor denying the findings contained in the order (except as to MetLife, Inc.'s corporate identity and organization). The consent order provides for a cease and desist, a censure, the provision of information to the MSD regarding certain annuitants in Massachusetts, undertaking several measures with respect to outreach and payment of benefits to those annuitants, and the payment by MetLife, Inc. of a $1 million administrative fine.","ab":"MetLife, Inc.","firms":[142463],"id":1331},{"d":"2018-12-17","di":"2018-12-17","dr":"2018-12-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil fine, disgorgement","st":"Final","fine":375000.0,"dk":"3-18935","al":"Nbaa, without admitting or denying any wrongdoing, consented to the entry of an order by the SEC, with respect to certain of the dyal funds, according to which the dyal funds' manager did not appropriately allocate a portion of the dyal capital partner's business services platform (the \"BSP\") expenses to certain dyal funds and did not have proper policies and procedures in place to ensure that all allocations were related to the utilization of the BSP.","res":"Order","sd":"Nbaa agreed as part of the settlement to pay disgorgement of $2,073,988 (plus prejudgment interest of $284,620) to certain dyal funds covering 2012-2016, and pay a civil monetary penalty of $375,000 to the SEC.","sm":"On December 17, 2018, the SEC announced that nbaa, without admitting or denying any wrongdoing, consented to the entry of an order (the \"order\") by the SEC focused solely on certain expense allocations relating to the business services platform (the \"BSP\"), a team within the dyal capital partners division focused on providing client development, talent management, operational advisory and other services to the partner managers in which the dyal funds invest. Following the completion of the blue owl transaction, no businesses of nbaa utilize the BSP and allocates the expense associated with the BSP to an nbaa-advised fund. The SEC order had no finding of intentional wrongdoing or fraud, and found that the issues relating to the BSP expenses ceased in 2017. According to the order, with respect to certain of the dyal funds, the dyal funds' manager did not appropriately allocate a portion of the BSP expenses to certain dyal funds and did not have proper policies and procedures in place to ensure that all allocations were related to the utilization of the BSP. The order required nbaa to cease and desist from committing or causing any violations and future violations of sections 206(2) and 206(4) of the Advisers Act, as amended, and rules 206(4)-7 and 206(4)-8 thereunder. Nbaa agreed as part of the settlement to pay disgorgement of $2,073,988 (plus prejudgment interest of $284,620) to certain dyal funds covering 2012-2016, and pay a civil monetary penalty of $375,000 to the SEC. the civil monetary penalty was satisfied on January 3, 2019. The disgorgement and prejudgment interest was satisfied on June 7, 2019.","ab":"NB Alternatives Advisers LLC","self":true,"firms":[149822],"id":1332},{"d":"2018-12-13","di":"2018-12-13","dr":"2018-12-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"2014041490801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to reasonably supervise an associated person who, together with a third party individual, engaged in a scheme to defraud a customer of the firm. The scheme began when the associated person was associated with the firm, but the actual theft of funds occurred after the associated person left the firm. The findings stated that the firm failed to respond reasonably to red flags that the associated person was engaged in conduct that appeared to violate the firm's policies and procedures, including a failure to reasonably investigate certain of the associated person's email communications that it had flagged for review and a failure to reasonably follow up on a default judgment entered against the associated person based on a civil complaint that alleged that the associated person had cheated a couple who had lent the third party money and that the associated person had written two post-dated checks, only to later close the account on which the checks were written. The findings stated that had the firm more vigorously responded to the red flags, it likely could have discovered the associated person's associated with the third party and been in a better position to address the risk that the associated person posed to the firm and customer of the firm. The findings also stated that the firm failed to disclose certain reportable events that occurred in 2010 and 2012 to FINRA.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $300,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1333},{"d":"2018-12-12","di":"2018-12-12","dr":"2018-12-12","k":"Regulatory Action","rg":"State regulator","reg":"Mississippi Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"LS-17-2288","al":"The Mississippi Securities Division (division) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of miss. Code. Ann. Section 75-71-411(c)(1) and Mississippi Securities Act rules 5.15.","res":"Consent","sm":"Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Mississippi statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1334},{"d":"2018-12-10","di":"2018-12-10","dr":"2018-12-10","k":"Regulatory Action","rg":"Other","reg":"Financial Services Commission of the Republic of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6654607.36,"al":"The Financial Services Commission of the Republic of Korea (\"FSC\") has imposed an administrative fine on Goldman Sachs international (\"GSI\") for violation of certain short sale restrictions as set out in articles 180(1) and 180-2(1) of the financial investment services and capital markets act (the \"act\") with respect to certain of GSI's short sale orders and short position reports. The fine was imposed pursuant to article 449 of the act, article 390 of the enforcement decree of the act, articles 26 and 48 of the regulation on investigation of capital markets, and article 20 of the regulation on examination and sanctions against financial institutions.","res":"Decision","sm":"The fine imposed by the FSC was in the amount of 7,504,800,000 south korean won (KRW), which was paid by gsi by wire on December 18, 2018.","ab":"Goldman Sachs","firms":[361],"id":1335},{"d":"2018-12-10","di":"2018-12-10","dr":"2018-12-10","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":15000.0,"dk":"2016051145501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to maintain a continuous two-sided trading interest during regular market hours, at prices within certain percentages away from the national best bid or offer (\"NBBO\"). The findings stated that this resulted from the firm failing to properly submit a market maker peg order for a security in which the firm made a market. The findings also stated that the firm's supervisory system was not reasonably designed to achieve compliance with Nasdaq quoting obligations. Specifically, the firm's written supervisory procedures failed to state, which reports the designated supervisor(s) review for quoting obligations and failed to establish a procedure to review the firm's entire quoting obligation on a given day. Rather, the firm only reviewed the firm's actual quotes, thus it did not review securities in which it had a quotation obligation but failed to properly quote.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $15,000, and required to revise its written supervisory procedures (WSPS).","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1336},{"d":"2018-12-06","di":"2018-12-06","k":"Regulatory Action","rg":"State regulator","reg":"Illinois Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":499000.0,"dk":"1800307","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Illinois Securities Department (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Illinois statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1337},{"d":"2018-12-04","di":"2017-12-27","dr":"2018-12-04","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt FÜR Finanzdienstleistungsaufsicht (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Administrative fine of euro 180,000","st":"Final","fine":209000.0,"dk":"WA 17-WP 3120-2017/0009","al":"Avi was one business day late in notifying BAFIN and the issuer that their holding in adler real estate had exceeded the 5% reportable threshold on 27 June 2016. This was due to an oversight by the individual responsible for making such notifications.","res":"Settled","sd":"Administrative fine of euro 180,000 only.","ab":"Asset Value Investors Limited","self":true,"firms":[137779],"id":1338},{"d":"2018-12-03","di":"2018-12-03","dr":"2018-12-03","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"N/A","al":"The Alabama Securities Commission (commission) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of rule 830-X-3-.14(1)(a) of the Alabama Securities Commission's administrative code.","res":"Consent","sm":"Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alabama statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1339},{"d":"2018-12-03","di":"2018-12-03","dr":"2018-12-03","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":450000.0,"dk":"18-0082 CA","al":"The Indiana Securities Division (division) alleged that during the period of approximately 2013 through September 2017 (relevant period) LPL Financial LLC (LPL) failed to review certain emails of its Indiana agents and failed to conduct annual examinations for certain branch offices located in Indiana in contravention of 710 iac 4-7-6(d)(1) (2017) and 710 iac 4-7-6(d)(9) (2017).","res":"Consent","sm":"LPL and the division agreed that the agreement does not constitute a finding of fact or determination against LPL for any violations of the Indiana uniform Securities Act or the rules and regulations promulgated thereunder. In addition, the division and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the agreement is intended to form the basis for disqualification under the rules and regulations of any self-regulatory organizations.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1340},{"d":"2018-12-03","di":"2018-05-24","dr":"2018-12-03","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt FÜR Finanzdienstleistungsaufsicht (German Federal Financial Supervisory Authority ­ \"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"WA 17-WP 3120-2018/0013","al":"BAFIN alleges non-compliance with the german securities trading act between February 2018 and March 2018 by one or several Morgan Stanley entities failing to submit notifications of changes in voting rights in a german listed entity within the prescribed time.","res":"Dismissed","ab":"Morgan Stanley","firms":[149777],"id":1341},{"d":"2018-11-28","di":"2018-11-28","dr":"2018-11-28","k":"Regulatory Action","rg":"Other","reg":"The People's Bank of China","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":145959.0,"dk":"2018/NO. 36","al":"Failure to maintain certain anti-money laundering controls related to customer due diligence between September 2015 and June 2017, in a manner that met the standards required under chinese law.","res":"Decision","sd":"Banco Santander, S.A. Shanghai branch paid a fine of RMB 1,000,000 - usd amount above is an estimate as of January 7, 2019.","sm":"Following a routine review by The People's Bank of China ('pboc ') carried out in 2017, the pboc issued an administrative decision identifying a failure to maintain certain anti-money laundering controls related to customer due diligence, between September 2015 and June 2017, in a manner that met the standards required under chinese law. The pboc's decision related solely to bssa's shanghai branch and is not related in any way to any activity or concern at or involving Santander investment securities inc.","ab":"Banco Santander, S.A.","firms":[143883],"id":1342},{"d":"2018-11-27","di":"2018-11-27","dr":"2018-11-27","k":"Regulatory Action","rg":"State regulator","reg":"Office of Attorney General, State of Illinois","san":"Restitution","st":"Final","fine":17250000.0,"dk":"N/A","al":"Without admitting liability, Wells Fargo & Company (WFC) consented to a settlement agreement with the Illinois attorney general's office in which WFC agreed to pay $17.25MM in restitution to designated illiniois state pensions to resolve an investigation of . Wells fargo mortgage - related securitizations issued before January 1, 2009.","res":"Settled","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1343},{"d":"2018-11-27","di":"2018-11-27","dr":"2018-11-27","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Department of State, Bureau of Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":450000.0,"dk":"C-2015-000021","al":"The State of New Hampshire Department of State, Bureau of Securities Division alleged that the firm failed to supervise a financial advisor who engaged in excessive trading and unsuitable switching of annuities in the accounts of three investors.","res":"Consent","sm":"On November 27, 2018, Morgan Stanley Smith Barney LLC (firm) and the State of New Hampshire Department of State, Bureau of Securities Division entered into a consent agreement in connection with allegations that, from May 1, 2007 through May 1, 2014, the firm failed to supervise a financial advisor who engaged in excessive trading, and unsuitable switching of annuities in three investors' accounts. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to the imposition of an administrative fine of $450,000, and $50,000 in costs, and to payment $187,702.91 and $295,582.05 as restitution to three investors.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1344},{"d":"2018-11-27","dr":"2018-11-27","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":26500.0,"dk":"NOT AVAILABLE","al":"Due to insufficient pre-deployment testing of the new it system, Samsung Life Insurance made the payment of insurance benefits for 1-23 days late, made the payment of insurance agent fees for 3-14 days late, overcharged insurance premium in total of 290,000 korean won, failed to revoke cancellation of insurance although insurers paid insurance premium, and caused 73 insurance contracts to be nullified.","res":"Decision","sd":"Financial Supervisory Service imposed a fine of KRW 30,000,000 on Samsung Life Insurance and issued warnings against one executive.","sm":"On 11/27/2018, the Financial Supervisory Service issued a notice of its decision, finding Samsung Life Insurance liable for the allegations listed in our answer to question 7. As a result, Financial Supervisory Service imposed a fine of KRW 30,000,000 on Samsung Life Insurance and issued warnings against one executive.","ab":"Samsung Life Insurance","firms":[158319],"id":1345},{"d":"2018-11-26","di":"2017-07-31","dr":"2018-11-26","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen (Swedish Financial Supervisory Authority)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":940.0,"dk":"17-12767","al":"Fi alleged that the investment adviser filed a short net position report for one security 33 minutes after the prescribed reporting deadline.","res":"Decision","sd":"Payment of fine only.","sm":"Fine paid. No additional terms or conditions. No information Filed","ab":"Hound Partners, LLC","self":true,"firms":[155551],"id":1346},{"d":"2018-11-20","di":"2018-11-20","dr":"2018-11-20","k":"Regulatory Action","rg":"Other","reg":"Vermont Department of Financial Regulation","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"18-032-S","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Vermont Department of Financial Regulation (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Vermont; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Vermont residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Vermont statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1347},{"d":"2018-11-19","di":"2018-11-19","dr":"2018-11-19","k":"Regulatory Action","rg":"Other","reg":"California Department of Business Oversight","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"N/A","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the California Department of Business Oversight (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in California; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to California residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any California statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1348},{"d":"2018-11-19","di":"2015-01-16","dr":"2018-11-19","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Market Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":99181.0,"dk":"DECISION NO. 12/801/28.11.2017","al":"Following an audit performed by the Hellenic capital markets commission (\"HCMC\") on certain transactions in certain shares of a publicly-listed equity on the athens exchange (the \"shares\") during the period May 2, 2014, through May 9, 2014, the HCMC issued a decision against TP lux holdco sarl (an affiliate of Third Point LLC) (\"lux holdco\"), imposing a fine on lux holdco on the basis that it sold shares in breach of article 12 (1.b) of EU regulation 236/2012 on short selling and of recital 8 and article 5 (1.e) of EU regulation 827/2012 (the \"regulations\") because, at the time that lux holdco sold such shares, the board of directors of the athens exchange had not yet ruled on the approval and the date of the listing of such shares for trading.","res":"Order","sd":"Third Point will pay a fine in an amount equal to EUR87,200 (approximately $99,181usd) upon receipt of payment instructions and the applicable tax certification from the greek tax office.","sm":"Third Point will pay a fine in an amount equal to EUR87,200 under article 18 of greek law 4141/2013 after the Hellenic Capital Market Commission (\"HCMC\") determined that on May 6, 2014, lux holdco sold shares in breach of the regulations. Under greek law, an investor may not sell shares before such shares have been approved and admitted for trading by the athens exchange board of directors (the \"aebd\"). The HCMC determined that the sale of the shares was in breach of the regulations because such sale occurred before the meeting of the aebd, which did not approve the listing of the shares for trading until May 9, 2014. Consistent with HCMC policy, greek law and the HCMC decision, Third Point intends to pay to the greek tax office an amount equal to 80% of the amount of the fine levied by the HCMC, such amount (EUR87,200/approximately $99,181usd) being in full satisfaction of such fine.","ab":"Third Point LLC","self":true,"firms":[137927],"id":1349},{"d":"2018-11-16","di":"2018-11-16","dr":"2018-11-16","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":400000.0,"dk":"2016-07-01067","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $400,000.00 paid November 30, 2018.","sm":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1350},{"d":"2018-11-16","di":"2018-11-16","dr":"2018-11-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida, Office of Financial Regulation","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"90555-S/OFR2018-535","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Florida, Office of Financial Regulation (office) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Florida; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Florida residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Stipulation and Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the office and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the office and LPL agreed that nothing in the agreement is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the agreement is not intended to be a final order based upon violations of any Florida statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1351},{"d":"2018-11-15","di":"2018-11-15","dr":"2018-11-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Department of Banking","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"CO-18-8453-S","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Connecticut Department of Banking (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Connecticut; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Connecticut residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Connecticut statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1352},{"d":"2018-11-13","di":"2018-11-13","dr":"2018-11-13","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"INV 18-104","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Nevada Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Nevada; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Nevada residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Nevada statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1353},{"d":"2018-11-09","di":"2018-11-09","dr":"2018-11-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","dk":"2016049975901","al":"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 these eligible 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. These sales disadvantaged eligible customers by causing such customers to pay higher fees than they were actually required to pay. The findings also stated that the firm failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales. The firm relied on its financial advisors to determine the applicability of sales charge waivers, but failed to maintain WSPS reasonably designed to assist financial advisors in making this determination. In addition, the firm failed to train its financial advisors regarding the availability of mutual fund sales-charge waivers for eligible customers. The firm failed to adopt controls reasonably designed to detect instances in which they did not provide sales-charge waivers to eligible customers in connection with their mutual fund purchases. As a result of the firm's failure to apply available sales charge waivers, the firm estimates that eligible customers were overcharged by $766,295 for mutual fund purchases made since July 1, 2009.","res":"Acceptance, Waiver & Consent(AWC)","sd":"In February 2016 the firm began to make restitution, which is estimated to total $888,337 (the amount eligible customers were overcharged, inclusive of interest). Each eligible customer has received restitution, plus interest.","sm":"FINRA has recognized the extraordinary cooperation of the firm for having: (1) initiated, prior to detection or intervention by a regulator, an investigation to identify whether eligible customers received sales charge waivers during the relevant period; (2) voluntarily expanded the relevant period of applicable transactions, resulting in additional restitution to additional customers; (3) promptly established a plan of remediation for eligible customers who did not receive appropriate sales charge waivers; (4) promptly taken action and remedial steps to correct the violative conduct; and (5) employed subsequent corrective measures, prior to detection or intervention by a regulator, to revise its procedures to avoid recurrence of the misconduct.","ab":"Commonwealth Equity Services, LLC","self":true,"firms":[8032],"id":1354},{"d":"2018-11-08","di":"2018-11-08","dr":"2018-11-08","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania Department of Banking and Securities, Bureau of Securities Compliance and Examinations","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"180091","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Commonwealth of Pennsylvania Department of Banking and Securities, Bureau of Securities Compliance and Examinations (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise its agents and employees regarding the sale of unregistered, non-exempt securities.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Pennsylvania statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1355},{"d":"2018-11-08","di":"2018-11-08","dr":"2018-11-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":215000.0,"dk":"2013039211801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that during the period of January 1, 2014 through April 5, 2016, the firm's supervisory system was not reasonably designed to account for the multi-day approach, which is utilized to calculate credit toward the firm's close-out and delivery obligations. The firm's deficient supervisory system allowed numerous violations of rule 204 of Regulation SHO to go undetected. The findings also provided that the firm failed to close out the fail-to-deliver positions in accordance with rule 204 of Regulation SHO during the periods of June 1, 2013 through September 30, 2013, October 1, 2014 through December 31, 2014, and January 1, 2016 through June 2, 2016. Third, the findings provided that the firm had a fail-to-deliver position at a registered clearing agency in an equity security and did not close out the fail-to-deliver positions by purchasing or borrowing securities of like kind and quantity within the time prescribed by rule 204(a) of Regulation SHO, and FINRA rule 2010. The department of enforcement found that the firm violated NASD rule 3010 (for conduct prior to December 1, 2014) and FINRA rule 3110 (for conduct on or after December 1, 2014), rule 204(a) of Regulation SHO of the Exchange Act, and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1356},{"d":"2018-11-08","di":"2018-10-17","dr":"2018-11-08","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1656.0,"al":"Egerton Capital (UK) LLP received a small fine of sek 15,000 (approximately $1,656) from the swedish regulatory authority, for a late disclosure of a short selling position in betsson ab held in June 2017. The reason for the late disclosure was that the issued share capital of betsson ab was not clear to market participants.","res":"Decision","sd":"Sek 15000 has been paid.","sm":"Egerton Capital (UK) LLP has chosen not to appeal against the decision. No information Filed","ab":"Egerton Capital (UK) LLP","self":true,"firms":[156384],"id":1357},{"d":"2018-11-07","di":"2018-11-07","dr":"2018-11-07","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"AP-18-12","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Missouri Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Missouri; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Missouri residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Missouri statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1358},{"d":"2018-11-07","di":"2018-11-07","dr":"2018-11-07","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement, civil money penalty","st":"Final","fine":13587507.86,"dk":"3-18886","al":"Alleged violation of section 17(a)(3) of the Securities Act in that Citibank, N.A. at times pre-released american depositary receipts (ADR) to pre-release brokers in circumstances where Citibank was negligent with respect to whether the pre-release brokers, or the parties on whose behalf the pre-released ADR's were being obtained, actually beneficially owned the corresponding number of ordinary shares, which resulted in the issuance of ADR's that in many instances, from August 2011 through November 2016, were not backed by ordinary shares as required by the ADR facility.","res":"Order","sm":"Without admitting or denying the allegations, the firm consented to cease and desist, disgorgement of $20,903,858.25, and a civil money penalty in the amount of $13,587,507.86","ab":"Citibank, N.A.","firms":[7059],"id":1359},{"d":"2018-11-02","di":"2018-11-02","dr":"2018-11-02","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":27500.0,"dk":"2015046590003","al":"Alleged violation of SEC rule 611(c) and edga rules 11.5(d)(1), 11.8(c). 5.1 and 3.1 in that cgmi failed to have a system of review for ( ) ( )( ) ( ) iso's independent of executions, limitations in the firm's order routing system led to a failure to retain market data snapshots of the sequenced quotes, and a latency issue within the firm's smart order router caused the firm to route iso's through protected quotations on certain occasions between November 1, 2011 and December 16, 2013. In addition, the firm failed to send certain iso's to better-priced quotes at one national exchange and failed to send an odd lot sized iso to a better-priced quote at another national exchange on June 12, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $27,500, and an undertaking to revise its processes and procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1360},{"d":"2018-11-02","di":"2018-11-02","dr":"2018-11-02","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":27500.0,"dk":"2015046590001","al":"Alleged violation of SEC rule 611(c) and BZX rules 11.9(d)(1), 11.9(d). 5.1 and 3.1 in that cgmi failed to have a system of review for iso's independent of executions, limitations in the firm's order routing system led to a failure to retain market data snapshots of the sequenced quotes, and a latency issue within the firm's smart order router caused the firm to route iso's through protected quotations on certain occasions between November 1, 2011 and December 16, 2013. In addition, the firm failed to send certain iso's to better-priced quotes at one national exchange and failed to send an odd lot sized iso to a better-priced quote at another national exchange on June 12, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $27,500, and an undertaking to revise its processes and procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1361},{"d":"2018-11-02","di":"2018-11-02","dr":"2018-11-02","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":27500.0,"dk":"2015046590004","al":"Alleged violation of SEC rule 611(c) and edgx rules 11.5(d)(1), 11.8(c). 5.1 and 3.1 in that cgmi failed to have a system of review for iso's independent of executions, limitations in the firm's order routing system led to a failure to retain market data snapshots of the sequenced quotes, and a latency issue within the firm's smart order router caused the firm to route iso's through protected quotations on certain occasions between November 1, 2011 and December 16, 2013. In addition, the firm failed to send certain iso's to better-priced quotes at one national exchange and failed to send an odd lot sized iso to a better-priced quote at another national exchange on June 12, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $27,500, and an undertaking to revise its processes and procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1362},{"d":"2018-11-02","di":"2018-11-02","dr":"2018-11-02","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":27500.0,"dk":"2015046590002","al":"Alleged violation of SEC rule 611(c) and byx rules 11.9(d)(1), 11.9(d). 5.1 and 3.1 in that cgmi failed to have a system of review for iso's independent of executions, limitations in the firm's order routing system led to a failure to retain market data snapshots of the sequenced quotes, and a latency issue within the firm's smart order router caused the firm to route iso's through protected quotations on certain occasions between November 1, 2011 and December 16, 2013. In addition, the firm failed to send certain iso's to better-priced quotes at one national exchange and failed to send an odd lot sized iso to a better-priced quote at another national exchange on June 12, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine in the amount of $27,500, and an undertaking to revise its processes and procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1363},{"d":"2018-10-29","di":"2018-10-29","dr":"2018-10-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":2750000.0,"dk":"2016050751901","al":"Through three distinct investigations, FINRA found that LPL Financial (1) failed to establish and implement an AML program reasonably designed to detect and cause the reporting of potentially suspicious activity, in violation of FINRA rules 3310(a) and 2010, (2) failed to amend forms U4 and U5 violating article v, section 2 and 3 of FINRA's by-laws and FINRA rule 2010, and (3) failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to achieve compliance with Form U4 and U5 reporting requirements, in violation of FINRA rules 3110 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining the appropriate monetary sanction, FINRA considered the firm's cooperation and undertaking to remedy its' violations. Specifically, in resolving this matter, FINRA recognized LPL's extraordinary cooperation in having: (1) initiated, on its own, an investigation to identify the scope and extent of its AML program failures regarding sar filings; (2) retained an outside law firm to conduct an extensive internal investigation, which included interviewing firm employees and re-evaluating reporting determinations; (3) promptly remediated certain of the problems by filing 418 sars that it determined should have been filed earlier, and agreeing to amend 31 forms U4 and U5 to add customer complaint information; (4) initiated a review of its procedures regarding complaint reporting, AML investigations and sar reporting, and a restructuring of its AML investigations unit; and (5) provided substantial assistance to FINRA in its investigation, including providing detailed presentations concerning the results of the firm's internal investigations.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1364},{"d":"2018-10-26","di":"2018-10-26","dr":"2018-10-26","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"CME 17-0729","al":"CME market regulation department alleged, and CME business conduct committee found, that Deutsche bank AG violated CME rules 538.c, 534 and 432.w by executing an exchange of futures for related position (\"EFRP\") without the exchange or related positions, thereby executing a non bona-fide erfp.","res":"Decision & Order of Offer of Settlement","sm":"The action was resolved by decision of CME business conduct committee dated October 24, 2018, which became effective on October 26, 2018. The decision accepted an offer of settlement from Deutsche bank AG and directed Deutsche bank AG to pay a fine of $75,000 on or before November 9, 2018. Without admitting or denying the allegations, Deutsche bank AG paid the fine in full on November 6, 2018.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":1365},{"d":"2018-10-24","di":"2018-10-24","dr":"2018-10-24","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"S-17-0078-18-OR-01","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Arkansas Securities Department (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Arkansas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Arkansas residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arkansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1366},{"d":"2018-10-24","di":"2018-10-24","k":"Regulatory Action","dk":"54631","ab":"Smith, Kevin, P","firms":[7691],"id":1367},{"d":"2018-10-22","di":"2017-11-28","dr":"2018-10-22","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen (Swedish Financial Supervisory Authority)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"FI REF 17-20168","al":"The swedish financial regulatory authority alleged that Wellington had not filed, within the specified time period, a report regarding a net short position held in a swedish security.","res":"Decision","sd":"The amount of penalty fee was sek 8,700 (approximately usd $1,000).","sm":"Wellington was assessed a penalty fee in full disposition of the matter. There were no additional conditions imposed.","ab":"Wellington Management Company LLP","self":true,"firms":[106595],"id":1368},{"d":"2018-10-18","di":"2018-10-18","dr":"2018-10-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Undertaking","st":"Final","dk":"2017053493101","al":"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 system and procedures reasonably designed to monitor and evaluate the performance of the vendor that handled certain functions on behalf of the firm. The findings stated that firm contracted with a vendor to handle the automated realignment of portfolio assets (\"rebalancing\") in certain customer accounts invested in mutual funds to the model selected by the customer, and the calculation of fees charged to certain customers. The firm discovered that the vendor was not rebalancing certain accounts. Technology upgrades by the vendor caused accounts to not be rebalanced at the appropriate time. Similarly, the vendor converted to a new billing platform, that caused billing errors that went undetected for periods of time. As a result, incorrect fee rebates were calculated, trade correction fee adjustments were not properly applied, account fee terminations were processed one day late, and incorrect blended rates were applied to accounts.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm self-reported its initial discovery of certain issues before FINRA was aware of the issues and promptly began its own examination to determine the full extent of the deficiencies described above, making additional reports to FINRA. The firm took extraordinary steps to correct its deficient system and procedures by implementing enhanced controls and testing to ensure the accuracy of the vendor's rebalancing and fee calculations. The firm provided extraordinary remediation to customers without being compelled to do so by FINRA. The firm paid total restitution of $4,620,140 to impacted customers. The firm provided substantial assistance to FINRA by proactively undertaking an extensive lookback concerning its complex and systemic failures and reporting related findings on an ongoing basis.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1369},{"d":"2018-10-18","di":"2018-10-18","dr":"2018-10-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Restitution plus interest.","st":"Final","dk":"FINRA LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017054119401","al":"FINRA alleged that, during the period January 2008 through April 2017, MBSC failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to monitor the transmittal of funds from customer accounts to third parties. FINRA alleged that this resulted in MBSC following instructions from two third-party advisors to disburse approximately $971,289 in excess fees to such advisors from the accounts of approximately 75 MBSC customers. FINRA alleged that MBSC thereby violated NASD rules 3010, 3012 and 2110 and FINRA rules 3110, 3110(c)(2) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"MBSC consented to the imposition of a censure and restitution to impacted customers in the amount of approximately $971,289 plus interest of approximately $242,955 for a total amount of approximately $1,214,244. MBSC completed its restitution payments, including interest, to these customers on August 31, 2018.","sm":"Provided). Following an internal review, MBSC self-reported to FINRA that it had discovered that two unaffiliated investment advisers had charged client fees in excess of the amounts permitted under the governing investment management agreements. Based upon instructions from the unaffiliated advisers, MBSC reported that it: (1) disbursed fees from accounts of a number of customers to the advisers that exceeded the fees to which the advisers were entitled and (2) intended to reimburse all affected customers, with interest, for any disbursement of improper fees from their accounts. As a result of MBSC's voluntary disclosure, FINRA investigated the matter. FINRA found that MBSC: (1) failed to establish, maintain and enforce a supervisory system, including written procedures, reasonably designed to review and monitor the transmittals of funds from customer accounts to third party accounts and (2) by virtue of the foregoing, violated NASD rules 3010, 3012 and 2110, and FINRA rules 3110, 3110(c)(2) and 2010. On October 18, 2018, 2018, MBSC and FINRA settled the matter pursuant to a letter of acceptance, waiver and consent (the \"AWC\") on a neither-admit-nor-deny basis in which MBSC consented and agreed to the imposition of a censure and restitution to impacted customers in the amount of approximately $971,289 plus interest of approximately $242,955 for a total amount of approximately $1,214,244.","ab":"BNY Mellon Securities Corporation","self":true,"firms":[231],"id":1370},{"d":"2018-10-18","di":"2018-10-18","dr":"2018-10-18","k":"Regulatory Action","rg":"State regulator","reg":"Office of Attorney General, State of New York","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":65000000.0,"dk":"18/121","al":"Without admitting liability, Wells Fargo & Company (WF&co) consented to a settlement agreement in which the Office of Attorney General, State of New York (OAG), alleged WF&co engaged in violations of NY general business law, § 352 et seq., executive law § 63(12), and the common law of the state of NY, related to representations to investors. Wells Fargo & Company agreed to pay a civil money penalty of $65,000,000. To the OAG within ten (10) business days.","res":"Settled","sm":"N/a","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1371},{"d":"2018-10-17","di":"2018-08-16","dr":"2018-10-17","k":"Regulatory Action","rg":"Other","reg":"The Danish Financial Supervisory Authority","san":"Reprimand","st":"Final","dk":"6376-0132","al":"Valiant missed three (3) reporting disclosures regarding its net short positions in two danish companies in 2017 and 2018.","res":"Decision","sd":"None","sm":"The missing notifications were subsequently filed and, after issuing a reprimand letter, the authority determined no further action was necessary. No information Filed","ab":"Valiant Capital Management, L.P.","self":true,"firms":[158071],"id":1372},{"d":"2018-10-12","di":"2018-09-21","dr":"2018-10-12","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"2018-016","al":"Alleged violation of exchange rule 4.07(c) in that Citigroup Global Markets Inc. failed to report certain block trades in a timely manner on March 9, 2018.","res":"Decision","sm":"Cgmi consented to a summary fine in the amount of $7,500","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1373},{"d":"2018-10-11","di":"2018-10-11","dr":"2018-10-11","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Mississippi Secretary of State's Office","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"LS-17-2768","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the Mississippi Secretary of State's Office (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Mississippi; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Mississippi residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Mississippi statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1374},{"d":"2018-10-08","di":"2018-10-08","dr":"2018-10-08","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":1000000.0,"dk":"69581-S","al":"N/a","res":"Order","sd":"$1,000,000.00 administrative fine paid 10/8/2018","sm":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1375},{"d":"2018-10-03","di":"2018-10-03","dr":"2018-10-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan, Department of Licensing & Regulatory Affairs, Corporations, Securities & Commercial Licensing Bureau","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"336330","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Michigan, Department of Licensing & Regulatory Affairs, Corporations, Securities & Commercial Licensing Bureau (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Michigan; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Michigan residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Michigan statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1376},{"d":"2018-10-02","di":"2018-10-02","dr":"2018-10-02","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the New Mexico Regulation and Licensing Department","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"15-099-0049","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the New Mexico Regulation and Licensing Department (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Mexico; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to New Mexico residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Mexico statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1377},{"d":"2018-10-01","di":"2018-10-01","dr":"2018-10-01","k":"Regulatory Action","rg":"Other","reg":"South Dakota Division of Insurance","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"3006","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the South Dakota Division of Insurance (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in South Dakota; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to South Dakota residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multi-state task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Dakota statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1378},{"d":"2018-09-28","di":"2018-04-04","dr":"2018-09-28","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Censure","os":"Fine","st":"Final","fine":200000.0,"dk":"SD-18-0013","al":"The Utah Division of Securities (\"division\") alleged LPL Financial failed to comply with the regulatory requirements governing networking arrangements between broker-dealers and credit unions, approve the use of misleading sales and advertising materials, and other information provided to customers and the public, failed to follow and enforce its policies and procedures, and failed to reasonably supervise the business run through the credit union.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1379},{"d":"2018-09-27","di":"2018-09-27","dr":"2018-09-27","k":"Regulatory Action","rg":"Other","reg":"La Comision Nacional de Mercado de Valores ('CNMV') - the Spanish National Securities Market Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5164650.0,"al":"Failure to act in customers' best interests as required under spanish law, in connection with the placement of shares of collective investment undertakings in customers' managed and advised portfolios.","res":"Decision & Order of Offer of Settlement","sd":"Banco Santander, S.A. (BSSA) was fined eur 4,500,000 - usd amount above is an estimate as of January 7, 2019. BSSA paid a reduced amount of eur 3,600,000, availing itself of the reduction for prompt payment allowance.","sm":"On September 27, 2018, the comision nacional del mercado de valores ('CNMV') published a decision as to bssa, concluding that bssa failed to act in customers' best interests as required under spanish law in connection with the placement of shares of collective investment undertakings in customers' managed and advised portfolios. Bssa paid a fine of eur 3,600,000. The CNMV's decision related solely to bssa and is not related in any way to any activity or concern at or involving Santander investment securities inc.","ab":"Banco Santander, S.A.","firms":[143883],"id":1380},{"d":"2018-09-26","di":"2018-09-26","dr":"2018-09-26","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":125000.0,"dk":"20140411279","al":"The exchange alleged that the firm did not have supervisory systems and surveillances reasonably designed to ensure compliance with exchange rules prohibiting manipulative cross-product trading or mini-manipulative activity and that the firm did not have written supervisory procedures with respect to the detection and prevention of potential mini-manipulation, in violation of NYSE ARCA rules 11.18(a), (b) and (c) and 11.1(b).","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying any allegations or the findings, the firm was censured and fined a total of $125,000, of which $15,625 is payable to the exchange. In addition, the firm agreed to revise its written supervisory procedures with respect to mini- manipulation.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1381},{"d":"2018-09-26","di":"2018-09-26","dr":"2018-09-26","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Gemx, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":125000.0,"dk":"2014041127906","al":"The exchange alleged that the firm did not have supervisory systems or surveillances reasonably designed to ensure compliance with exchange rules prohibiting potentially manipulative cross-product trading or mini-manipulative activity and that the firm did not have reasonable written supervisory procedures with respect to the detection and prevention of potential mini- manipulation, in violation of gemx chapter 4 in connection with ise rules 400 and 401.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm was censured and fined a total of $125,000, of which $15,625 is payable to the exchange. In addition, the firm agreed to revise its written supervisory procedures with respect to mini-manipulation.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1382},{"d":"2018-09-26","di":"2018-09-26","dr":"2018-09-26","k":"Regulatory Action","rg":"Other","reg":"Box Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":125000.0,"dk":"2014041127904","al":"Box alleged that the firm did not have supervisory systems or surveillances reasonably designed to ensure compliance with box rules prohibiting manipulative cross-product trading or mini-manipulative activity and that the firm did not have reasonable written supervisory procedures with respect to the detection and prevention of potential mini-manipulation , in violation of box rules 3000(a), 2010 and 7000(c)(4).","res":"Consent","sm":"Without admitting or denying the findings, the firm was censured and fined a total of $125,000, of which $15,625 is payable to box. In addition, the firm agreed to revise its written supervisory procedures with respect to mini-manipulation.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1383},{"d":"2018-09-20","di":"2018-05-31","dr":"2018-09-20","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen - Swedish Financial Services Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2020.0,"al":"BlackRock investment management (UK) limited (\"bim UK\") is required to report to the swedish financial services authority (\"SFSA\"), within a specified time period, its holdings in listed issuers where those holdings cross a certain threshold (\"notifications\"). On May 5, 2017, an external vendor was unable to provide accurate data resulting in approximately a 5 minute delay in bim UK's submission of certain short selling notifications to the SFSA. The SFSA was informed in advance of the filing deadline of the likelihood of a delay to the submission of certain short selling notifications. In September 2017, bim UK responded to an inquiry from the SFSA regarding the late submission on May 5, 2017 of short selling notifications for three listed issuers (I.E., byggmax group ab, JM ab and mycronic ab). That response explained the circumstances and noted that the issue arose as a result of inaccurate data received from an external data vendor. The swedish FSA took a strict approach to the interpretation of the requirement to submit the notifications on time and imposed a special fee on bim UK for each of the three late notifications.","res":"Decision","sd":"On May 31, 2018, bim UK limited received three letters imposing a special fee for each of the late short selling notifications. Invoice(s) totaling 17,300 sek (approximately $2020 usd) were received on August 21, 2018 for the special fee(s).","sm":"Bim UK paid the special fee to the sfsa on September 20, 2018.","ab":"BlackRock, Inc; BlackRock,Inc","firms":[106614,107105,290336],"id":1384},{"d":"2018-09-19","di":"2018-09-19","dr":"2018-09-19","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; underaking","st":"Final","fine":30000000.0,"dk":"CFTC DOCKET NO. 18-34","al":"The U.S. Commodity Futures Trading Commission (CFTC) alleged that, on occasion from January 2007 through December 2012, the firm, by and through certain of its traders, attempted to manipulate the U.S. dollar international swaps and derivatives association fix (usd isdafix), a benchmark related to interest-rate products, to benefit the firm's derivatives positions in violation of section 9(a)(2) of the commodity Exchange Act (CEA); section 6(c) and 6(d) of the CEA, for conduct occurring prior to August 15, 2011; and section 6(c)(1), 6(c)(1)(a), 6(c)(3) and 6(d) of the CEA, and regulations 180.1(a) and 180.2, for conduct occurring on or after August 15, 2011.","res":"Order","sm":"Without admitting or denying the findings or conclusions in the order, the firm consented to the imposition of the following sanctions: (1) to cease and desist from violating sections 6(c)(1), 6(c)(1)(a), 6(c)(3), 6(d), and 9(a)(2) of the cea and regulations 180.1(a) and 180.2, (2) to pay a civil monetary penalty in the amount of $30,000,000, which the firm paid on September 24, 2018, and (3) continue to undertake certain remediation efforts, including providing a report to the CFTC within 120 days of the order addressing remediation efforts both prior to and since entry of the order, and providing an additional report to the CFTC, no later than 365 days from entry of the order, explaining how the firm has complied with the undertakings set forth in the order.","ab":"Bank of America, National","firms":[142558],"id":1385},{"d":"2018-09-18","di":"2018-09-18","dr":"2018-09-18","k":"Regulatory Action","rg":"Other","reg":"Securities & Exchange Commission","san":"Cease and Desist","os":"Censure & $200,000 civil penalty","st":"Final","fine":200000.0,"dk":"FILE NO. 3-18779","al":"On September 18, 2018, the SEC instituted a settled order against Creative Planning, inc. (\"CPI\") and peter a. Mallouk, the firm's ( ) president and majority owner. Creative Planning distributed hundreds of radio advertisements that contained prohibited client testimonials. The radio station DJ had become a client of Creative Planning and, on air, discussed his and his wife's satisfaction with Creative Planning services and with their advisor. Creative should have been aware of these testimonials and stopped them. Creative and Mallouk failed to enforce the firm's code of ethics with regard to the radio advertisements and the reporting and review of certain securities accounts in which the firm's president had a beneficial interest. Creative failed to keep true and accurate books and records and failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Creative consented to a cease-and-desist order, a censure, and a civil penalty of $200,000 and Mallouk consented to a cease-and-desist order and a civil penalty of $50,000.","res":"Order","sd":"Firm was ordered to cease and desist from committing or causing any violations and any future violations of sections 204, 204a, and 206(4) of the Advisers Act and rules 204-2(a)(11),204A-1, 206(4)-1(a)(1), and 206(4)-7 thereunder, censured, and imposed a civil penalty of $200,000 on Creative Planning and $50,000 against MR. Mallouk.","sm":"FINE WAS PAID ON SEPTEMBER 9/18/2018. No Information Filed","ab":"Mallouk, Peter, Alex","firms":[105348],"id":1386},{"d":"2018-09-14","di":"2018-09-14","dr":"2018-09-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, disgorgement, civil money penalty","st":"Final","fine":6500000.0,"dk":"3-18766","al":"Alleged violation of section 17(a)(2) of the Securities Act in that Citigroup Global Markets Inc. made material misstatements and omissions to certain institutional users in connection with a dark pool called Citi match concerning the types of market participants that were allowed to place orders in Citi match and Citi match's practice of routing order to other trading venues for execution from at least December 2011 through June 2014.","res":"Order","sm":"Without admitting or denying the findings, the firm consented to cease and desist, censure, disgorgement of $4,718,784.59 and prejudgment interest of $718,690.47, and a civil money penalty in the amount of $6,500,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1387},{"d":"2018-09-14","di":"2018-09-14","dr":"2018-09-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s).","st":"Final","fine":100000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-18767","al":"On August 28, 2018, Cushing Asset Management, LP (\"Cushing\") entered into a settlement with the Securities and Exchange Commission (\"SEC\"), which resulted in an order issued by the SEC. the order resolves the SEC's allegations that Cushing caused its client's violations of section 17(a) of the Investment Company Act of 1940 (\"Investment Company Act\") in connection with two undisclosed cross trades on December 20, 2012.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, Cushing consented to the order without admitting or denying the matters therein (except the SEC's jurisdiction). The allegations, dispositions, findings and sanctions of the order are described in items 7 and 12 above. No information Filed","ab":"Cushing Asset Management, LP","self":true,"firms":[131517],"id":1388},{"d":"2018-09-13","di":"2016-03-09","dr":"2018-09-13","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Undertaking","os":"Edward jones should review current supervisory provisions and practices. Update agent's U-5. Pay fine in the amount of","st":"Final","fine":50000.0,"dk":"S-16-0017","al":"The Arkansas Securities Department alleged that the firm failed to adequately supervise the activities of an agent, properly disclose a complaint and settlement related to the agent, update and disclose information that the agent was the subject of an internal review at the time of termination, and make and keep books and records in violation of ark. Code ann. §§ 23­42­301(f)(1) and 23-42-306, rules of the Arkansas securities commissioner 301.01(c)(2)(f), 301.01(c)(5), 306.02, and 308.01(x), and FINRA by-law article v, section 3.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1389},{"d":"2018-09-13","di":"2018-09-13","dr":"2018-09-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":37500.0,"dk":"2016050506801","al":"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 in over-the-counter (OTC) securities traded customer orders in OTC securities for its own account at prices that would have satisfied the customer orders, and failed to execute or immediately execute the customer orders 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 the firm transmitted inaccurate reports to OATS. The firm's OATS reports contained an inaccurate information barrier identifier. The cause of the inaccurate reports, which was systemic, was a change that the firm's vendor made to the manner in which the firm reported information barrier identifiers. For each stock in which the firm makes a market, the stock is assigned to a particular trader at the firm. Because of the change by the firm's vendor, instead of reporting information barrier identifiers based on the actual trader who handled the order, the firm reported information barrier identifiers based on the trader who was assigned the stock. As a result, the firm has submitted an estimated 452,024 reports to OATS with an inaccurate information barrier identifier. 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 compliance with FINRA rule 7450. Specifically, the firm's written supervisory procedures (WSPS) failed to include a review for the reporting of information barrier identifiers to OATS, and the firm did not otherwise review its reporting of information barrier identifiers to OATS.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1390},{"d":"2018-09-13","di":"2018-09-13","dr":"2018-09-13","k":"Regulatory Action","rg":"Department of Justice","reg":"Investor Protection Unit of the Delaware Department of Justice","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"18-0027","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the investor protection unit (IPU) of the Delaware Department of Justice alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to comply with state securities registration requirements, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ipu and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ipu and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Delaware statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1391},{"d":"2018-09-11","di":"2018-09-11","dr":"2018-09-11","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"OFI-2018-04","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Louisiana Office of Financial Institutions (OFI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Louisiana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Louisiana residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ofi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ofi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Louisiana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1392},{"d":"2018-09-07","di":"2018-09-07","dr":"2018-09-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, remediation plan, restitution","st":"Final","fine":100000.0,"dk":"2016049977601","al":"Alleged violation of NASD conduct rule 3010 and FINRA rules 3110 and 2010 in that Citigroup Global Markets Inc. failed to establish and maintain a supervisory system and procedures reasonably designed to ensure that eligible customers who purchased mutual fund shares received the benefit of applicable sales charge waivers between January 1, 2011 and September 30, 2016.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to a censure, fine in the amount of $100,000, and remediation to eligible customer including restitution.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1393},{"d":"2018-09-04","di":"2018-05-25","dr":"2018-09-04","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Korea","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6700.0,"dk":"N/A","al":"In September 2018, the korean securities and futures commission (\"SFC\") determined to impose on Dalton Investments LLC (\"Dalton\") an \"administrative fine\" of 7,500,000 KRW (approximately $6,700 usd), which Dalton paid in due course. The SFC alleged that Dalton, on behalf of one of the funds under Dalton's management, placed an order in July 2017 to engage in a short sale in korea without borrowing the securities to be sold, violating the short sale restriction provisions in the financial investment services and capital markets act of korea. This matter arises out of the following: Dalton, on behalf of one of its funds, requested its prime broker to locate and make available shares of a security with an intent to sell the shares short. After Dalton's prime broker approved the request, Dalton placed a short sale trade. Thereafter, the executing broker in korea notified Dalton that the trade was failing because the shares had not been placed in daltonfund's investor registration code (\"IRC\") account but rather were in the prime broker's swap IRC account. To resolve this problem, the trade was settled on time after the executing broker delivered the shares from itsinventory. Upon learning of this issue, Dalton immediately purchased the shares in the open market and returned the shares to the executing broker.","res":"Order","sd":"See above.","ab":"Dalton Investments LLC","firms":[308609],"id":1394},{"d":"2018-08-31","di":"2018-08-31","dr":"2018-08-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; cease and desist order","st":"Final","fine":1900000.0,"dk":"3-18704","al":"The SEC found that certain marketing materials provided by MFS to institutional clients and prospective institutional clients, investment consultants and financial intermediaries concerning MFS's blended research investment strategies contained material misstatements and omissions. The SEC's findings specifically pertained to a conceptual chart included in the marketing materials that presented the performance of hypothetical buckets of stocks created using quantitative inputs and fundamental inputs. Though MFS regularly labeled the chart as \"hypothetical,\" the SEC found that MFS failed to disclose and/or misrepresented the fact that some of the quantitative data used to create the chart was generated by a retroactive application of MFS's quantitative model (I.E., by \"back-testing\" the model). As a result of these disclosure issues, the SEC found that MFS violated section 206(2) and 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-1(a)(5) thereunder, and that it failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules in violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. MFS neither admitted nor denied the findings in the SEC's order initiating administrative proceedings.","res":"Settled","sd":"A civil penalty of US $1,900,000 was paid to the SEC. MFS was also censured and ordered to cease and desist from further violations of the relevant statutes and rules.","sm":"The matter was settled pursuant to an offer of settlement submitted by MFS in anticipation of the institution of administrative proceedings by the SEC. the SEC issued its order instituting administrative and cease-and-desist proceedings on August 31, 2018. A civil penalty of US $1,900,000 was paid to the SEC. MFS was also censured and ordered to cease and desist from further violations of the relevant statutes and rules. No information Filed","ab":"Massachusetts Financial Services Company","self":true,"firms":[110045],"id":1395},{"d":"2018-08-30","di":"2018-06-21","dr":"2018-08-30","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"18-0012/20160498080","al":"It was alleged that on two settlement dates the firm entered sell-side orders prior to the cut-off time for participation in the special opening quotation and subsequently changed its orders through submission of buy-side orders after the cut-off time which is violation of CBOE rule 6.2b. It was further alleged that the firm violated CBOE rule 4.2 for failing to supervise its associated persons to assure compliance with exchange rule 6.2b for failing to establish and maintain adequate supervisory procedures for compliance with exchange rule 6.2b.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1396},{"d":"2018-08-29","di":"2016-12-22","dr":"2018-08-29","k":"Regulatory Action","rg":"State regulator","reg":"Rhode Island Securities Division","san":"p","st":"Final","fine":175000.0,"dk":"N/A","al":"The state of Rhode Island Securities Division alleged that the firm failed to supervise a program that encouraged financial advisors to open securities-based loans accounts for clients.","res":"Consent","sm":"On August 29, 2018, Morgan Stanley Smith Barney LLC (firm) and the state of Rhode Island Securities Division entered into a consent agreement in connection with allegations that, from September 1, 2013 through April 30, 2015, the firm failed to supervise in connection with a program within the metrowest-ri complex to make lending products available to eligible customers. This same program was the subject of a settlement with Massachusetts in April 2017. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to the imposition of an administrative fine of $175,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1397},{"d":"2018-08-27","di":"2018-08-27","dr":"2018-08-27","k":"Regulatory Action","rg":"Other","reg":"Puerto Rico Office of the Commissioner of Financial Institutions","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"N/A","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Puerto Rico Office of the Commissioner of Financial Institutions (OCFI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Puerto Rico; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Puerto Rico residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ocfi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ocfi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Puerto Rico statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1398},{"d":"2018-08-27","di":"2018-08-27","dr":"2018-08-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement of $27,594,729 and prejudgment interest of $6,907,765. Separately, on June 4, 2018 Legg Mason, Inc. (\"Legg Mason\")","st":"Final","dk":"EXCHANGE ACT RELEASE NO. 83948; ACCOUNTING AND AUDITING RELEASE NO. 3961; AMINISTRATIVE PROCEEDING FILE NO. 3-18684.","al":"On August 27, 2018, the SEC issued an order that found that Legg Mason had violated section 13(b)(2)(b) of the Securities Exchange Act of 1934 by failing to devise and maintain a system of appropriate internal accounting controls with respect to theuse of introducing brokers and other intermediaries in emerging markets, including libya, and that imposed a cease-and- desist order on Legg Mason with respect to any violations or future violations of section 13(b)(2)(b). Previously, Legg Mason had submitted an offer of settlement in connection with the matter which the SEC determined to accept. The order resolved a fcpa investigation concerning the activities of Legg Mason's former permal business in connection with managing assets of libyan governmental entities in structures established by a third-party financial institution. Those investments were made in calendar years 2005-2007 and all were terminated by 2012. The matter does not relate to any current business activities or client relationships of Legg Mason or any affiliate, and was focused on the actions of former permal employees who left that firm four or more years ago.","res":"Order","sd":"The order required Legg Mason to pay disgorgement of $27,594,729 and prejudgment interest of $6,907,765 to the SEC. the SEC did not impose its own penalty based upon the penalty paid to resolve a DOJ investigation arising out of the same matter, as described in the response to item 2 above.","sm":"On August 27, 2018, the SEC issued an order that contained findings that Legg Mason had violated section 13(b)(2)(b) of the Securities Exchange Act by failing to devise and maintain appropriate internal accounting controls with respect to the use of introducing brokers and other intermediaries in emerging markets, including libya, and that imposed a cease-and-desist order on Legg Mason with respect to any violations or future violations of section 13(b)(2)(b). Previously, Legg Mason had submitted an offer of settlement which the SEC determined to accept. The order resolved a fcpa investigation concerning the activities of Legg Mason's former permal business in connection with managing assets of libyan governmental entities in structures established by a third-party financial institution. Pursuant to the order, the SEC ordered Legg Mason to cease and desist from committing or causing any violations and future violations of section 13(b)(2)(b) of the Securities Exchange Act of 1934 and to pay disgorgement of $27,594,729 and prejudgment interest of $6,907,765 for a total payment of $34,502,944. Separately, on June 4, 2018 Legg Mason agreed to pay a penalty and disgorgement to resolve a DOJ investigation arising out of the same matter, as described in the response to item 2 above. No information Filed","ab":"Legg Mason, Inc; Legg Mason, Inc.","firms":[106631,107689,110427,110441,110783,111364,111382,111383,137028,142188],"id":1399},{"d":"2018-08-20","di":"2018-08-20","dr":"2018-08-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; disgorgement; prejudgment interest","st":"Final","fine":4032871.89,"dk":"3-18651","al":"On August 20, 2018, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an order. Merrill lynch consented to the entry of the order (the \"order\") that finds that it failed to disclose that the portfolio manager evaluation process employed in connection with a January 2013 termination recommendation for over fifteen hundred of its retail advisory accounts was exposed to a conflict of interest involving other business interests. The order finds that this undisclosed conflict of interest in Merrill lynch's decision-making process violated Advisers Act section 206(2). Merrill lynch also violated Advisers Act section 206(4) and rule 206(4)-7 promulgated thereunder.","res":"Order","sm":"Solely for the purpose of settling these proceedings, Merrill lynch consented to the order without admitting or denying the findings in the order, except as to the SEC's jurisdiction over it and the subject matter. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1400},{"d":"2018-08-15","dr":"2018-08-15","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Cease and Desist","st":"Final","fine":499000.0,"dk":"18-0069 CO","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Indiana Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Indiana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Indiana residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Indiana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1401},{"d":"2018-08-13","di":"2018-01-04","dr":"2018-08-13","k":"Regulatory Action","rg":"Other","reg":"The Czech National Bank","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":33945.0,"dk":"2017 / 158544 / 570; 2018 / 095899 / CNB / 110","al":"The Czech National Bank (\"CNB\") issued an order alleging that The Goldman Sachs Group, inc. (the \"firm\") failed to notify the CNB within the statutory time limit that its shares in the voting rights of a certain issuer company had exceeded 1%, in deemed violation of article 122(1), and in conjunction with article 122(2), of the capital market undertakings act.","res":"Decision","sm":"The CNB imposed a fine on the firm in the amount of 750,000 czech koruna (CZK), together with costs of 1,000 CZK, which was paid by wire on September 7, 2018.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1402},{"d":"2018-08-01","dr":"2018-08-01","k":"Regulatory Action","rg":"Department of Justice","reg":"U.S. Department of Justice","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2090000000.0,"al":"Without admitting liability, the bank consented to a civil settlement agreement in which the US DOJ alleged the bank engaged in violations covered under the financial institutions reform, recovery and enforcement act of 1989, 12 U.S.C. § 1833a, related to representations, disclosures or non-disclosures to RMBS investors or third parties that were passed through to RMBS investors. Wells Fargo Bank, N.A. agreed to pay a civil money penalty of $2,090,000,000 to the civil division of the U.S. Department of Justice within fifteen (15) days.","res":"Settled","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1403},{"d":"2018-07-31","di":"2018-05-21","dr":"2018-07-31","k":"Regulatory Action","rg":"Other","reg":"Sweden's Finansinspektionen (Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"17-12945","al":"On May 21, 2018, FMR LLC, the registrant's ultimate parent company, received notice from sweden's finansinspektionen (the \"sfsa\") that the sfsa was issuing a fine, equivalent to approximately US$40,000, against FMR LLC based on a finding that a notification of a change in shareholdings in a swedish corporation, which shares were held by client accounts managed by FMR LLC's investment advisory subsidiaries, had been made eight days late. The late notification arose because, as a result of a data issue, FMR LLC's filing agent was not alerted on a timely basis that such accounts' holdings had crossed the relevant filing threshold by O.OOOOO12%.","res":"Decision","sd":"Fine of 337,500 swedish krona (approximately US$40,000) was paid by FMR LLC on July 31, 2018.","ab":"FMR LLC; FMR, LLC","firms":[104555,301896,315088],"id":1404},{"d":"2018-07-26","di":"2018-07-17","dr":"2018-07-26","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","st":"Final","fine":7500.0,"dk":"2017053084602","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to register one associated person as both a series 7 general securities representative and series 24 general securities principal with byx. The same associated person was also not qualified or registered as a series 24 securities trader principal with byx even though the person had responsibility over securities trading activities on byx. Although the person had passed the series 24 examination, the person had not passed the series 57 prerequisite examination. The findings stated that separately, the firm failed to register a different associated person, the firm's chief compliance officer, as a series 7 general securities representative with byx. The findings also stated that the firm failed to follow its written supervisory procedures to ensure that its associated persons were properly registered with the exchange.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The supervisory structure was revised and a qualified series 24 securities trader principal is now supervising the trading desk activities.","sm":"The firm was censured, fined $7,500 and required to ensure that the associated person discussed in the AWC becomes qualified and registered as a series 24 securities trader principal with byx, assuming the firm intends for the associated person to have a role in supervising the trading activities of the firm on byx going forward. Until this associated person becomes qualified and registered as a series 24 securities trader principal, the individual shall have no role in supervising the firm's trading activities on byx. The firm shall inform FINRA that the associated person became qualified and registered as a series 24 securities trader principal with byx. Alternatively, if the firm decides that the associated person shall not have a role in supervising the firm's trading activities on byx going forward, the information to FINRA shall provide notice of that decision and the date of that decision. The decision in this matter is final 20 business days after the issuance of the decision. Therefore, this AWC will become final August 14, 2018. Payment was remitted 7/26/2018. The supervisory structure was revised and a qualified series 24 securities trader principal is now supervising the trading desk activities.","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":1405},{"d":"2018-07-17","di":"2018-06-15","dr":"2018-07-17","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40925.0,"dk":"FI DNR 17-14217","al":"In August 2017, Farallon Capital Management, L.L.C. Self reported to the sfsa it was submitting a late notification in connection with its net short position in a Swedish issuer. No trade was made to trigger the change in Farallon's net short position. The change in Farallon's net short position was due to a directed new share issuance in which Farallon was not invited to participate, which had the effect of reducing Farallon's net short position.","res":"Decision","sd":"The penalty fee of sek 376,200 (approximately $40,925) was paid to the sfsa on August 16, 2018 upon receipt of payment details.","sm":"In its decision posted on the sfsa website, the sfsa noted the mitigating circumstances and acknowledged that Farallon self reported the late filing. The sfsa reduced the penalty provided for in the regulatory guidelines, which is otherwise set based on the number of days for which the filing is late. No information Filed","ab":"Farallon Capital Management, L.L.C.","self":true,"firms":[107322],"id":1406},{"d":"2018-07-17","di":"2018-07-17","dr":"2018-07-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil money penalty, censure","st":"Final","fine":75000.0,"dk":"FILE NO. 3-18599","al":"The settlement order, entered by the Securities and Exchange Commission on July 17, 2018 (the \"settlement order\"), arose in connection with the distribution of annual audited financial statements relating to two private funds (collectively, the \"NSR funds\") advised by New Silk Route Advisors, L.P. (\"NSR\"). The settlement order included findings that (1) NSR failed to timely distribute such annual audited financial statements to the investors in the NSR funds and (2) NSR did not adopt or implement written policies and procedures reasonably designed to prevent such violation. As a result, the settlement order finds that NSR violated section 206(4) of the Investment Advisers Act of 1940, as amended, and rules 206(4)-2 and 206(4)-7 thereunder. NSR consented to the settlement order without admitting or denying the SEC's findings.","res":"Settled","sd":"Pursuant to the settlement order, NSR was ordered to cease and desist from committing or causing any violations and any future violations of section 206(4) of the Investment Advisers Act of 1940, as amended, and rules 206(4)-2 and 206(4)-7 thereunder, and agreed to pay a civil money penalty of $75,000. NSR was also censured pursuant to the terms of the settlement order. The settlement order provides that payment shall be made within 15 days of the entry of the order.","sm":"Pursuant to the settlement order, NSR was ordered to cease and desist from committing or causing any violations and any future violations of section 206(4) of the Investment Advisers Act of 1940, as amended, and rules 206(4)-2 and 206(4)-7 thereunder, and agreed to pay a civil money penalty of $75,000. NSR was also censured pursuant to the terms of the settlement order. The settlement order provides that payment shall be made within 15 days of the entry of the order. No claims were made against any of NSR's advisory affiliates. No information Filed","ab":"New Silk Route Advisors, L.P.","self":true,"firms":[161339],"id":1407},{"d":"2018-07-16","di":"2018-07-16","dr":"2018-07-16","k":"Regulatory Action","rg":"Other","reg":"Finanstilsynet: the Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":18500.0,"dk":"17/11166","al":"On July 16, 2018, Kayne Anderson Rudnick Investment Management, LLC (\"KAR\") received notice from the financial supervisory authority of norway (\"finanstilsynet\") that finanstilsynet had levied a penalty against KAR equivalent to approximately 18,500 usd based on a finding that two notifications of large share ownership in a norwegian company were not made in a timely manner under norwegian law.","res":"Decision","ab":"Kayne Anderson Rudnick Investment Management, LLC","self":true,"firms":[104599],"id":1408},{"d":"2018-07-10","di":"2018-07-10","dr":"2018-07-10","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty and censure","st":"Final","fine":100000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-18585","al":"The SEC alleged that in three instances, Oaktree provided advisory services for compensation for two years to a state or local governmental investor after a \"covered associate\" of Oaktree made a personal campaign contribution to a candidate for a governmental position which had the ability to influence the selection of investment advisers for that governmental investor, in technical violation of rule 206(4)-5 under the Advisers Act (the SEC's \"pay-to-play\" rule for investment advisers). These non- scienter based violations took place in 2014 and 2016.","res":"Order","sd":"Oaktree paid a civil monetary penalty in the amount of $100,000 within 10 days of the entry of the order.","sm":"The action was resolved pursuant to an SEC order dated July 10, 2018: in the matter of Oaktree Capital Management, L.P., administrative proceeding file no. 3-18585. Without admitting or denying the findings except as to the commission's jurisdiction over it and the subject matter of these proceedings, Oaktree consented to the entry of the order that Oaktree (I) 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)-5 thereunder; (II) is censured; (III) pay a civil money penalty of $100,000 to the SEC.","ab":"Oaktree Capital Management, L.P.","self":true,"firms":[106793],"id":1409},{"d":"2018-07-10","di":"2018-07-10","dr":"2018-07-10","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure","st":"Final","fine":500000.0,"dk":"3-18584","al":"On July 10, 2018, the Securities and Exchange Commission (\"SEC\"), acting pursuant to an offer by the registrant which consented, without admitting or denying the factual allegations and findings, to the entry of an order making certain findings and imposing certain remedies, instituted administrative proceedings against the registrant, finding that the registrant had violated section 206(4) of the Investment Advisers Act of 1940 (the \"Advisers Act\") and rule 206(4)-5 thereunder when the registrant provided investment advisory services for compensation to certain government entities in Texas, Wisconsin, and Indiana within two years after covered associates of the registrant made campaign contributions to candidates for elective offices who were \"officials\" of the government entities as defined in the rule. The SEC noted that Advisers Act rule 206(4)-5 does not require a showing of quid pro quo or actual intent to influence an elected candidate.","res":"Order","sm":"The action was resolved pursuant to commission order: in the matter of Encap Investments L.P., administrative proceeding file no. 3-18584 (\"order\"). Pursuant to the order, the registrant was ordered to 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)-5 thereunder. Additionally, pursuant to the order, the registrant was censured and was also ordered to, within 10 days of the entry of the order, pay a civil monetary penalty of $500,000 to the SEC. the registrant paid the civil penalty on July 10, 2018. No information Filed","ab":"Encap Investments L.P.","firms":[160695],"id":1410},{"d":"2018-07-02","di":"2018-03-05","dr":"2018-07-02","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt Fur Finanzdienstleistungsaufsicht (\"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"None","st":"Final","fine":365397.0,"dk":"BAFIN-115741090005-WA 17-WP 3120-2015/0096","al":"BAFIN levied a fine of euro 200,000 for each of Wasatch funds trust and wa holdings, inc. for failure to submit a voting rights notification on time to BAFIN, stating that the percentage of voting rights for a security held in client portfolios and an affiliated mutual fund had fallen below the 3% notification threshold (from 3.26% to 2.89%).","res":"Acceptance, Waiver & Consent(AWC)","sd":"Original fine: eur 400,000. After working with local counsel, BAFIN lowered the fine to eur 288,000; additional procedural fees: eur 14,400; total paid: eur 302,400 ($365,397); date paid: May 7, 2018","sm":"On July 2, 2018, Wasatch was notified by BAFIN that the matter was completely resolved. No information Filed","ab":"Wasatch Advisors LP","self":true,"firms":[106081],"id":1411},{"d":"2018-06-29","di":"2017-06-16","dr":"2018-06-29","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30457.42,"dk":"EAD-2/DSR/RG/14036/2017-PM/RR/02/2018-19","al":"In a notice to Goldman Sachs (India) securities private limited (\"GIPL\"), the Securities and Exchange Board of India (\"SEBI\") alleged that GIPL made certain misleading statements to SEBI following the deferral of a qualified institutional placement of securities in INDIA, in alleged violation of paragraph 20 of the code of conduct for merchant bankers under the SEBI (merchant bankers) regulations, 1992.","res":"Settled","sm":"Without admitting or denying the findings of fact and conclusions of law, gipl submitted a settlement application to sebi which was accepted by sebi on June 29, 2018, in which gipl agreed to make a monetary payment to sebi in the amount of 20,80,242 indian rupees (INR), which was paid by submission of a bank demand draft on June 19, 2018.","ab":"Goldman Sachs (India)","firms":[361],"id":1412},{"d":"2018-06-29","di":"2018-06-29","dr":"2018-06-29","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"18-CH-1804","al":"The clearing house risk committee of the Chicago merchantile exchange alleged that the firm violated CME rule 971.A.1.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1413},{"d":"2018-06-29","di":"2018-06-29","dr":"2018-06-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty, undertaking","st":"Final","fine":3600000.0,"dk":"FILE NO. 3-18566","al":"The SEC alleged that MSWM willfully violated certain sections of the Investment Advisers Act of 1940, specifically section 206(4) and rule 206(4)-7 thereunder, as well as section 203(e)(6).","res":"Order","sm":"On June 29, 2018, the SEC entered into a settlement order with MSWM settling an administrative action which relates to misappropriation of client funds in four related accounts by a single former MSWM financial advisor (\"FA\"). The SEC found that MSWM failed to adopt and implement policies and procedures or systems reasonably designed to prevent personnel from misappropriating assets in client accounts. The SEC specifically found that, over the course of eleven months, the FA initiated unauthorized transactions in the four related client accounts in order to misappropriate client funds. The SEC found that while MSWM policies provided for certain reviews prior to issuing disbursements, such reviews were not reasonably designed to prevent fas from misappropriating client funds. Upon being informed of the issue by representatives of the FA's affected clients, MSWM promptly conducted an internal investigation, terminated the FA, and reported the fraud to law enforcement agencies. MSWM also fully repaid the affected clients, made significant enhancements to its policies, procedures and systems (\"enhanced MSWM policies\") and hired additional fraud operations personnel. The SEC found that MSWM willfully violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. The SEC also found that MSWM failed to supervise the FA pursuant to its obligations under section 203(e)(6) of the Advisers Act. MSWM consented, without admitting or denying the findings, to a censure; to cease and desist from committing or causing future violations; to certain undertakings, including certifications related to the implementation and adequacy of the enhanced MSWM policies and to pay a civil penalty of $3,600,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1414},{"d":"2018-06-25","di":"2018-06-25","dr":"2018-06-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","fine":4000000.0,"dk":"3-18556","al":"SEC admin release 33-10511; 34-83508; ia release 4947, June 25, 2018: the Securities and Exchange Commission (commission) deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to section 8a of the Securities Act of 1933 (Securities Act), section 15(b) of the Securities Exchange Act of 1934 (Exchange Act), and section 203(e) of the Investment Advisers Act of 1940 (Advisers Act) against Wells fargo advisors, LLC. from at least January 2009 through June 2013, certain registered representatives at Wells fargo advisors, LLC (WFA) and its predecessor Wells fargo investments, LLC (WFI) improperly solicited customers to redeem their market-linked investments (MLI) early and purchase new mlis without adequate analysis or consideration of the substantial costs associated with such transactions. An MLI is a fixed maturity financial product whose interest is determined by the performance of a reference asset or market measure such as an equity or commodity index over the term of the product. Mlis have limited liquidity and significant upfront fees, and accordingly WFA considered them to be products intended to be held to maturity and in 2011 implemented a policy prohibiting representatives from engaging in \"short-term trading\" or \"flipping\" of mlis. Notwithstanding WFA's internal guidance and policy, and despite the adverse economic consequences to WFA customers, certain WFA representatives did not reasonably investigate or understand the significant costs of MLI exchanges. Nevertheless, they recommended to their customers that they redeem their mlis early, typically to realize profits, and to use the proceeds from those redemptions to purchase new mlis. Supervisors routinely approved the recommendations or the exchanges. This practice caused certain WFA customers to incur significant costs and impaired the customers' ability to achieve their investment objectives. As a consequence, WFA obtained commissions by means of recommendations that contained implied representations that WFA personnel had formed a reasonable basis for the recommendations when they had not, in fact, done so. As a result of the conduct described above, WFA willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act.","res":"Order","sm":"In anticipation of the institution of these proceedings, 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 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 administrative and cease-and-desist proceedings, pursuant to section 8a of the Securities Act of 1933, section 15(b) of the Securities Exchange Act of 1934, and section 203(e) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (order). As a result of the conduct described, wfa willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act. In view of the foregoing, the commission deems it appropriate and in the public interest to impose the sanctions agreed to in wfa's offer. Accordingly, pursuant to section 8a of the Securities Act, section 15(b) of the Exchange Act, and section 203(e) of the Advisers Act it is hereby ordered that wfa is censured, ordered to 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, and shall pay disgorgement, prejudgment interest, and a civil monetary penalty totaling $5,108,441.27 as follows: wfa shall pay disgorgement of $930,377, which represents the commissions wfa earned on representatives recurrent mli exchanges between January 1, 2009 and August 31, 2012, prejudgment interest thereon of $178,064.27, and a civil money penalty in the amount of $4,000,000, consistent with the provisions of the order.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1415},{"d":"2018-06-25","di":"2011-09-02","dr":"2018-06-25","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Because this is a civil suit there were no regulatory sanctions. The Supreme Court denied Nomura's petition for writ of","st":"Final","al":"The federal housing finance agency (FHFA), as conservator for the federal national mortgage association (fannie mae) and the federal home loan mortgage corporation (freddie mac) filed a complaint against Nomura Holding America inc., Nomura asset acceptance corporation, Nomura holding equity loan, inc., Nomura credit & capital , inc., Nomura securities international, inc., certain of their officers, including an officer who is also a principal of Nomura Corporate Research and Asset Management Inc. (\"ncram'), and an unaffiliated underwriter. The suit, which is unrelated to ncram's investment advisory business, asserts claims pursuant to sections 11,12, and 15 of the Securities Act of 1933, state securities law and state common law in connection with the sale of residential mortgage-backed securities to fannie mae and freddie mac. The suit alleges that the registration statements for such securities contained misstatements and omissions concerning the underlying mortgages. The officer was a control person of issuers which were found to have made misstatements in supplements to their offering materials.","res":"Other","sd":"Because is a civil suit there were no regulatory sanctions.","ab":"Nomura Holding America","firms":[110411],"id":1416},{"d":"2018-06-22","di":"2018-06-22","dr":"2018-06-22","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"CO-2018-0012","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Alabama Securities Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to establish and maintain reasonable policies and procedures to prevent the sale of unregistered, non-exempt securities by LPL to Alabama residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alabama statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1417},{"d":"2018-06-20","di":"2018-06-20","dr":"2018-06-20","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":205000000.0,"dk":"N/A","al":"On June 20, 2018, the New York State Department of Financial Services (\"DFS\"), dbag and dbag's New York branch (collectively, \"the bank\") entered into a consent order (\"order\"). Although the order recognized the bank's \"extraordinary cooperation\" with the DFS and institution of \"wide-ranging reforms to address improper conduct in its FX trading business\", the DFS found that the bank \"fail[ed] to implement effective controls over its FX business\" to ensure that the bank's FX activities complied with safe and sound banking practices and applicable internal policies, which prevented the bank from detecting and addressing improper conduct by certain of its FX traders and salespersons from 2007 to 2013. As a result of this conduct, the DFS found that the bank engaged in unsafe, unsound, and improper conduct.","res":"Order","sm":"The bank consented to the entry of the order on June 20, 2018 by the DFS, pursuant to which the bank: (a) shall pay a civil monetary penalty of $205,000,000, which the bank paid on June 22, 2018; (b) shall not rehire or retain certain former employees involved in the misconduct described in the order; (c) shall submit written plans to improve senior management oversight and the compliance risk management program, an enhanced written internal controls and compliance program, and an enhanced written internal audit program to the DFS within 90 days of the order; (d) for sub-section c, shall promptly implement the approved plans and programs within 10 days of approval by the DFS and thereafter fully comply with them; and (e) shall submit written progress reports to the DFS at the point of 12 and 24 months after execution of the order.","ab":"Deutsche Bank AG and","firms":[300838],"id":1418},{"d":"2018-06-19","di":"2018-06-19","dr":"2018-06-19","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":42000000.0,"dk":"3-18549","al":"On June 19, 2018, the Securities and Exchange Commission (SEC) issued an administrative proceeding against the firm concerning the firm's sustained efforts to hide its practice of routing certain institutional customer orders to other broker-dealers (external liquidity providers, electronic liquidity partners, or elps), including proprietary trading firms and wholesale market makers, for execution. The firm configured a number of internal and external trade reporting systems so that institutional customer orders that were executed at elps instead appeared to institutional customers to have been executed at the firm. The firm similarly misreported elp executions in reports provided to institutional customers and in billing invoices. When responding to institutional customer questionnaires and in other communications, the firm specifically omitted elps from lists of venues to which institutional customer orders were routed. The firm referred to this practice internally as \"masking.\" The firm masked the elp executions of the firm's \"direct strategy access\" or \"dsa\" institutional customers. These institutional customers typically were financial institutions such as asset managers, mutual fund investment advisers, and public pension funds. The firm falsely reported to institutional customers that all of these transactions occurred at the firm. As a result of the firm's masking practice, institutional customers did not know that some of their orders were executed at elps and other orders were exposed to elps before being executed at other venues. As a result, these institutional customers' orders received unwanted executions against entities with which they believed their orders would not interact. Because of masking, these institutional customers did not know that the firm violated their instructions. The firm stopped masking in May 2013 on a prospective basis, but did not inform institutional customers that it previously had masked their elp executions. To the contrary, the firm configured systems so that future reports to institutional customers, typically provided on a monthly or quarterly basis, continued to mask elp executions. The firm's statements and omissions in communications to institutional customers through responses to questionnaires, messages regarding trade executions, reports, and billing statements were materially misleading concerning orders that the firm sent to elps and orders that the elps executed. The firm's efforts to mask the correct trading venues, including by altering trade reporting programs, operated as a fraud or deceit upon its institutional customers. As a result, the firm willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act.","res":"Order","sm":"The firm was censured, ordered to 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 and ordered to pay a civil money penalty in the amount of $42,000,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1419},{"d":"2018-06-18","di":"2018-05-25","dr":"2018-06-18","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"SB-05-18","al":"Without admitting or denying the findings of fact and conclusions of law, JPMS consents to the entry of the order confirming an employee of JPMS provided investment advisory services in the capacity of an investment adviser representative of JPMS within the District while not effectively licensed, in violation of section 202(a) of the Securities Act, D.C. Official code 31-5602.02(b)(2).","res":"Decision & Order of Offer of Settlement","sm":"RR relocated from Massachusetts to Washington DC in 2016 and due to a JPMS administrative oversight, the firm neglected to file on their his behalf an application for ra registration (investment advisory representative) and therefore RR conducted ia business in DC without ra registration from 2016 thru 2018. The RR has the series 65 and was eligible for ra status in DC. The firm has communicated with the District of Columbia and acknowledged responsibility for failing to submit the required registration request to the District. Without admitting or denying the findings, the firm settled the allegations by consenting to an administrative fine of $5,000 which has been paid.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1420},{"d":"2018-06-15","di":"2018-06-15","k":"Regulatory Action","dk":"89202-SR","ab":"Sanchez Carrasquillo,","firms":[7691],"id":1421},{"d":"2018-06-13","di":"2018-06-13","dr":"2018-06-13","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"18-0002","al":"Without admitting or denying the findings, it was alleged that the firm violated cfe rules 401a, 412b(a) and 609. On numerous dates from May 2016 through May 2017, due to a third party service provider programming error and a failure to follow its own written procedures, the firm reported inaccurate open interest in various VX weekly contracts, resulting in overstatements of overall exchange open interest. In addition, on numerous dates between December 2016 and August 2017, due to a third party service provider inputting incorrect reportable levels and a failure to follow its own written procedures, the firm failed to report large trader positions in various VX weekly contracts.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1422},{"d":"2018-06-12","di":"2018-06-12","dr":"2018-06-12","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Cease and Desist","os":"Civil and administrative penalty; offers of restitution; undertakings","st":"Final","fine":499000.0,"dk":"E-2017-0067","al":"In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Massachusetts Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to establish and maintain reasonable policies and procedures to prevent the sale of unregistered, non-exempt securities by LPL to Massachusetts residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.","res":"Consent","sm":"This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Massachusetts statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1423},{"d":"2018-06-12","di":"2018-06-12","dr":"2018-06-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; disgorgement; prejudgment interest","st":"Final","fine":5267720.0,"dk":"3-18538","al":"On June 12, 2018, the Securities and Exchange Commission (SEC) issued an administrative proceeding against the firm finding that the firm failed reasonably to supervise firm personnel so as to prevent and detect violations of antifraud provisions of the federal securities laws in connection with the firm's secondary market purchases and sales of certain bonds known as non- agency residential mortgage-backed securities (non-agency RMBS). The trading that is the subject of the order took place from June 2009 through December 2012 (relevant period) and involved intra-day purchases and sales of non-agency RMBS from and to the firm's institutional customers. During the relevant period, firm personnel who purchased and sold non-agency RMBS made false or misleading statements, directly and indirectly, to the firm's institutional customers and/or charged the firm's institutional customers undisclosed excessive mark-ups. By engaging in this conduct, the firm's personnel acted knowingly or recklessly. The firm had both policies that prohibited false or misleading statements and the means to monitor communications for such statements. The firm, however, failed reasonably to implement procedures to monitor for the types of false or misleading statements that were the subject of the order. The firm also had policies that prohibited excessive mark-ups and procedures to monitor for excessive mark-ups on transactions in non-agency RMBS, but the policies and procedures were not reasonably designed and implemented. Due to these deficiencies, the firm failed reasonably to perform a meaningful review of potentially excessive mark-ups on certain non-agency RMBS transactions, including transactions that were the subject of the order. Under the circumstances described above, the firm failed reasonably to supervise for violations of antifraud provisions of the federal securities laws within the meaning of section 15(b)(4)(e) of the Exchange Act.","res":"Order","sm":"The firm was censured, ordered to pay disgorgement and pre-judgment interest totaling $10,535,441, and to pay a civil money penalty in the amount of $5,267,720. In determining to accept the firm's offer, the commission considered remedial steps that Merrill undertook. Merrill also agreed to cooperate fully with the commission in any and all investigations, litigations, or other proceedings relating to or arising from the matters described in the order.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1424},{"d":"2018-06-09","di":"2018-04-27","dr":"2018-06-09","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","st":"Final","fine":200000.0,"dk":"2014040982001","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"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.","sm":"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)","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1425},{"d":"2018-06-08","di":"2018-01-10","dr":"2018-06-08","k":"Regulatory Action","rg":"Other","reg":"Foreign- Comision Nacional Del Mercado de Valores in Spain","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":225000.0,"dk":"NO. 2018046592","al":"Pursuant to regulation (EU) no. 236/2012 on short selling (the \"regulation\"), merian global investors (UK) limited (\"MGI\") is required to file net short position reports (the \"reports\") with the comision nacional del mercado de valores in spain (\"CNMV\") when certain prescribed thresholds are crossed. In November 2017, MGI's compliance function identified an error in the monitoring of such thresholds. MGI immediately commenced an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. On January 10 2018, MGI notified the CNMV of its inadvertent failure to file the reports during the period between July 2014 and December 2017. MGI filed the delinquent reports and put appropriate controls in place to mitigate the risk of the error reoccurring. CNMV subsequently found that MGI breached the regulation by failing to file such reports.","res":"Consent","sd":"See details in number 13 below","sm":"On April 12 2018, CNMV issued an administrative sanction that determined that merian global investors (UK) (\"MGI\"), now known as Jupiter Investment management limited, breached the regulation and imposed a fine of eur 200,000 (approximately usd 225,000). Because MGI complied with certain terms and conditions of the sanction, MGI was eligible for a 40% reduction of the fine (eur 80,000). MGI paid the reduced fine in the amount of eur 120,000 (approximately usd 135,000) effective June 8 2018.","ab":"Jupiter Investment","firms":[306863],"id":1426},{"d":"2018-06-05","di":"2018-05-15","dr":"2018-06-05","k":"Regulatory Action","rg":"Other","reg":"Swedish Finansinspektionen","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"No other sanction","st":"Final","fine":1634.0,"dk":"17-15403, 18-2339, 17-12600","al":"The firm submitted private notifications of net short positions after the deadline of 15H30 on t+1 to the Swedish inspektionen on June 5, September 4, and October 3, 2017. The notifications were submitted on the correct day. No public disclosure of the net short positions was required. The regulatory action were resolved on June 5, 2018 when the firm accepted the Swedish inspektionen's decision of May 15, 2018 to levy a penalty fee of SEK14,300 (US$1,634).","res":"Decision","sm":"The firm submitted private notifications of net short positions after the deadline of 15H30 on t+1 to the Swedish inspektionen on June 5, September 4, and October 3, 2017. The notifications were submitted on the correct day. No public disclosure of the net short positions were required. The regulatory action was resolved on June 5, 2018 when the firm accepted the Swedish inspektionen's decision of May 15, 2018 to levy a penalty fee of SEK14,300 (US$1,634). The firm instituted controls and enhanced procedures to ensure consistent compliance with the regulatory deadline once the breach was identified. There has not been a recurrence subsequently. No information Filed","ab":"Clearance Capital Ltd","self":true,"firms":[166644],"id":1427},{"d":"2018-06-04","di":"2018-06-04","dr":"2018-06-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":500000.0,"al":"On June 4, 2018, the registrant (\"Lyxor\") entered into a agreement with the U.S. Securities and Exchange Commission (\"SEC\") to settle charges relating to a 2012 agreement Lyxor entered into with third-party advisers that managed funds in which Lyxor invested certain client assets. That agreement had a provision for payments to be made to Lyxor based on the total amount of client assets placed or maintained in certain funds managed by the third-party advisers, and Lyxor subsequently received payment pursuant to the agreement. The SEC alleged Lyxor failed to disclose the conflicts of interest arising from the agreement; the agreement was in contravention of investment management agreements Lyxor had with two clients; Lyxor failed to implement policies and procedures reasonably designed to detect and prevent conflicts of interest; and Lyxor failed to maintain accurate books and records to reflect receipt of payment under the agreement. The SEC found, and Lyxor neither admitted nor denied, that Lyxor violated section 206(2) of the Investment Advisers Act of 1940 (\"Advisers Act\"), section 206(4) of the Advisers Act and rule 206(4)-7 thereunder, and section 204(a) of the Advisers Act and rule 204-2(a)(2) thereunder.","res":"Settled","sd":"Pursuant to the settlement, the SEC ordered a civil monetary penalty in the amount of $500,000. The penalty will be paid within 14 days of the entry of the order. No portion of the penalty was waived.","sm":"On June 4, 2018, the SEC announced an agreement with the registrant to settle the charges relating to the 2012 agreement. The SEC administrative order is final. The civil monetary penalty will be paid within 14 days of the entry of the order.","ab":"Lyxor Asset Management","firms":[6210],"id":1428},{"d":"2018-06-01","di":"2018-01-26","dr":"2018-06-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"P-02093","al":"Alleged violations of rule 204(b)-1 under U.S. Investment Advisers Act of 1940, due to the adviser's failure to file form PF.","res":"Decision & Order of Offer of Settlement","sd":"$75,000 paid on June 6, 2018.","sm":"On January 26, 2018, the Securities and Exchange Commission (the \"SEC\") first notified Prescott General Partners LLC (\"Prescott\") that it failed to file certain form PF filings. Pursuant to a settlement offer proposed by the SEC, Prescott agreed to the entry of an order (the \"order\"). Pursuant to the order, Prescott, without admitting or denying the findings, was censured, fined $75,000 and was ordered to cease and desist from committing or causing any violations of rule 204(b)-1 under the Investment Advisers Act. Promptly upon the initial notification by the SEC, Prescott filed an annual form PF for fiscal year 2017, and, promptly upon settlement, Prescott filed all required historical form PF filings with the SEC. No information Filed","ab":"Prescott General Partners LLC","self":true,"firms":[157907],"id":1429},{"d":"2018-05-30","di":"2016-12-13","dr":"2018-05-30","k":"Regulatory Action","rg":"Other","reg":"Thellenic Capital Market Commission (\"HCMC\"), the Greek Financial Services Regulator.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":260000.0,"dk":"135/15.1.2015, 124/15.1.2015 AND 1027/20.3.2015","al":"In April 2014, ozme, a relying adviser of oz management LP (together with ozme, the \"firm\") subscribed for a total of 24,000,000 shares of a secondary offering of EUROBANK ergasias S.A., a greek listed issuer (\"EUROBANK\"). The trade date for this transaction was April 30, 2014, with a settlement date of May 8, 2014, and the EUROBANK shares started trading in the market on May 9, 2014. Ozme subsequently sold some of the long position in the EUROBANK shares, with a trade date of May 6, 2014 and a settlement date of May 9, 2014 (the \"sale transaction\"). Ozme timely delivered the shares on May 9, 2014. The HCMC alleges that the sale transaction amounted to an uncovered short sale in breach of the EU SSR.","res":"Decision","sd":"On May 30, 2018, 11 of the 12 funds that participated in the eurobank placement were fined 324,000 euro, but expect to pay a total fine of 260,000 euro due to the settlement discount. The firm does not expect the 12TH fund to be fined for the reason indicated above. The firm notified the HCMC of its decision not to appeal the fine. While we continue to strongly believe the relevant trades were fully compliant with the EU SSR, the firm's decision to forego the opportunity to appeal and agree to pay the fine associated with the alleged violation will (I) allow the firm to avoid the legal cost of pursuing an appeal and (II) allow the firm to take advantage of a 20% discount on the fine offered by the HCMC to any party which agrees to accept their decision. The firm awaits payment instructions from the HCMC or relevant authority in greece in order to pay the fine. The firm's clients will not bear any cost associated with the fine levied by the HCMC.","sm":"On May 30, 2018, 11 of the 12 funds that participated in the eurobank placement were fined 324,000 euro, but expect to pay a total fine of 260,000 euro due to the settlement discount. The firm does not expect the 12TH fund to be fined for the reason indicated above. The firm notified the HCMC of its decision not to appeal the fine. While we continue to strongly believe the relevant trades were fully compliant with the EU SSR, the firm's decision to forego the opportunity to appeal and agree to pay the fine associated with the alleged violation will (I) allow the firm to avoid the legal cost of pursuing an appeal and (II) allow the firm to take advantage of a 20% discount on the fine offered by the HCMC to any party which agrees to accept their decision. The firm awaits payment instructions from the HCMC or relevant authority in greece in order to pay the fine. The firm's clients will not bear any cost associated with the fine levied by the HCMC. No information Filed","ab":"Och-Ziff Management","firms":[107913],"id":1430},{"d":"2018-05-25","di":"2018-05-25","dr":"2018-05-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine Office of Securities","san":"Restitution","os":"Undertaking","st":"Final","dk":"15-11252-CON","al":"On May 25, 2018, the State of Maine Office of Securities (\"Maine securities\") issued a consent order (\"order\") in connection with Merrill lynch's activities as distribution agent of Maine's NEXTGEN 529 college investment plan-client select series (\"NEXTGEN\") and the fees associated with the different classes of units available to NEXTGEN investors (class a units and class c units). The order cited Merrill lynch for (I) having violated 32 M.R.S. 16412(4)(m) and Maine office of securities rule chapter 504 section 8(3) when its representatives recommended class c units of NEXTGEN to investors for whom class a units likely would have been less expensive over the investors' investment horizon given the age of the investors' beneficiaries, and (II) having violated 32 M.R.S. 16412(4)(I) and Maine office of securities rule chapter 504 section 7(1) by failing to (a) reasonably supervise its agents, and (b) establish and maintain policies and procedures, and effective monitoring or other controls reasonably designed to ensure that its agents properly considered the beneficiaries' age, investment time horizon, and relative expense of class a and class c units when representatives recommended NEXTGEN.","res":"Consent","sm":"Merrill lynch agreed to the entry of the order without admitting or denying the findings of fact and conclusions of law of Maine securities. The order also contained the following language with respect to any of the \"bad actor\" disqualifications under the federal securities laws: \"pursuant to 17 C.F.R. §230.506(d)(2)(II) nothing stated in this consent order gives rise to a disqualification under 17 C.F.R. §230.506(d)(1) or any other statutory or regulatory disqualification provision.\"","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1431},{"d":"2018-05-25","di":"2018-05-25","dr":"2018-05-25","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":25000.0,"dk":"2016-10-00034","al":"The firm violated Securities Exchange Act of 1934 rule 15C3-5(c)(1)(II) (market access rule) by failing to establish, document, and maintain risk management controls and supervisory procedures that were reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time; and NYSE ARCA equities rules 6.18(b) and (c), by failing to establish and maintain adequate supervisory systems and written procedures that were reasonably designed to ensure compliance with rule 15C3-5.","res":"Decision & Order of Offer of Settlement","sm":"In determining to resolve this matter on the basis set forth herein, enforcement took into consideration that the firm cooperated in NYSE regulation's investigation and modified controls relating to the entry of erroneous orders, including pre- market orders, and modified its process for handling the submission of requests for review pursuant to NYSE ARCA rule 7.10-e during pre-market hours. The firm has undertaken to address any remaining deficiencies.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1432},{"d":"2018-05-21","di":"2018-04-20","dr":"2018-05-21","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":45000.0,"dk":"20150452814-03","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), NYSE rules 13(e)(3), 2010, 342 (for conduct before December 1, 2014) and 3110 (for conduct on or after December 1, 2014).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Additionally, acceptance of this AWC is conditioned upon acceptance of settlement agreements in related matters between the firm and the following self-regulatory organizations: (I) CBOE BZX exchange, inc.; (II) CBOE byx exchange, inc.; (III) CBOE edga exchange, inc.; (IV) CBOE edgx exchange, inc.; (v) FINRA; (VI) investors exchange LLC; (VII) NYSE ARCA, inc.; and (VIII) NYSE american LLC.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1433},{"d":"2018-05-21","di":"2018-05-21","dr":"2018-05-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":550000.0,"dk":"2014039653701","al":"Alleged violation of NASD rules 3010, 2110, and 2230, FINRA rules 3110, 2010, and 2232(a), and sea rules 10B-10(a)(1) and 10B-10(a)(2) in that Citigroup Global Markets Inc. failed to have adequate supervisory procedures reasonably designed to ensure compliance with federal securities laws and NASD and FINRA rules regarding the issuance of accurate customer trade confirmations from June 2006 through at least September 2017. As a result, the firm issued certain customer trade confirmations that contained inaccurate information.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $550,000, and an undertaking to address the deficient supervisory system and WSP's relating to the accuracy of customer trade confirmations and to ensure that it has implemented controls and procedures that are reasonably designed to achieve compliance with the rules and regulations.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1434},{"d":"2018-05-21","di":"2018-05-21","dr":"2018-05-21","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12500.0,"dk":"2016051138801","al":"Without admitting or denying the findings, applicant consented to the sanctions and to the entry of findings that it failed to maintain a continuous two-sided trading interest during regular market hours, at prices within certain percentages away from the national best bid or offer (NBBO). The findings stated that the violations occurred because applicant failed to set up the automated quote refresh function in its order management system for each security it was in as a market maker. The findings also stated that applicant's supervisory system was not reasonably designed to achieve compliance with Nasdaq quoting obligations.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, applicant consented to the described sanctions and to the entry of findings, and was censured and fined $12,500. Because applicant has already enhanced its written supervisory procedures and implemented new reviews to ensure compliance with its quoting obligations, an undertaking is not being ordered for this matter.","ab":"A.G.P. / Alliance Global Partners, LLC","self":true,"firms":[8361],"id":1435},{"d":"2018-05-14","di":"2018-04-23","dr":"2018-05-14","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt Fur Finanzdienstleistungsaufsicht (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fee for costs of proceeding","st":"Final","fine":1635872.0,"dk":"NA","al":"The BAFIN alleged that necessary and reasonable supervisory and organizational measures which could have ensured the correct and complete submission of voting rights notifications within the time stipulated were not taken on time or to the adequate extent by the company concerned, which led to violations of voting rights notification requirements.","res":"Other","sm":"The BAFIN imposed a fine on the firm in the amount of eur 1,340,000/usd 1,635,872 and a fee for costs of the proceeding in the amount of eur 7,500/usd 9,156. The effective date of the notice is two weeks after the delivery of the notice - during which time the firm can appeal the notice. The firm did not appeal the notice and the notice became effective on May 14, 2018.","ab":"Bank of America","firms":[7691,142558],"id":1436},{"d":"2018-05-09","di":"2018-05-09","dr":"2018-05-09","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":13500.0,"dk":"2016049343501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it did not follow up on position limit overages and failed to promptly take the action necessary to bring a position into compliance. The findings stated that a correspondent firm, a client of the firm, effected opening transactions for the account of its customer that exceeded the applicable position limit on the bullish side of the market in a security, which was 50,000 contracts, by 5,676 contracts. The next day, the correspondent firm executed an additional 500 contracts in the security for the same customer while the customer's position in the security had already exceeded the position limit on the previous trading day, which further caused the applicable position limit to be exceeded by a total of 6,176 contracts. The findings also stated that the firm maintained and cleared the options positions in the security for the correspondent firm. During a bi-monthly surveillance review of options positions that the firm conducted, it identified the positions in the security. However, the firm mistook the 5,000,000 shares position limit, which it had obtained from the website of the options clearing corporation, as contracts. The 5,000,000 shares position limit is equivalent to the 50,000 contracts position limit since the shares deliverable of an options contract is 100 shares. As such, the firm considered the subject options position to be within the position limit. As a result, the firm did not follow up on these position limit overages and failed to promptly take the action necessary to bring the position into compliance. Further, the correspondent firm also failed to bring its customer's position in the security into compliance with the applicable position limit. The position limit in a security was exceeded for a total 16 consecutive trading days, which ranged from approximately 11 percent to 12 percent over the applicable limit for the security. On March 18, 2016, a position limit increase was published by the options clearing corporation that increased the limit from 50,000 contracts to 75,000 contracts, which brought the customer's positions in compliance. 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 Nasdaq options market LLC (NOM), concerning position limits. Specifically, the firm only conducted a bi-monthly surveillance review of options positions to determine compliance with position limits, and it failed to detect the position limit overages in the security when they were reviewed.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On May 2, 2016, the firm modified its supervisory systems and procedures to provide for a daily review of options positions to determine compliance with position limits for securities in RBC wealth management, a division of the firm.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1437},{"d":"2018-05-08","di":"2018-05-08","dr":"2018-05-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Censure","os":"Monetary fine & undertaking","st":"Final","fine":200000.0,"dk":"20160501987","al":"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.","res":"Decision & Order of Offer of Settlement","sd":"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.","sm":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1438},{"d":"2018-05-08","di":"2018-01-25","dr":"2018-05-08","k":"Regulatory Action","rg":"Other","reg":"Foreign - Danish Financial Supervisory Authority","san":"Reprimand","st":"Final","dk":"J.NO. 6379-0091","al":"Pursuant to regulation (EU) no. 236/2012 on short selling (the \"regulation\"), merian global investors (UK) limited (\"MGI\") is required to file net short position reports (the \"reports\") with the danish financial supervisory authority (\"danish FSA\") when certain prescribed thresholds are crossed. In November 2017, MGI's compliance function identified an error in the monitoring of such thresholds. MGI immediately commenced an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. On January 25 2018, MGI notified the danish FSA of its inadvertent failure to file the reports during the period between September 2015 and January 2018. MGI filed the delinquent reports and put appropriate controls in place to mitigate the risk of the error reoccurring. The danish FSA subsequently found that MGI breached the regulation by failing to file such reports.","res":"Consent","sd":"See details in number 13 below","sm":"On May 8 2018, the danish FSA determined that merian global investors (UK) (\"MGI\"), now known as Jupiter Investment management limited, breached the regulation and issued a reprimand. On May 24 2018, the danish FSA published information regarding the reprimand on its web page.","ab":"Jupiter Investment","firms":[306863],"id":1439},{"d":"2018-05-05","di":"2018-05-05","dr":"2018-05-05","k":"Regulatory Action","rg":"Other","reg":"Sr. Ministro de Economia, Industria Y Competitividad (Spanish Ministry of Economy and Competition)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12346789.0,"dk":"MAR/4028/2017","al":"Failure to maintain certain anti-money laundering controls (relating to, among other things, customer due diligence and the filing of suspicious activity reports during the period of time between 2012 and 2015) meeting the standards required under spanish law.","res":"Decision","sd":"See response to b above.","sm":"On March 1, 2018, the spanish ministry of economy and competition issued an unpublished decision on administrative proceedings as to Banco Santander, S.A. (\"BSSA\"), concluding that certain aspects of BSSA's anti-money laundering controls (relating to, among other things, customer due diligence and the filing of suspicious activity reports during the period of time between 2012 and 2015) did not meet all required standards under spanish law. As a result, the ministry imposed a fine of 10,547,704 euros. BSSA strongly believes the decision is unfounded and without merit and on May 5, 2018 appealed the administrative decision to the spanish high national court. The ministry's decision relates solely to BSSA and is not related in any way to any activity or concerned at or involving Santander Asset Management SA Sgiic. On November 2019, the spanish national court issued a decision on the sanctions matter, which BSSA subsequently appealed to the spanish Supreme Court. And on June 2021, following the Supreme Court's decision, part of the fine was ultimately paid after the amount was reduced (eur 2,000,000.00). BSSA paid the fine.","ab":"Banco Santander, S. A.","firms":[143883],"id":1440},{"d":"2018-05-04","di":"2018-05-04","dr":"2018-05-04","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":30000.0,"dk":"20150452814-01","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into an offer of settlement and consent to the sanctions and entry of findings that the firm violated: (I) SEC rules 611(a) and (c), and NYSE ARCA equities rules 6.1 and 2010, by failing to establish, maintain, and enforce written policies and procedures reasonably designed to prevent trade-throughs of protected quotations in NMS stocks that do not fall within any applicable exception, and if relying on an exception, are reasonably designed to assure compliance with the terms of the exception, and by failing to take reasonable steps to establish that the isos it routed met the definitional requirements set forth in SEC rule 600(b)(30); and (II) SEC rules 611(a) and (c), and NYSE ARCA equities rules 6.1, 6.18 and 2010, by failing to establish and maintain a supervisory system reasonably designed to achieve compliance with SEC rules 611(a) and (c) during the review period, defined as January 2009 through May 2017.","res":"Decision & Order of Offer of Settlement","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1441},{"d":"2018-05-01","di":"2018-05-01","dr":"2018-05-01","k":"Regulatory Action","rg":"Other","reg":"Investors Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":25000.0,"dk":"20150452814-05","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), and iex rules 3.110, 5.110, and 11.190(b)(12).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1442},{"d":"2018-05-01","di":"2018-05-01","k":"Regulatory Action","rg":"State regulator","reg":"The Enforcement Section of the Missouri Securities Division of the Office of Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":320754.72,"dk":"AP-23-18","al":"Pursuant to 15 CSR 30-51.171(2)(a) of the Missouri Securities Act of 2003, The Enforcement Section of the Missouri Securities Division of the Office of Secretary of State alleged that, during the period of approximately July 1, 2016 to June 3, 2018, the broker-dealer's procedures were not reasonably designed with respect to the sale of certain class a share mutual funds relative to the fee offsets provided when certain brokerage customers holding those securities engaged Edward jones to serve as their investment adviser and manage those assets.","res":"Consent","sm":"The Enforcement Section of the Missouri Securities Division of the Office of Secretary of State found that Edward jones did not have reasonably designed procedures with respect to its activities as a broker-dealer during the investigation period that would have detected the conduct alleged, which constituted a violation of 15 CSR 30-51.171(2)(a) of the Missouri Securities Act of 2003. Without admitting or denying the findings of fact or conclusions of law set forth in the consent order, Edward jones agreed to pay an administrative monetary fine of $320,754.72 payable to the Missouri secretary of state investor education and protection fund.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1443},{"d":"2018-05-01","di":"2018-05-01","dr":"2018-05-01","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":54750000.0,"dk":"18-015-B-HC; 18-015-CMP-HC","al":"The Board of Governors of the Federal Reserve System (the \"Federal Reserve\") has alleged that: whereas The Goldman Sachs Group, inc. (\"GS group\") serves as a foreign exchange (\"FX\") dealer through certain of its indirect subsidiaries (\"FX subsidiaries\"), by buying and selling U.S. dollars and foreign currency for their own account and by soliciting and receiving orders through communications between customers and sales personnel that are executed on the spot market (\"covered FX activities\"), from October 2008 through October 2012, GS group and certain subsidiaries (together, the \"firm\"): (a) lacked adequate governance, compliance risk management, compliance and/or audit policies to ensure that the FX subsidiaries' covered FX activities complied with safe and sound banking practices and applicable internal policies; and (b) had deficient policies and procedures that prevented it from detecting and addressing potentially unsound conduct by certain of the FX subsidiaries' FX traders, and as a result of the deficient policies and procedures, engaged in unsafe and unsound banking practices.","res":"Consent","sm":"On May 1, 2018, prior to the filing of any notices of charges, or taking of any testimony, or adjudication of or finding on any issues of fact or law herein, and solely for the purpose of settlement of this matter without a formal proceeding being filed and without the necessity for protracted or extended hearings or testimony, GS group and the Federal Reserve entered into an order to cease and desist and order of assessment of a civil money penalty issued upon consent pursuant to the federal deposit insurance act, as amended (the \"consent order\"), pursuant to which: (a) GS group, as applicable, shall submit to the Federal Reserve within the applicable time periods set forth in the consent order, an enhanced written internal controls and compliance program, compliance risk management program, controls review, and internal audit program, each as acceptable to the Federal Reserve; (b) the firm shall adopt and implement these programs and submit progress reports to the Federal Reserve; (c) the firm shall not in the future directly or indirectly retain any individual as an officer, employee, agent, consultant, or contractor of the firm or any subsidiary or any affiliate thereof who has participated in the conduct underlying the consent order, been subject to a formal disciplinary action as a result of the firm's internal disciplinary review or performance review in connection with the conduct described in the consent order and separated from the firm or any subsidiary thereof or had his or her employment terminated in connection with the conduct described in the consent order; and (d) the firm paid a civil monetary penalty in the amount of $54,750,000 on May 2, 2018.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1444},{"d":"2018-05-01","di":"2018-05-01","dr":"2018-05-01","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":54750000.0,"al":"The New York State Department of Financial Services (the \"DFS\") has alleged that: (a) certain foreign exchange (\"FX\") traders at certain affiliates of The Goldman Sachs Group, inc. and Goldman Sachs bank USA (together, \"Goldman Sachs\") engaged in improper conduct over the period 2008 through early 2013; (b) escalation of certain compliance concerns did not always occur as required, allowing potentially improper activity to continue unnecessarily; and (c) Goldman Sachs conducted banking business in an unsafe and unsound manner, in violation of New York banking law § 44.","res":"Consent","sd":"On May 1, 2018, Goldman Sachs and the DFS entered into a consent order under New York state banking law §§ 39 and 44, which assesses Goldman Sachs a civil monetary penalty in the amount of $54,750,000, which Goldman Sachs paid to the DFS on May 8, 2018.","sm":"On May 1, 2018, Goldman Sachs and the DFS entered into a consent order under New York state banking law §§ 39 and 44 (the \"consent order\"), pursuant to which Goldman Sachs: (a) shall not in the future rehire or retain a certain trader as either an officer, employee, agent, consultant, or contractor of Goldman Sachs or any affiliate of Goldman Sachs, or in any other capacity; (b) shall submit to the DFS within the applicable time periods set forth in the consent order, an enhanced written internal controls and compliance program, compliance risk management program, and internal audit program, each acceptable to the DFS, adopt and implement those programs, and provide written progress reports concerning: (I) compliance with applicable New York state and federal laws and regulations as regards its FX business, and recognized FX industry best practices, as affect or pertain to Goldman Sachs or New York customers; (II) creation of enhanced policies and procedures governing the FX business, and Goldman Sachs' compliance with those policies and procedures, as affect or pertain to Goldman Sachs or New York customers, and (III) Goldman Sachs' maintenance of an honest, ethical and fair FX business as it affects or pertains to the New York branch or New York customers; and (c) paid a civil monetary penalty in the amount of $54,750,000 on May 8, 2018.","ab":"The Goldman Sachs Group,","firms":[283221,286067],"id":1445},{"d":"2018-04-30","di":"2018-04-12","dr":"2018-04-30","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"18-9579","al":"The market regulation department of the CME Group Inc. (\"CME\") determined that certain Goldman Sachs & Co. LLC (the \"firm\") trade data for the trade dates of December 11, 2017 through February 23, 2018 reflected a computerized trade reconstruction (CTR) error rate in excess of applicable threshold levels, in deemed violation of chicago mercantile exchange inc. rule 536.f.","res":"Decision","sm":"The CME imposed a fine on the firm in the amount of $5,000, which was paid by submission of a wire on May 4, 2018.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1446},{"d":"2018-04-26","di":"2018-04-26","dr":"2018-04-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":25000.0,"dk":"2011027891502","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its former registered representative entered orders in the equity shares of a security on behalf of client accounts that he improperly marked as \"unsolicited\" despite the fact that such orders were solicited, causing the firm's books and records to be inaccurate. The findings stated that the firm had programmed its order management system to block the former registered representative from entering solicited orders in the security. The restriction was lifted, but the systemic block was not immediately removed. Upon discovering, that the systemic block had not been lifted and that the firm's former registered representative had been mismarking orders, it reprogrammed its order management system and had its former registered representative correct the mismarked orders. Thereafter, the firm corrected its books and records.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1447},{"d":"2018-04-23","di":"2018-04-23","dr":"2018-04-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":40000.0,"dk":"20150452814-04","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), NASD rule 3010, and FINRA rules 2010 and 3110.","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1448},{"d":"2018-04-20","di":"2018-04-20","dr":"2018-04-20","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":40000.0,"dk":"20150452814-02","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), NYSE American rule 7.31e(e)(3), NYSE American rules 16 - equities (for conduct before May 26, 2009) and 2010 - equities (for conduct on or after May 26, 2009),and NYSE American rules 342 - equities (for conduct before December 1, 2014) and 3110 - equities (for conduct on or after December 1, 2014).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1449},{"d":"2018-04-20","di":"2018-04-05","dr":"2018-04-20","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"RSRH-18-5008","al":"CME Group Inc. (\"CME\") market regulation issued a summary fine notice to Goldman Sachs & Co. LLC (the \"firm\") stating that CME market regulation identified two block trades that were reported late or misreported by the firm during January 2018, in violation of CME rule 526.f.","res":"Decision","sm":"The summary fine, in the amount of $1,000, was paid by submission of a wire on April 24, 2018.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1450},{"d":"2018-04-20","di":"2018-04-20","dr":"2018-04-20","k":"Regulatory Action","rg":"Other","reg":"Bureau of Consumer Financial Protection","san":"p","os":"Restitution disgorgement cease and desist","st":"Final","fine":500000000.0,"dk":"2018-BCFP-0001","al":"Without admitting or denying the findings of fact or conclusions of law, the bank consented to the issuance of an order in which the CFPB found that the bank engaged in unfair acts or practices in violation of sections 1031(c) and 1036(a)(1)(b) of the consumer financial protection act of 2010 (CFPA) for certain specified acts and practices related to: (1) the bank's failure to follow the mortgage-interest-rate-lock process it explained to some prospective borrowers; and (2) the bank's force-placed automobile collateral protection insurance (CPI) program. In addition to ordering the bank to stop engaging in the specified acts and practices, the order further requires the bank to: (1) maintain a compliance committee responsible for monitoring and overseeing the bank's compliance with the provisions of the order; (2) submit an acceptable enterprise-wide compliance risk management plan designed to ensure the bank's acts and practices comply with federal consumer financial law and the terms of the order, a staffing assessment for the compliance risk management program, and a plan to enhance the internal audit program with respect to compliance; (3) establish a comprehensive remediation program for remediation activities conducted by the bank and establish remediation plans addressing the CPI and mortgage-interest-rate-lock findings in the order; (4) pay a civil money penalty of $1 billion, for which only $500 million must be paid to the CFPB as the CFPB is treating the payment of the $500 million OCC penalty as partial satisfaction of the penalty; and (5) comply with various reporting and approval requirements.","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1451},{"d":"2018-04-20","di":"2018-04-20","dr":"2018-04-20","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency (OCC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution disgorgement cease and desist","st":"Final","fine":500000000.0,"dk":"AA-EC-2018-15 & AA-EC-2018-16","al":"Without admitting or denying the findings, the bank consented to the issuance of an order in which the OCC found that the bank failed to implement and maintain an enterprise-wide compliance risk management program commensurate with the bank's size, complexity, and risk profile. The OCC found that the deficiencies in the bank's enterprise-wide compliance risk management program, which were identified during the OCC's ongoing supervision of the bank, constituted reckless unsafe or unsound practices resulting in violations of the unfair acts or practices provision of section 5 of the federal trade commission act. The OCC also found that deficiencies in the bank's automobile collateral protection insurance (CPI) program and mortgage interest rate lock extension fee practices constituted unfair acts or practices and were unsafe or unsound. The order requires the bank to: (1) maintain a compliance committee responsible for monitoring and overseeing the bank's compliance with the provisions of the order; (2) develop and execute a compliance risk management plan, a consent order action plan, a staffing assessment for the compliance risk management program, and a plan to enhance the internal audit program with respect to compliance; (3) establish a comprehensive remediation program for remediation activities conducted by the bank and establish remediation plans addressing CPI and mortgage interest rate lock extension fees; (4) pay a civil money penalty of $500,000,000; and (5) comply with various reporting and approval requirements.","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1452},{"d":"2018-04-19","di":"2018-04-19","dr":"2018-04-19","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"17-0642-BC","al":"Alleged violation of CME rule 811 in that Citigroup Global Markets Inc. misreported open interest in multiple products between .49% and 16.05% of the total open interest in these products on certain dates in January 2017.","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a fine of $10,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1453},{"d":"2018-04-19","di":"2018-04-19","dr":"2018-04-19","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"17-0642-BC","al":"Alleged violation of CME rule 811 in that Citigroup Global Markets Inc. misreported open interest in multiple markets between .1% and 28% of the total open interest in these products on certain dates in January 2017 and June 2017.","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a fine of $20,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1454},{"d":"2018-04-16","di":"2018-04-16","dr":"2018-04-16","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":40000.0,"dk":"20150452814-09","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), and edgx rules 3.1, 5.1, and 11.8(c).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1455},{"d":"2018-04-16","di":"2018-04-16","dr":"2018-04-16","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":45000.0,"dk":"20150452814-07","al":"Without admitting or denying any allegations or findings, J.P. Morgan Securities, LLC (\"the firm\") entered into a letter of acceptance, waiver and consent stating that during the review period, defined as January 2009 through May 31, 2017, the firm, due to various proprietary system flaws and deficiencies, the firm on numerous occasions routed isos through protected quotations. Limitations in the firm's systems also led to a failure to retain market data snapshots from the securities information processor (\"SIP\"), which the firm used to make order routing determination, in violation of: SEC rules 611(a) and (c), and byx rules 3.1, 5.1, and 11.9(d).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1456},{"d":"2018-04-13","di":"2018-04-13","dr":"2018-04-13","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","st":"Final","fine":250000.0,"dk":"16-CH-1607","al":"On April 12, 2018, the CME clearing house risk committee reviewed the firm's risk based examination report dated March 9, 2018 and charged the firm with violating CBOT rules 951., 970.a., 971.a., 971.A.1. And 980.b.","res":"Settled","sd":"The fine of $250000 was paid.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1457},{"d":"2018-04-13","di":"2018-04-13","dr":"2018-04-13","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8000.0,"dk":"CI15-011 AND CI15-013","al":"Alleged that WFCS has violated NRS 90.360(2) and nac 90.392 by maintaining three (3) branch office locations in the state of Nevada without obtaining a license from the division","res":"Order","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1458},{"d":"2018-04-13","di":"2018-04-13","dr":"2018-04-13","k":"Regulatory Action","rg":"Other","reg":"Box Options Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"2014043230901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it inappropriately used options clearing corporation (OCC) adjustments to create a position without trading on an exchange and subsequently inappropriately used OCC adjustments to close out a position without trading on an exchange. The findings stated that further, it was determined that the firm through 273 internal entries triggered OCC adjustments in a total of 107 symbols for a total of 203,478 contracts, which created long and short positions at the OCC without trading on an exchange, and resulted in inflated open interest. The findings also stated that the firm failed to follow its written supervisory procedures related to the proper use of OCC adjustments. The firm further failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with the applicable securities laws and regulations, and box rules, concerning OCC adjustments, as the firm did not have any procedures in place to verify that OCC adjustments were not associated with internal entries.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1459},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":40000.0,"dk":"2014041261702","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce written policies and procedures that were reasonably designed to prevent trade-throughs of protected quotations in national market system (NMS) stocks that did not fall within any applicable exception, and if relying on an exception, were reasonably designed to assure compliance with the terms of the exception. The findings stated that the firm inaccurately appended print protection modifiers to transaction reports submitted to the FINRA/Nasdaq trade reporting facility (FNTRF) identifying the transactions as qualifying for an exception or exemption from SEC rule 611 of regulation NMS. The findings also stated that for stopped orders that the firm purportedly had executed pursuant to SEC rule 611(b)(9), it failed to document on an order-by-order basis the specified price agreed to by the customer and the time at which the stop price was determined.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $40,000, and required to revise its WSPS.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1460},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Other","reg":"Box Options Exchange LLC","st":"Final","fine":20400.0,"dk":"2013036836014","al":"Alleged non-compliance with a certain system of risk management controls andexchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $20,400 was paid to box;and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1461},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":59500.0,"dk":"2013036836015","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $59,500 was paid to FINRA;and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1462},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Other","reg":"Investors' Exchange LLC","st":"Final","fine":75000.0,"dk":"2013036836016","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $75,000 was paid to iex;and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1463},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","st":"Final","fine":59700.0,"dk":"2013036836003","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $59,700 was paid to PHLX;and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1464},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq BX, Inc.","st":"Final","fine":67000.0,"dk":"2013036836002","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $67,000 was paid to BX; and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1465},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":189700.0,"dk":"2013036836001","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $189,700 was paid to Nasdaq;and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consents to the sactions and to the entry of the findings that it was non- compliant with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1466},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Options Market LLC","st":"Final","fine":7300.0,"dk":"2013036836004","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $7,300 was paid to Nasdaq Options Market LLC and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1467},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","st":"Final","fine":77100.0,"dk":"2013036836009","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured and fined $77,100 paid to NYSE ARCA inc., and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm accepted the offer of settlement and consents to pay a fine total of $1,575,000, of which $77,100 was paid to NYSE ARCA inc.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1468},{"d":"2018-04-11","di":"2018-04-11","dr":"2018-04-11","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","st":"Final","fine":276100.0,"dk":"2013036836010","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured and fined $276,100 paid to NYSE ARCA equities inc., and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm accepted the offer of settlement and consents to pay a fine total of $1,575,000, of which $276,100 was paid to NYSE ARCA equities inc.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1469},{"d":"2018-04-10","di":"2018-03-12","dr":"2018-04-10","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","st":"Final","fine":5000.0,"dk":"2014041261701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to implement policies and procedures to reasonably avoid displaying, or engaging in a pattern or practice of displaying, any quotations that locked or crossed a protected quotation, and any manual quotations that locked or crossed a quotation previously disseminated pursuant to an effective national market system plan. 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 BZX rules concerning locking or crossing protected quotations. Specifically, with respect to its direct market access clients, the firm's system did not include written supervisory procedures providing for the following: (1) the identification of the persons responsible for supervision with respect to the applicable rules; (2) a statement of the supervisory steps to be taken by the persons identified as responsible for ensuring compliance with the applicable rules; (3) a statement of the frequency with which such person should take such steps; and (4) a statement as to how the completion of the steps included in the written supervisory procedures should be documented.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $5,000. If this settlement is made pursuant to BZX rule 8.8, the decision in this matter is final 20 business days after the issuance of the decision. Therefore, this AWC became final April 10, 2018.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1470},{"d":"2018-04-06","di":"2018-04-06","dr":"2018-04-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":115000.0,"dk":"2013037652201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce written policies and procedures that were reasonably designed to prevent trade-throughs of protected quotations in NMS stocks that do not fall within any applicable exception, and if relying on an exception, are reasonably designed to assure compliance with the terms of the exception. The findings stated that the firm failed to take reasonable steps to establish that the intermarket sweep orders it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The firm experienced four systems issues that gave rise to certain of the above violations. In connection with one of the systems issues, the firm became aware in June 2007 that its smart order router would limit the total share quantity of its regulation NMS sweep obligation to the share quantity of the relevant underlying customer facilitation trade. Thus, in cases where the quantity of superior protected quotations in the market were greater than the quantity of shares in the underlying customer facilitation trade, the firm's smart order router may not have routed intermarket sweep orders to all superior protected quotations in the market or to the full size of all superior protected quotations in the market resulting in trade-throughs of those protected quotations. The firm failed to recognize the scope of the issue and assigned it a low priority for later remediation. The firm did not remediate the issue until March 2014. The firm also reported certain trades with trade through exempt modifiers to the FINRA trade reporting facility when, in fact, the transactions were not exempt.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $115,000 and required to comply with an undertaking to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1471},{"d":"2018-04-06","di":"2018-04-04","dr":"2018-04-06","k":"Regulatory Action","rg":"State regulator","reg":"Ontario Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":900000.0,"dk":"2018-15","al":"The Ontario Securities Commission alleged that Mackenzie failed to (I) comply with national instrument 81-105 mutual fund sales practices (\"ni 81-105\") by not meeting the minimum standards of conduct expected of industry participants in relation to certain sales practices between May 2014 and December 2017; (II) have systems of controls and supervision over its sales practices that were sufficient to provide reasonable assurances that it was complying with its obligations under ni 81-105; and (III) maintain adequate books, records and other documents to demonstrate its compliance with ni 81-105.","res":"Order","sd":"The total amount levied against Mackenzie was $1,050,000 (canadian dollars). All amounts were paid on April 4, 2018, as required by the order and settlement agreement.","sm":"The Ontario Securities Commission (\"OSC\") investigated Mackenzie for sales practices related to mutual fund products. The OSC concluded that MFC failed to comply with national instrument 81-105 (\"ni 81-105\"). The OSC and Mackenzie entered into a settlement agreement on April 6, 2018. The settlement agreement states that Mackenzie failed to comply with ni 81-105. The purpose of ni 81-105 is to discourage sales practices that could be perceived as inducing dealers and their representatives to sell mutual fund securities on the basis of incentives they were receiving (such as promotional items or activities) rather than on the basis of what is suitable for and in the best interest of their clients. Mackenzie agreed to: (I) pay an administrative penalty of $900,000 (canadian dollars); (II) submit to regular reviews of its sales practices, procedures and controls by an independent consultant; (III) and pay costs of the investigation in the amount of $150,000 (canadian dollars). All amounts have been paid pursuant to the settlement agreement. No information Filed","ab":"Mackenzie Financial Corporation","self":true,"firms":[110338],"id":1472},{"d":"2018-04-06","di":"2018-04-04","dr":"2018-04-06","k":"Regulatory Action","rg":"Other","reg":"Ontario Securiteis Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":900000.0,"dk":"2018-15","al":"The Ontario securities commission alleged that Mackenzie financial corporation failed to (I) comply with national instrument 81-105 mutual fund sales practices (\"ni 81-105\") by not meeting the minimum standards of conduct expected of industry participants in relation to certain sales practices between May 2014 and December 2017; (II) have systems of controls and supervision over its sales practices that were sufficient to provide reasonable assurances that it was complying with its obligations under ni 81-105 and (III) maintain adequate books, records and other documents to demonstrate its compliance with 81-105.","res":"Order","sd":"The total amount levied against Mackenzie financial corporation was $1,050,000 (canadian dollars). All amounts were paid on April 4, 2018, as required by the order and settlement agreement.","sm":"The Ontario securities commission (\"OSC\") investigated Mackenzie financial corporation for sales practices related to mutual fund products. The OSC concluded that MFC failed to comply with national instrument 81-105 (\"ni 81-105\"). The OSC and Mackenzie entered into a settlement agreement on April 6, 2018. The settlement agreement states that Mackenzie failed to comply with ni 81- 105. The purpose of ni 81-105 is to discourage sales practices that could be perceived as inducing dealers and their representatives to sell mutual fund securities on the basis of incentives they were receiving (such as promotional items or activities) rather than on the basis of what is suitable for and in the best interest of their clients. Mackenzie agreed to: (I) pay an administrative penalty of $900,000 (canadian dollars); (II) submit to regular reviews of its sales practices, procedures and controls by an independent consultant; (III) and pay costs of the investigation in the amount of $150,000 (canadian dollars). All amounts have been paid pursuant to the settlement agreement. No information Filed","ab":"Mackenzie Investments","firms":[165899],"id":1473},{"d":"2018-03-26","di":"2018-03-26","dr":"2018-03-26","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Securities Division","san":"Cease and Desist","st":"Final","fine":2500.0,"dk":"FILE NO. 14 SEC 035","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the North Carolina Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its North Carolina representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to North Carolina residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to North Carolina residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a sum in the amount of $24,342.35. The sum represents a civil penalty of $2,500 plus $21,842.35 for investigative costs. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1474},{"d":"2018-03-22","di":"2018-03-22","dr":"2018-03-22","k":"Regulatory Action","rg":"State regulator","reg":"Attorney General of the State of New York Investor Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Agreement not to engage, or attempt to engage, in conduct in violation of any applicable laws, agreement to provide certain","st":"Final","fine":42000000.0,"dk":"AGREEMENT NO. 18-025","al":"The Attorney General of the State of New York Investor Protection Bureau alleged that Bank of America corporation (BAC) and the firm (1) concealed from its institutional clients that orders were routed to and executed by \"electronic liquidity providers,\" (2) misstated the composition of orders and trades in its dark pool, and (3) did not accurately describe its use of a proprietary \"venue ranking\" analysis, in violation of the martin act and executive law § 63(12).","res":"Settled","sm":"In connection with the agreement, bofaml agreed (1) not to engage, or attempt to engage, in conduct in violation of any applicable laws, including but not limited to the martin act and executive law § 63(12); (2) to pay a penalty in the amount of $42,000,000; and (3) provide the nyag a summary of the review of its electronic trading policies and procedures.","ab":"Bank of America","firms":[7691,142558],"id":1475},{"d":"2018-03-19","di":"2018-03-19","dr":"2018-03-19","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Cease and Desist","st":"Final","fine":10934.13,"dk":"SB-03-18","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the District of Columbia Department of Insurance, Securities and Banking (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its District of Columbia representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to District of Columbia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to District of Columbia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $10,934.13. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1476},{"d":"2018-03-17","di":"2018-02-15","dr":"2018-03-17","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":195600.0,"dk":"2013036836011","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $195,600 was paid to the New York Stock Exchange; and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm accepted the offer of settlement and consents to pay a fine total of $1,575,000, of which $195,600 was paid to New York Stock Exchange.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1477},{"d":"2018-03-17","di":"2018-02-15","dr":"2018-03-17","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","st":"Final","fine":47800.0,"dk":"2013036836012","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $47,800 was paid to NYSE American; and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm accepted the offer of settlement and consents to pay a fine total of $1,575,000, of which $47,800 was paid to NYSE American LLC.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1478},{"d":"2018-03-09","di":"2018-02-08","dr":"2018-03-09","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":30000.0,"dk":"2016-07-01063","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to implement adequate written procedures and supervisory systems and controls reasonably designed to achieve compliance with NYSE rule 123c with respect to certain of the firm's proprietary trading units. The findings stated that the firm failed to comply with the requirements governing the cancellation of market-on-close/limit-on-close (moc/loc) and closing offset (CO) orders when firm traders cancelled three moc/loc or CO orders between 3:45 P.M. And 3:58 P.M. That were not the result of legitimate order errors. In addition, the firm failed to provide complete and/or accurate information in response to requests by NYSE regulation. Specifically, the firm provided incomplete, incorrect and/or misleading information on material issues to this matter, including its relationship to certain clients and its related supervisory systems. The firm also provided an explanation of how other cancellations were entered on the NYSE that was later determined to not be complete and/or accurate.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $30,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1479},{"d":"2018-03-09","di":"2018-02-08","dr":"2018-03-09","k":"Regulatory Action","rg":"Other","reg":"Bats Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":57500.0,"dk":"2014041324302","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take resonable steps to establish that the inter-market sweep orders it routed met the definitional requirements set forth in SEC rule 600(b)(30) of regulation NMS. The findings stated that the firm failed to establish, maintain and enforce a supervisory system that was reasonably designed to achieve compliance with the applicable securities laws and regulations, and byx rules, concerning compliance with rule 611(c). Specifically, the firm's supervisory system did not include written supervisory procedures (\"WSPS\") that included an identification of the person(s) responsible for supervision with respect to applicable rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total of $135,000, of which $57,500 is payable to the exchange. In addition, the firm agreed to revise its written supervisory procedures with respect to the areas outlined in the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1480},{"d":"2018-03-09","di":"2018-02-08","dr":"2018-03-09","k":"Regulatory Action","rg":"Other","reg":"Bats BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":77500.0,"dk":"2014041324301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take resonable steps to establish that the inter-market sweep orders it routed met the definitional requirements set forth in SEC rule 600(b)(30) of regulation NMS. The findings stated that the firm failed to establish, maintain and enforce a supervisory system that was reasonably designed to achieve compliance with the applicable securities laws and regulations, and BZX rules, concerning compliance with rule 611(c). Specifically, the firm's supervisory system did not include written supervisory procedures (\"WSPS\") that included an identification of the person(s) responsible for supervision with respect to applicable rules. The findings also stated that the firm failed to reasonably avoid displaying or engaging in a pattern or practice of displaying quotations that locked or crossed a protected quotation, or any manual quotations that locked or crossed a quotation previously disseminated pursuant to an effective national market system plan.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined a total of $135,000, of which $77,500 is payable to the exchange. In addition, the firm agreed to revise its written supervisory procedures with respect to the areas outlined in the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1481},{"d":"2018-03-08","di":"2018-03-08","dr":"2018-03-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist;censure;degorgement;prejudgment interest","st":"Final","fine":1250000.0,"dk":"3-18392","al":"On March 8, 2018, the U.S. Securities and Exchange Commission (\"SEC\") issued an administrative order against Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") finding that Merrill lynch, from January 24, 2011 to August 18, 2011, violated the registration provisions of the federal securities laws by effecting unregistered sales of almost 3 million shares of longtop financial technologies limited's securities for a customer that maintained an account at a Merrill lynch branch office in Singapore. In 2013, Merrill lynch sold its Singapore branch office and the branch employees handling the account ceased their association with Merrill lynch. Merrill lynch consented to the issuance of the administrative order without admitting or denying the SEC's findings. The SEC found that, although in advance of the sales Merrill lynch reviewed longtop's public filings, gathered information from the Singapore branch concerning longtop and the account, had discussions with longtop's U.S.-based outside counsel who was not on a list of known securities law offenders, and consulted with in-house counsel, Merrill lynch did not perform a reasonable inquiry into the facts surrounding the proposed sales to determine if there was an available exemption from registration under the Securities Act of 1933 (\"Securities Act\"), and as a result Merrill lynch was not entitled to rely on the brokers' transaction exemption in section 4(a)(4) of the Securities Act. The SEC found that the sales through the account, generated approximately $38 million in proceeds for the benefit of longtop and its affiliates. Merrill lynch wired the proceeds from the nominee account to a Hong Kong bank account in the name of a different entity that was controlled by longtop management. Unknown to Merrill lynch, the majority of the proceeds were then transferred from the Hong Kong bank account to one or more affiliates of longtop. Merrill lynch received over $127,000 in commissions and fees during the relevant period. As a result, the SEC found that Merrill lynch willfully violated sections 5(a) and 5(c) of the Securities Act.","res":"Other","sm":"Merrill lynch submitted an offer of settlement, which the SEC determined to accept. Solely for the purposes of this proceeding and any other proceedings brought by or on behalf of the SEC, or to which the SEC is a party, and without admitting or denying the findings in the administrative order, except as to the SEC's jurisdiction over it and the subject matter of the proceeding, which were admitted, Merrill lynch consented to the entry of the administrative order, which contained a finding that Merrill lynch willfully violated sections 5(a)(and 5(c) of the Securities Act. The SEC ordered that Merrill lynch is censured and shall cease and desist from committing or causing any violations and any future violations of sections 5(a) and 5(c) of the Securities Act. Merrill lynch was also ordered to pay disgorgement of $127,545 along with prejudgment interest of $27,340 and pay a civil money penalty in the amount of $1.25 million.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1482},{"d":"2018-03-07","di":"2018-02-06","dr":"2018-03-07","k":"Regulatory Action","rg":"Other","reg":"Bats BZX Exchange, Inc.","st":"Final","fine":5700.0,"dk":"20160499339-02","al":"Alleged non-compliance with certain professional customer and exchange rules regarding the definitional requirements of professional customer orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $125,000 of which $5,700.00 was paid to BZX and the remainder of the fine total paid to the CBOE exchange, inc. and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain professional customer and exchange rules regarding the definitional requirements of professional customer orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1483},{"d":"2018-03-07","di":"2018-03-07","dr":"2018-03-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Byx Exchange, Inc.","st":"Final","fine":79700.0,"dk":"2013036836005","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $79,700 was paid to CBOE Byx Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm was censured and fined a total of $1,575,000 of which $79,700 was paid to CBOE Byx Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1484},{"d":"2018-03-07","di":"2018-03-07","dr":"2018-03-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE BZX Exchange, Inc.","st":"Final","fine":169100.0,"dk":"2013036836006","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $169,100 was paid to CBOE BZX Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm was censured and fined a total of $1,575,000 of which $169,100 was paid to CBOE byx exchange, inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1485},{"d":"2018-03-07","di":"2018-03-07","dr":"2018-03-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edgx Exchange, Inc.","st":"Final","fine":67000.0,"dk":"2013036836008","al":"Without admitting or denying the findings, the firm consents to the sactions and to the entry of the findings that it was non- compliant with with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $67,000 was paid to CBOE Edgx Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm was censured and fined a total of $1,575,000 of which $67,000 was paid to CBOE Edgx Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1486},{"d":"2018-03-07","di":"2018-03-07","dr":"2018-03-07","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Edga Exchange, Inc.","st":"Final","fine":124300.0,"dk":"2013036836007","al":"Without admitting or denying the findings, the firm consents to the sactions and to the entry of the findings that it was non- compliant with with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"He firm was censured and fined a total of $1,575,000 of which $124,300 was paid to CBOE Edga Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm was censured and fined a total of $1,575,000 of which $124,300 was paid to CBOE Edga Exchange, Inc. and undertakes to address its deficiencies and revise its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1487},{"d":"2018-03-06","di":"2018-03-06","dr":"2018-03-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"2016049858101","al":"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 3,182 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 due to a programming error in which the firm was using outdated quotation price and display matrices.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $7,500.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1488},{"d":"2018-03-05","di":"2016-03-22","dr":"2018-03-05","k":"Regulatory Action","rg":"Other","reg":"Portuguese Securities Market Commission","san":"Other","os":"Caution","st":"Final","dk":"ADMINISTRATIVE OFFENSE PROCEEDINGS NO. 20/2014","al":"The Portuguese Securities Market Commission (CMVM) alleged that the firm did not notify the CMVM or the issuing company of changes to certain qualifying holdings within the required time period, in violation of article 16 of the Portuguese securities code","res":"Decision","sd":"Caution","sm":"On March 5, 2018, Morgan Stanley became subject to a decision by the Portuguese Securities Market Commission (CMVM) in which the CMVM issued the firm a caution for the willful breach of (I) the duty to notify the CMVM of its qualifying holding, and (II) the duty to notify the issuing company of its qualifying holding. The CMVM also reminded the firm that it is under strict legal obligations that must be complied with. The CMVM specifically noted that, in qualifying the firm's conduct as willful misconduct, this does not mean that the firm (specifically) acted with the goal of breaching the legal norm in question.","ab":"Morgan Stanley","firms":[104859,105922,110353,126896,134366,149777,158959,309263],"id":1489},{"d":"2018-02-23","di":"2017-05-19","dr":"2018-02-23","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service","san":"Other","os":"Warning","st":"Final","dk":"IT & FINTECH STRATEGY DEPARTMENT (CASE NUMBER NOT AVAILABLE)","al":"Financial Supervisory Service alleged that Samsung Life Insurance improperly used personal information of customers whose insurance policies were already terminated","res":"Decision","sd":"Financial Supervisory Service issued a warning against Samsung Life Insurance and reprimand and warning against 2 executives","sm":"The Financial Supervisory Service issued a notice of its decision, finding Samsung Life Insurance liable for the allegation listed in our answer to question 7. As a result, financial service issued a warning.","ab":"Samsung Life Insurance","firms":[158319],"id":1490},{"d":"2018-02-23","di":"2018-02-23","dr":"2018-02-23","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service","san":"Other","os":"Warning","st":"Final","dk":"NOT AVAILABLE","al":"When Samsung Life Insurance could not create a request for wire transfer of monthly insurance premium due to system failure and attempted to create a request as of the day before, Samsung Life Insurance used bank account numbers and other personal information of customers whose insurance contracts expired on the same day without those customers' consent in violation of credit information use and protection act. (After Samsung Life Insurance learned that it received insurance premium from customers whose insurance contracts already expired, it notified them and refunded the premium with interest)","res":"Decision","sd":"Financial Supervisory Service issued warnings against Samsung Life Insurance, reprimand against one executive, and warning against one executive","sm":"On 2/23/2018, Financial Supervisory Service issued a notice of its decision, finding Samsung Life Insurance liable for the allegations listed in our answer to question 7. As a result, Financial Supervisory Service issued warnings against Samsung Life Insurance, reprimand against one executive, and warning against one executive","ab":"Samsung Life Insurance","firms":[158319],"id":1491},{"d":"2018-02-23","di":"2018-02-23","dr":"2018-02-23","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"CME 17-0658-BC","al":"The action involved an alleged violation of Chicago Mercantile Exchange (\"CME\") rule 538.c in connection with the execution of certain exchange for related position (\"EFRP\") transactions.","res":"Settled","sd":"A $40,000 fine was paid by the adviser promptly after the settlement was agreed to. No portion of the fine was waived.","sm":"Pursuant to an offer of settlement in which the adviser neither admitted nor denied the alleged rule violation upon which the penalty is based, on February 21, 2018, a PANEL of the CME business conduct committee (\"PANEL\") found that between January 2016 and June 2016 the adviser executed certain efrp transactions in e-mini Nasdaq 100 futures and e-mini s&p 500 futures contracts that were contingent on other transactions that were immediately offset without incurring material market risk. The PANEL found that the adviser thereby violated CME rule 538.c. The PANEL's decision became effective February 23, 2018. In accordance with the settlement, the PANEL ordered that the adviser pay a fine in the amount of $40,000, which the adviser paid promptly after the settlement. No information Filed","ab":"Stone Ridge Asset Management LLC","self":true,"firms":[165598],"id":1492},{"d":"2018-02-21","di":"2018-02-21","k":"Regulatory Action","dk":"18-011-S","ab":"Barber, Lawrence, Kimball","firms":[7691],"id":1493},{"d":"2018-02-21","di":"2018-02-21","dr":"2018-02-21","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":80000.0,"dk":"DOCKET NO. 18-011-5","al":"The Vermont department of financial regulation alleged that Merrill Lynch, Pierce, Fenner & Smith incorported (\"Merrill lynch\") failed to supervise a registered representative subject to its supervision with respect to the representative's violations of Vermont securities rules regarding a customer's investment advisory program, which included improperly effecting transactions without authority, exercising discretionary power without first obtaining authority, effecting an unsuitable sale, failing to segregate securities held in safekeeping, by requesting and receiving customer account passwords, and by accessing customer accounts with the passwords.","res":"Consent","sm":"Merrill lynch entered into a stipulation and consent agreement with the Vermont department of financial regulation in which the department of regulation which stated that Merrill lynch failed to supervise within the meaning of 9 V.S.A. Para. S412(d)(9) by (a) failing to escalate for further supervisory review a registered representative's email requesting his client's Merrill lynch password and (b) failing to supervise reasonably in connection with the registered representative's unauthorized sale of designated securities. The stipulation and consent agreement also stated that: (1) it is not and shall not be deemed to be, a final order of any law or regulation that prohibits fraudulent, manipulative or deceptive conduct, and (2) it is not intended to subject Merrill lynch or any of its affiliates to any disqualification under Vermont law, or rules or regulations thereunder, federal securities laws, or rules or regulations thereunder, the rules and regulations of self-regulatory organizations or various states or U.S. territories, including any disqualification from relying upon the registration exemptions or safe harbor provisions to which Merrill lynch, or any of its affiliates may be subject. The stipulation and consent agreement also provided that nothing in the stipulation and consent agreement is intended in any way to subject Merrill lynch or any of its affiliates to any statutory disqualification by FINRA in any way.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1494},{"d":"2018-02-15","di":"2018-02-15","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","st":"Final","fine":59700.0,"dk":"2013036836013","al":"Alleged non-compliance with a certain system of risk management controls and exchange rules consisting of definitional requirements and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $1,575,000 of which $59,700 was paid to NYSE American LLC (EQUITIES) and undertakes to address its deficiencies and revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm accepted the offer of settlement and consents to pay a fine total of $1,575,000, of which $59,700 was paid to NYSE American LLC (EQUITIES).","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1495},{"d":"2018-02-13","di":"2018-02-13","dr":"2018-02-13","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cost of the proceeding","st":"Final","fine":2466.2,"dk":"CASE REF. 2018/03","al":"The firm exceeded the order to trade ratio mentioned in section 17b of the Eurex Deutschland and Eurex zurich exchange rules by 0.2873 as per the least trading day of November 2017.","res":"Decision","sm":"The firm was issued an administrative fine in the amount of 2,000 euro (approximately $2,466.20) and was required to bear the cost of the proceeding in the amount of 2,000 euro (approximately $2,466.20). The sanctions committee noted that there was no financial loss to other market participants nor any loss in trust for the stakeholders involved, and that the firm did not gain any financial advantage.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1496},{"d":"2018-02-12","di":"2018-02-12","dr":"2018-02-12","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"COMEX-RSRH-18-4986","al":"For trade date January 16, 2018, JPMS submitted a transfer which resulted in reducing open interest by 17 contracts, or 15.45%, in the January 2018 comex silver (SI) futures contract in violation of comex rule 854 (\"concurrent long and short positions\").","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1497},{"d":"2018-02-12","di":"2018-02-12","dr":"2018-02-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervision Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2480.0,"dk":"17-12596","al":"According to requirements imposed by the Swedish Financial Supervision Authority (\"Swedish fi\") related to the european securities markets authority EU regulation on short selling, The Mangrove Partners master fund, LTD. (the \"cayman master\") reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 on the trading day following passage of the reporting threshold. Inadvertently, and due to an administrative oversight, the cayman master reported its net short position at 16:16 on the trading day following the passage of the reporting threshold and updated such notification two days following.","res":"Order","sd":"$2480","sm":"According to requirements imposed by the Swedish fi the cayman master reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 (9:30 am est) on the trading day following passage of the reporting threshold (I.E., May 24, 2017). Inadvertently, and due to an administrative oversight, the cayman master, which is advised by New York-based Mangrove partners, reported its net short position at 16:16 (10:16 am est) on May 24, 2017. Mangrove partners updated such notification two days following (May 26, 2017) per the request of the Swedish fi to not round the percentage of shares short. As a result of the cayman master's failure to report its short position in a timely manner, the Swedish fi assessed a sek $20,000 (approximately $2,480.00 usd) penalty fee for reporting one day late. As a result of the foregoing, Mangrove partners has implemented additional controls to ensure timely reporting to the Swedish fi going forward.","ab":"The Mangrove Partners","firms":[162296],"id":1498},{"d":"2018-02-12","di":"2018-02-12","dr":"2018-02-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervision Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":620.0,"dk":"17-12598","al":"According to requirements imposed by the Swedish Financial Supervision Authority (\"Swedish fi\") related to the european securities markets authority EU regulation on short selling, The Mangrove Partners master fund, LTD. (the \"cayman master\") reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 on the trading day following passage of the reporting threshold. Inadvertently, and due to an administrative oversight, the cayman master reported its net short position at 17:46 on the trading day following the passage of the reporting threshold.","res":"Order","sd":"$620","sm":"According to requirements imposed by the Swedish fi the cayman master reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 (9:30 am est) on the trading day following passage of the reporting threshold (I.E., May 22, 2017). Inadvertently, and due to an administrative oversight, the cayman master, which is advised by New York-based Mangrove partners, reported its net short position at 17:46 (11:46 am est) on May 22, 2017. As a result of the cayman master's failure to report its short position in a timely manner, the Swedish fi assessed a sek $5,000 (approximately $620.00 usd) penalty fee, which had been reduced from the guidelines normally used to assess such penalties, given that the Swedish fi found the infringement to be minor. As a result of the foregoing, Mangrove partners has implemented additional controls to ensure timely reporting to the Swedish fi going forward.","ab":"The Mangrove Partners","firms":[162296],"id":1499},{"d":"2018-02-12","di":"2018-02-12","dr":"2018-02-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervision Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1240.0,"dk":"17-12680","al":"According to requirements imposed by the Swedish Financial Supervision Authority (\"Swedish fi\") related to the european securities markets authority EU regulation on short selling, The Mangrove Partners master fund, LTD. (the \"cayman master\") reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 on the trading day following passage of the reporting threshold. Inadvertently, and due to an administrative oversight, the cayman master reported its net short position at 19:41 on the trading day following the passage of the reporting threshold.","res":"Order","sd":"$1240","sm":"According to requirements imposed by the Swedish fi the cayman master reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 (9:30 am est) on the trading day following passage of the reporting threshold (I.E., July 17, 2017). Inadvertently, and due to an administrative oversight, the cayman master, which is advised by New York-based Mangrove partners, reported its net short position at 19:41 (1:41 PM est) on July 17, 2017. As a result of the cayman master's failure to report its short position in a timely manner, the Swedish fi assessed a sek $10,000 (approximately $1,240.00 usd) penalty fee, which had been reduced from the guidelines normally used to assess such penalties, given that the Swedish fi found the infringement to be minor. As a result of the foregoing, Mangrove partners has implemented additional controls to ensure timely reporting to the Swedish fi going forward.","ab":"The Mangrove Partners","firms":[162296],"id":1500},{"d":"2018-02-12","di":"2018-02-12","dr":"2018-02-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervision Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1624.0,"dk":"17-20165","al":"According to requirements imposed by the Swedish Financial Supervision Authority (\"Swedish fi\") related to the european securities markets authority EU regulation on short selling, The Mangrove Partners master fund, LTD. (the \"cayman master\") reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 on the trading day following passage of the reporting threshold. Inadvertently, and due to an administrative oversight, the cayman master reported its net short positions at 18:32 and 21:09 on the trading days following the passage of the reporting thresholds.","res":"Order","sd":"$1624","sm":"According to requirements imposed by the Swedish fi the cayman master reported its net short position in the issued share capital of a Swedish-listed company. Pursuant to applicable requirements, notification of such net short positions must be received no later than 15:30 (9:30 am est) on the trading day following passage of the reporting threshold (I.E., April 13, 2017 and June 5, 2017, respectively). Inadvertently, and due to an administrative oversight, the cayman master, which is advised by New York-based Mangrove partners, reported its net short positions at 18:32 (12:32 PM est) on April 13, 2017 and 21:09 (3:09 PM est) on June 5, 2017 respectively. As a result of the cayman master's failure to report its short position in a timely manner, the Swedish fi assessed a sek $13,100 (approximately $1,624.00 usd) penalty fee, which had been reduced from the guidelines normally used to assess such penalties, given that the cayman master itself reported such infringement to the Swedish fi and as such the Swedish fi found the infringement to be minor. As a result of the foregoing, Mangrove partners has implemented additional controls to ensure timely reporting to the Swedish fi going forward.","ab":"The Mangrove Partners","firms":[162296],"id":1501},{"d":"2018-02-09","di":"2018-02-09","dr":"2018-02-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":450000.0,"dk":"2014041142501","al":"Alleged violation of rule 200(f), NASD rules 3010, 2010 and 2110 in that Citigroup Global Markets Inc. did not include two accounts engaged in proprietary transaction in any independent trading aggregation unit and the firm's supervisory system was not reasonably designed to ensure that all firm accounts conducting proprietary business were included in an aggregation unit during the period November 21, 2008 through December 3, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $450,000, and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1502},{"d":"2018-02-06","di":"2018-02-06","dr":"2018-02-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":375000.0,"dk":"2015045703001","al":"From January 2010 through at least December 2016, FINRA alleged that LPL Financial failed to reasonably supervise the sale of certain brokered certificates of deposit (\"brokered CDS\"), which the firm characterized as non-security CDS because they were FDIC insured instruments. The firm allegedly failed to ensure that (1) its registered representatives were trained on all material risks and features of brokered CDS and (2) adequately disclose all material risks and features of brokered CDS to customers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"As a result of the firm's alleged inadequate supervisory system, five customers of one of the firm's registered representatives suffered losses of approximately $75,000. The firm subsequently remediated these customers' losses.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1503},{"d":"2018-02-05","di":"2016-05-27","dr":"2018-02-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500000.0,"dk":"2012033105901","al":"The firm was named a respondent in a FINRA complaint alleging that it willfully violated section 15(c) of the Exchange Act of 1934, Exchange Act rule 15C3-3(b) (1) thereunder, and FINRA rule 2010 by creating or increasing deficits in the number of securities required to be in the firm's possession or control. The complaint alleges that the firm willfully violated section 15(c) of the Exchange Act of 1934, Exchange Act rule 15C3-3(e) thereunder, and FINRA rule 2010 by failing to accurately calculate its customer reserve formula and adequately fund its customer reserve account in accordance with the customer protection rule, which resulted in hindsight deficiencies. The complaint also alleges that the firm failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with both the possession and control requirement and the customer reserve requirements of the customer protection rule.","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured, fined $1.5 million and required to submit an undertaking pursuant to which the firm's president, or his successor-in-interest, shall within 30 days of the completion of the firm's implementation of the recommendations received from the independent consultant to be retained by the firm in connection with the order instituting administrative and cease-and-desist proceedings, pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 and section 203(e) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and- desist order, entered concurrently herewith with the U.S. Securities and Exchange Commission, certify in writing to FINRA that, as of the date of the certification, the firm has in place policies, systems and procedures to address and correct the violations described in this offer of settlement.","sm":"Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that in 30 separate instances, the firm created and/or increased deficits in its segregation requirement through deliveries or returns of securities. The findings also stated that on 14 occasions the firm improperly calculated its customer reserve formula, which, on eight occasions, resulted in hindsight deficiencies between $945,000 and $77 million. The findings also included that the firm failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with both the possession or control requirement and the customer reserve account requirement of the customer protection rule. Under the terms of the offer, the firm has also consented, without admitting or denying the allegations and to the entry of findings and violations arising out of examinations conducted by FINRA in 2014, 2015 and 2016, as described below, and to the imposition of the sanctions contained herein. The additional findings are as follows: from November 2015 through March 2016, the firm held multiple positions in certificates of deposit (CDS) issued by major financial institutions for which there was no \"ready market,\" for over five business days, but failed to deduct the value of each position exceeding 30% of the firm's tentative net capital. The firm created and maintained inaccurate books and records that inaccurately reported the amounts the firm was required to maintain in its customer reserve account. Additionally, inaccurately reported its net capital.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1504},{"d":"2018-02-05","di":"2018-02-05","dr":"2018-02-05","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000000.0,"dk":"3-18357","al":"SEC admin release 34-82630, ia release 40-4852 / February 5, 2018: the Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to sections 15(b), and 21c of the Securities Exchange Act of 1934 (\"Exchange Act\"), and section 203(e) of the Investment Advisers Act of 1940 (\"Advisers Act\") against Wedbush Securities Inc. (\"Wedbush\" or \"respondent\"). The commission finds that these proceedings involve Wedbush's violations of Exchange Act rule 15C3-3, known as the customer protection rule (\"rule\"). The customer protection rule requires broker-dealers to safeguard both the cash and securities of their customers so that customer assets can be promptly returned if the firm fails. In order to do so, a broker-dealer is required to periodically (daily, weekly, or monthly depending on the firm) calculate the net amount of cash it owes its customers, and deposit that amount into a segregated bank account known as the \"reserve account.\" Between September 2014 and January 2015, Wedbush's weekly rule 15C3-3 calculations to determine the net amount that should have been deposited into the reserve account included a significant error, resulting in weekly reserve account deficiencies ranging from approximately $10 million to $193 million out of a total reserve account requirement that ranged between $1.5 billion and $1.7 billion. When the error was uncovered, Wedbush was required to immediately deposit an additional $133 million into its reserve account, which created a significant liquidity challenge for Wedbush. Wedbush's failure to properly fund its reserve account also caused it to violate section 17(a) (1) of the Exchange Act and rule 17A-5(a) thereunder, because it included inaccurate information in its financial and operational combined uniform single reports (\"focus reports\"). As a result of the conduct described, Wedbush willfully violated section 15(c)(3) of the Exchange Act and rule 15C3-3 thereunder, which require carrying broker-dealers to maintain a reserve of funds or qualified securities in an account at a bank that is at least equal in value to the net cash owed to customers. Wedbush also willfully violated section 17(a)(1) of the Exchange Act and rule 17A-5(a) thereunder by filing focus reports that contained incorrect information on the reserve formula because of the calculation error.","res":"Order","sd":"Without admitting or denying the accusations Wedbush is censured and ordered to cease and desist from committing or causing any violations and any future violations of sections 15(c)(3) and 17(a)(1) of the Exchange Act, and rules 15C3-3 and 17A-5(a) thereunder. Wedbush is ordered to pay disgorgement of $275,851 along with prejudgment interest of $28,346 and ordered to pay a civil money penalty in the amount of $1,000,000 plus post-order interest to the Securities and Exchange Commission. Wedbush is also ordered to comply with certain undertakings.","sm":"Without admitting or denying the accusations respondent has submitted an offer of settlement (the \"offer\") which the commission has determined to accept. Wedbush willfully violated sections 15(c)(3) and 17(a)(1) of the Exchange Act and rules 15C3-3 and 17A-5(a) thereunder. It is ordered that Wedbush is censured and shall cease and desist from committing or causing any violations and any future violations of sections 15(c)(3) and 17(a)(1) of the Exchange Act, and rules 15C3-3 and 17A-5(a) thereunder. Wedbush is ordered to pay disgorgement of $275,851 along with prejudgment interest of $28,346 and ordered to pay a civil money penalty in the amount of $1,000,000 plus post-order interest to the Securities and Exchange Commission. Wedbush is also ordered to comply with certain undertakings.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1505},{"d":"2018-02-05","di":"2018-01-08","dr":"2018-02-05","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Exchange, Inc.","st":"Final","fine":119300.0,"dk":"18-0001/20160499339","al":"Alleged non-compliance with a certain professional customer and exchange rules regarding the definitional requirements of professional customer orders and related supervision.","res":"Consent","sd":"The firm was censured and fined $125,000 of which $119,300.00 was paid to CBOE Exchange, Inc. and the remainder of the fine total paid to the bats BZX exchange, inc. and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- complianct with certain professional customer and exchange rules regarding the definitional requirements of professional customer orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1506},{"d":"2018-02-02","di":"2018-02-02","dr":"2018-02-02","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Independent reviews","st":"Final","dk":"18-007-B-HC","al":"Without admitting or denying the findings, the firm consented to the order to cease and desist and to take affirmative action to take steps to ensure the bank complies with consent orders issued by the OCC and CFPB, within sixty days, submit a written plan to further enhance the effectiveness in carrying out oversight and governance of WFC, improve its oversight of senior management including an effective risk tolerance program and risk identification and escalation framework. Following the adoption fo the plans and improvements, WFC shall conduct by September 30, 2018 and independent review of the Board's improvements, enhancements to the firm's compliance and operational risk management program. WFC must conduct a second independent review into WFC's \"business-as-usual practices and operations to assess the efficacy and sustainability of the improvements. Both reviews must be conducted by third party experts with results submitted to the Federal Reserve within 30 days of completion of the reports. WFC is restricted, without prior written appoval, to take any action that would cause the average of WFC's total consolidated assets for the current and preceding quarter to exceed a specified level as described more fully in the order.","res":"Consent","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1507},{"d":"2018-02-01","di":"2018-01-30","dr":"2018-02-01","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":80000.0,"dk":"NYMEX 16-0404-BC","al":"The New York Mercantile Exchange (\"NYMEX\") alleged that (1) an automated order routing system operated by the firm misrouted an unsupported type of customer order to globex as a market order instead of rejecting the order, which caused a price spike (but did not result in a trading halt), and (2) the firm had insufficient procedures or internal controls in place to reject the unsupported customer order type. NYMEX found that the firm violated NYMEX rules 432.q and 432.w.","res":"Decision","sm":"Without admitting or denying the rule violations upon which the penalty was based, the firm agreed to pay a fine in the amount of $80,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1508},{"d":"2018-01-29","di":"2018-01-29","dr":"2018-01-29","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Cease and desist, undertakings","st":"Final","fine":30000000.0,"dk":"CFTC DOCKET NO. 18-06","al":"The CFTC alleged that Deutsche Bank AG (\"DBAG\"), by and through the acts of certain precious metals traders, manipulated and attempted to manipulate prices and engaged in spoofing in the precious metals futures markets on various occasions between February 2008 and September 2014. The CFTC alleged that these traders placed orders to buy or sell futures contracts with the intent to cancel the orders before execution, and that such orders manipulated and were intended to manipulate the prices of precious metals futures contracts. The CFTC alleged that, through the acts of one trader, DBAG manipulated the price of precious metals futures contracts and triggered customers' stop-loss orders, allowing that trader to buy precious metals futures contracts at artificially low prices or sell such contracts at artificially high prices. The CFTC also alleged that Deutsche bank securities inc. (\"DBSI\") failed to diligently supervise in connection with the above referenced conduct.","res":"Settled","sm":"On January 29, 2018, Deutsche bank, without admitting or denying the findings or conclusions therein, entered into a settlement with the CFTC. The CFTC approved the settlement in its order instituting proceedings pursuant to section 6(c) and (d) of the Commodity Exchange Act, making findings and imposing remedial sanctions, including the following terms and conditions. Deutsche bank agreed to pay a $30,000,000 civil monetary penalty, which was paid on February 2, 2018; to cease and desist from violating certain provisions of the cea and CFTC regulations related to manipulation, spoofing, and supervision; and to comply with undertakings regarding, among other things, maintaining systems and controls reasonably designed to detect spoofing activity, and maintaining training of certain Deutsche bank employees addressing spoofing, manipulation, and attempted manipulation.","ab":"Deutsche Bank AG","firms":[300838],"id":1509},{"d":"2018-01-26","di":"2018-01-26","dr":"2018-01-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":37500.0,"dk":"2014042512701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in 18 instances between April 2014 to June 2014, the firm accepted and held 12 customer orders in over-the-counter (OTC) securities, traded for its own account at prices that would have satisfied the customer orders, and failed to execute or immediately execute the customer orders 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 with respect to 16 of the 18 instances, the firm asserted the \"no-knowledge exception,\" which is codified in supplementary material .02 of FINRA rule 5320. The firm's system of internal controls (information barriers) did not meet the requirements set forth in supplementary material .02(b), because traders at one desk had the ability to view the outstanding customer orders that were accepted and held by another desk. The findings also stated that during the second quarter of 2014 and fourth quarter of 2014 through the first quarter of 2015, 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 NASD rules concerning compliance with FINRA rule 5320 and supplementary material .02 of rule 5320. The firm did not have policies or procedures that prevented its trading desks that were separated by information barriers from obtaining knowledge regarding orders or trading activity of the other desks. The firm's written supervisory procedures failed to include a supervisory review that ensured that the firm's information barriers, for which the firm relied on the \"no-knowledge exception,\" were operating appropriately and permissions that the firm's employees had to the firm's systems were granted appropriately. In addition, although the firm had a trading ahead exception report, it failed to capture any of the trading ahead instances identified. The exception report was also flawed and unreliable during the review periods. The findings also included that during the second quarter of 2014, fourth quarter of 2014 through the first quarter of 2015 and fourth quarter of 2015, the firm failed to report an information barrier identifier with its order audit trail system (OATS) submissions for 76 orders.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1510},{"d":"2018-01-26","di":"2018-01-26","dr":"2018-01-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":17500.0,"dk":"2017053250501","al":"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) 200 transactions in TRACE-eligible securitized products within the time required by FINRA rule 6730.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1511},{"d":"2018-01-25","di":"2018-01-25","k":"Regulatory Action","dk":"OBS 3121-A (AR)","ab":"Macbeth, Scott, T","firms":[7691],"id":1512},{"d":"2018-01-24","di":"2018-01-24","dr":"2018-01-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"MC 17-47","al":"During the course of a routine market conduct exam, the State of Connecticut Insurance Department (the state) found New York Life Insurance company did not timely pay long term care claims in four instances.","res":"Consent","ab":"New York Life Insurance","firms":[107717,169553,173355,309234,340676],"id":1513},{"d":"2018-01-19","di":"2018-01-19","dr":"2018-01-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":525000.0,"dk":"2014040400701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to report, or inaccurately reported, certain short interest positions in violation of FINRA rule 4560; (1) as a result of an undetected system logic error in the firm's internal short interest report that dropped certain symbols involved in recent corporate actions that resulted in mergers and an exchange of shares; (2) due to an undetected coding error on its internal short interest report that omitted certain over-the-counter (OTC) foreign securities (I.E., duly listed securities) from its short interest submission; and (3) as a result of a failure to update its internal programming logic in its master security database used to determine if a security was reportable, that caused the firm to fail to capture certain equity preferred securities involving corporate actions. The findings also stated that the firm failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with FINRA rule 4560 in violation of NASD rule 3010 (for conduct prior to December 1, 2014) and FINRA rule 3110 (for conduct on and after December 1, 2014) and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining to resolve this matter in the manner set forth herein, and in determining the appropriate monetary sanction, FINRA took into consideration the following: (I) that the firm self-reported a significant number of the violations at issue after conducting an internal investigation; (II) provided assistance to FINRA in assessing the number and scope of violations; and (III) promptly took remedial action to correct the deficiencies that led to the violative activity.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1514},{"d":"2018-01-12","di":"2018-01-12","dr":"2018-01-12","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14000000.0,"dk":"17-047-CMP-HC; 17-047-CMP-SM","al":"The Goldman Sachs group, inc. (\"GS group\") and Goldman Sachs Bank USA (\"GS bank\") entered into an order of assessment of a civil money penalty issued upon consent pursuant to the federal deposit insurance act, as amended, with the Board of Governors of the Federal Reserve System (the \"Federal Reserve\") on January 12, 2018 (the \"consent assessment\"). The consent assessment related to allegations by the Federal Reserve that, prior to September 1, 2011, GS group and GS bank had engaged in deficient practices in residential mortgage loan servicing and foreclosure processing involving LITTON loan servicing LP (\"LITTON\"), a former subsidiary. Without admitting or denying the allegations, GS group and GS bank had previously entered into a consent order with the Federal Reserve relating to the same alleged conduct on September 1, 2011, as amended on February 28, 2013 (the \"amended consent\", which is reported on a separate DRP).","res":"Consent","sm":"Without admitting or denying the allegations in the amended consent, GS group, GS bank and the Federal Reserve entered into the consent assessment, which releases and discharges GS group, GS bank, and their affiliates, successors, and assigns from all potential liability that has been or might have been asserted by the Federal Reserve based on the conduct that is the subject of consent assessment or the amended consent, and assesses GS group and GS bank a civil money penalty in the amount of $14,000,000, which was paid to the Federal Reserve by submission of a wire on January 12, 2018.","ab":"Goldman Sachs Bank USA","firms":[361,283221,286067],"id":1515},{"d":"2018-01-12","di":"2018-01-12","dr":"2018-01-12","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"17-045-CMP-SM","al":"The Board of Governors of the Federal Reserve System (the \"Federal Reserve\") alleged that Goldman Sachs Bank USA (\"GS bank\"), engaged in a pattern or practice of violations under section 102(f)(2) of the national flood insurance act, 42 U.S.C. 4012a(f).","res":"Consent","sm":"On January 12, 2018, prior to the taking of any testimony or adjudication of or finding on any issue of fact or law, and solely for the purpose of settlement of the matter without a formal proceeding being filed and without the necessity for protracted or extended hearings or testimony, GS bank and the Federal Reserve entered into an order of assessment of a civil money penalty pursuant to the national flood insurance act, as amended, which assesses GS bank a civil money penalty in the amount of $90,000, which was paid to the Federal Reserve by submission of a check on January 12, 2018.","ab":"Goldman Sachs Bank USA","firms":[361],"id":1516},{"d":"2018-01-12","di":"2017-03-30","dr":"2018-01-12","k":"Civil Judicial Action","san":"Disgorgement","os":"Fines","st":"Final","fine":209090.91,"al":"Violation of fiduciary duties under ERISA and engaging in prohibited transactions","res":"Settled","sd":"The firm agreed to pay a penalty of $209,090.91 to the Department of Labor. The firm agreed to pay restitution to the plans a total sum of $2,090,909.09. The firm also agreed to offer certain individuals in the plan the right to sell their shares in Wedbush inc at a price of $14.","ab":"Wedbush, Edward William","firms":[877],"id":1517},{"d":"2018-01-08","di":"2018-01-08","dr":"2018-01-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"2016048755401","al":"FINRA found that, during the period of October 1, 2015 through December 31, 2015, JPMS failed to report 85 transactions to the trade reporting and compliance engine within 15 minutes of the time of execution in violation of FINRA rule 6730(a) and that the conduct constituted a pattern and practice of late reporting in violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1518},{"d":"2017-12-29","di":"2017-11-07","dr":"2017-12-29","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and disgorgement","st":"Final","fine":20000.0,"dk":"11-0052/20160501553","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to enforce written supervisory procedures, designed to prevent and detect violations of Exchange Act rule 14E-4 relating to its tender of 32,567 shares into the baxter international (\"BAX\") partial tender offer on May 18, 2016 in excess of its net long position.","res":"Stipulation and Consent","sm":"A summary of this action is set forth in the letter of consent, which is publicly available via the CBOE.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1519},{"d":"2017-12-28","dr":"2017-12-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":5500000.0,"dk":"2016048931101","al":"Alleged violation of FINRA rules 2010, 2210(d)(1), and 3110(a) and (b) and NASD rules 2210(d)(1) and 3010(a) and (b) in that Citigroup Global Markets Inc. displayed to its brokers, customers, and supervisors inaccurate research ratings for certain equity securities. The firm's failure to display accurate research ratings caused its brokers to solicit certain transactions inconsistent with the firm's actual ratings and brokers solicited transactions that violated the portfolio guidelines of certain firm-managed portfolios. The firm also failed to timely correct the inaccurately displayed ratings and failed to conduct testing reasonably designed to verify the accuracy of research ratings data that it used and distributed from February 2011 through December 2015.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $5,500,000 and an undertaking to pay compensation totaling at least $6 million to customers","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1520},{"d":"2017-12-27","di":"2017-12-27","dr":"2017-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2800000.0,"dk":"2015047091401","al":"Without admitting or denying the findings, the firm, as surviving entity from the merger of JPMorgan clearing corp (\"JPMCC\"), consented to the sanctions and to the entry of findings that during the relevant period from March 2008 through June 2016 JPMCC failed to promptly obtain and hereafter maintain physical possession or control of its customers' fully-paid and excess margin securities, in violation of section 15 of the Securities Exchange Act of 1934 (\"SEA\") and rule 15C3-3(b) promulgated thereunder. Due to the lack of reasonable supervision, the numerous design flaws in the possession or control systems went undetected and led to global segregation deficiencies during the relevant period, in violation of NASD rule 3010 (for the time period prior to December 1, 2014) and FINRA rule 311o(a) (for the time period on and after December 1, 2014). This conduct also constitutes a violation of NASD rule 2110 (for the time period prior to December 15, 2008) and FINRA rule 2010 (for the time period on and after December 15, 2008).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1521},{"d":"2017-12-27","di":"2017-12-27","dr":"2017-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"$115,000.00 fine","st":"Final","fine":115000.0,"dk":"2016051515201","al":"It was alleged that during the review period Davenport did not establish a system reasonably designed to fully comply with FINRA rule 3110, 2010 (NASD rule 3010 for conduct prior to December 1, 2014) related to supervision of consolidated reports; and it was alleged that Davenport did not fully comply with section 15(c)(3) of the SEC act of 1934 and exchange rule act 15C3-5, FINRA rule 2010 and MSRB rule G-27 related to automated controls for alternative trading systems for municipal securities transactions","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the allegations or findings, Davenport, on December 27, 2017 executed a letter of acceptance, waiver and consent and paid the stated fine.","ab":"Davenport & Company LLC","self":true,"firms":[1588],"id":1522},{"d":"2017-12-21","di":"2017-12-21","dr":"2017-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":13000000.0,"dk":"2012035224301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that at various relevant times, the firm's implementation of certain systems and procedures that comprise its AML program related to retail brokerage accounts suffered from numerous deficiencies. The findings stated that the firm used an automated monitoring system called mantas as a central part of its AML program to monitor for potentially suspicious activity in firm brokerage accounts. In approximately October 2010, the firm connected mantas to a company's, that the firm was a subsidiary of, enterprise-wide, proprietary system called \"event processor.\" Thereafter, mantas generated events related to potentially suspicious activities and fed these events into event processor, and event processor grouped mantas events with other events generated by other monitoring systems into \"event groups.\" Each event group was scored based on the AML risk posed by the events or customer types identified; if the total score for an event group reached a certain risk-based threshold, the firm opened an investigation of the activity. For a four-month period, the firm did not investigate suspicious activity detected only by mantas. By 2011, the firm believed that system was producing too many \"false positives\" and determined to change how the system generated and scored mantas events and investigated potentially suspicious activity. From September 2011 until February 2012, the firm decided to not investigate event groups generated only from mantas events while it implemented the changes. The firm also decided not to review hundreds of mantas alerts that had been generated by the automated surveillance system. As a result of these decisions, the firm failed to investigate 1,015 instances of potentially suspicious activity at that time and then only after the investigation that led to this settlement had begun. The findings also stated that how the firm scored certain events in its automated surveillance system minimized potentially suspicious activity or prevented such activity from being reviewed. For example, the firm determined to score multiple occurrences of potentially suspicious money movements involving high risk counterparties and entities once. Until 2015, it did not link related accounts for some of the firm's highest risk customers and did not consistently identify or monitor customers in certain high risk jurisdictions or senior foreign political figures who were opening or conducting transactions through firm accounts. The findings also included that the firm excluded millions of accounts from its automated monitoring system and therefore failed adequately to monitor the accounts for potentially suspicious activity. These accounts included retirement accounts, certain securities-based loan accounts and the accounts pledged to them, and certain managed accounts whose investments were not controlled by the beneficial owner. As a result of these deficiencies, the firm failed to have systems and procedures reasonably designed to monitor for, detect, and report suspicious activity. FINRA found that the firm failed to implement adequate systems and procedures as part of its AML program and as a result it failed to detect and investigate potentially suspicious activity. Due in large part to the deficiencies in the operation of the AML monitoring systems for retail brokerage accounts, the firm failed to detect or investigate certain potentially suspicious activity in retail brokerage accounts maintained for non-resident aliens at \"international\" and non-","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $13,000,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1523},{"d":"2017-12-21","di":"2017-12-21","dr":"2017-12-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":13000000.0,"dk":"3-18318","al":"SEC admin release 34-82382; ia release 4831, December 21, 2017: the Securities and Exchange Commission (commission) deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to sections 15(b), and 21c of the Securities Exchange Act of 1934 (Exchange Act) and section 203(e) of the Investment Advisers Act of 1940 (Advisers Act) against the firm. The firm, in addition to offering its customers the ability to buy and sell securities, offered its customers other services in brokerage accounts, such as atm cash deposits, wires, journal-entry transfers, check writing, atm withdrawals, cash advances, and ach transfers. By offering these additional services, the firm was susceptible to risks of money laundering and other illicit financial activity associated with these services. During the relevant period, the firm primarily used a system called \"mantas\" for the automated monitoring of retail brokerage accounts to detect potential money laundering activity related to money movements. Mantas alerted on transactions that fit within the parameters of specific scenarios selected by the firm. The firm had other methods of detecting suspicious movements of funds in accounts, but those methods were primarily manual, or only alerted on certain types of activity. The firm also used a separate automated surveillance system to conduct trade surveillance and referred to the alerts produced by its anti-money laundering (AML) detection channels as \"events.\" The firm also used a system called \"event processor,\" or \"ep,\" which grouped mantas events and events produced by other firm detection channels and assigned points to the event groups. From 2006 through May 2015, the firm did not apply its mantas automated monitoring to certain accounts. From about September 2011 through January 2012, the firm did not investigate mantas events that were not grouped with an event from one of the other detection channels, such as an employee referral, a government subpoena, or an event related to a wire transfer or atm transaction that had been routed through a consumer bank before being debited or credited to a firm customer's retail brokerage account. Ep used a number of systems and techniques to group events arising from related retail brokerage accounts. However, ep inadvertently did not link related accounts that involved customers who had both U.S. dollar-denominated and foreign currency-denominated accounts. Accordingly, certain event groups did not meet the risk-based threshold and become an investigation for further review as rapidly as they otherwise would have, if at all. The did not have adequate policies and procedures for filing what were commonly known as \"continuing activity\" or \"ongoing activity\" suspicious activity reports (SARS). The firm had AML policies and procedures that were not reasonably designed to account for the additional risk associated with the additional services offered by certain of its retail brokerage accounts. Once an AML case was opened, the platform used by the firm's AML investigators during part of the relevant period did not provide sufficient visibility into transactions occurring in an account, causing the investigators sometimes unduly to limit their review to the specific events that triggered the event and not to review the account more broadly to determine whether the risk associated with that event warranted additional investigation or reporting. Because of the deficiencies in its AML policies and procedures the firm failed to adequately monitor for, detect,","res":"Order","sm":"In anticipation of the institution of these proceedings, 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 herein, except as to the commission's jurisdiction over him and the subject matter of these proceedings, which are admitted, the firm consents to the entry of this order instituting administrative and cease-and-desist proceedings, pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934, and section 203(e) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order (order). By failing to file sars with respect to certain of its customers' activity as described above, the firm willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder. In view of the foregoing, the commission deems it appropriate, in the public interest to impose the sanctions agreed to in the firm's offer. Accordingly, pursuant to sections 15(b) and 21c of the Exchange Act and section 203(f) of the Advisers Act, it is hereby ordered that the firm cease and desist from committing or causing any violations and any future violations of Exchange Act section 17(a) or rule 17A-8 promulgated thereunder; the firm be, and hereby is censured; and shall, within 14 days of the entry of this order, pay a civil money penalty in the amount of $13,000,000 to the Securities and Exchange Commission.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1524},{"d":"2017-12-21","di":"2017-12-17","dr":"2017-12-21","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois, Illinois Securities Department","san":"Other","os":"Notice of hearing","st":"Final","dk":"1500252","al":"Without admitting or denying the findings, the firm consented to the sanctions and the entry of findings that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that the firm included the financial advisory firm's money manager strategies in certain of its externally managed separately managed account programs, but the firm did not utilize inaccurate historical performance data in connection with its decision to onboard the money manager strategies and the firm did not incorporate inaccurate performance data in its advertisements or program marketing materials.","res":"Consent","sm":"Notice of hearing was issued December 21, 2017. Consent order was issued December 21, 2017.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1525},{"d":"2017-12-21","di":"2017-12-21","dr":"2017-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":2000000.0,"dk":"2013036343601","al":"Without admitting or denying FINRA's findings, Raymond James Financial services (\"RJFS\" or \"firm\") consented to the sanctions imposed by FINRA and to the entry of findings that, between December 2007 and September 2017, RJFS did not have supervisory systems and process for reviewing email communications that were reasonably designed to achieve compliance with applicable legal requirements or appropriate for the firm's business, size, structure and customers, as a result, FINRA found that RJFS violated NASD rules 3010 and 2110 and FINRA rules 3110 and 2010. In particular, FINRA found that (1) the firms' automated lexicon- based system to surveil the e-mails of its personnel was flawed in significant respects, (2) the firm failed to devote adequate personnel and resources to the team that reviewed e-mails, (3) the firm failed to apply all of its policies in its primary lexicon to branch offices that had their own email servers, and (4) the firm did not periodically test the configuration and effectiveness of its email surveillance system. The firm was censured, fined $2 million, and agreed to certain undertakings to address the identified deficiencies.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $2 million and undertakes to certify in writing to FINRA that it has adopted and implemented written supervisory policies, procedures, and systems including, if utilized, an appropriate email review lexicon, that are reasonably designed to address each of the deficiencies identified in this AWC and that it has (I) completed a risk-based retrospective review, which may include the use of sampling, reasonably designed to detect potential violations of the securities laws and FINRA rules evidenced in emails sent or received by its registered representatives that were impacted by the systemic failures described above; and has (II) complied with its Form U4, Form U5, and rule 4530 reporting obligations as a result of its findings arising out of that review.","sm":"The Financial Industry Regulatory Authority (\"FINRA\") entered findings that Raymond James Financial services, inc., failed to establish, maintain, and supervise a supervisory system in connection with review of email communications. Without admitting or denying the findings, on December 21, 2017, the firm consented to a censure and fine of $2,000,000 and is adopting and implementing supervisory policies to address the deficiencies.","ab":"Raymond James Financial","firms":[149018],"id":1526},{"d":"2017-12-20","di":"2017-10-10","dr":"2017-12-20","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania, Department of Banking and Securities","san":"Other","os":"Administrative assessment","st":"Final","fine":23480.0,"dk":"17-0077","al":"From February 2017 until December 2017, Vanguard Advisers, inc., due to administrative error, employed an investment adviser representative who, although registered as an investment adviser representative in Arizona, was not registered as an investment adviser representative in Pennsylvania.","res":"Consent","sd":"An administrative assessment of $23,480 was levied against vai. Payment was made January 9, 2018.","sm":"An investment adviser representative (\"IAR\") changed his personal residence from Arizona to Pennsylvania. As a result of an administrative error, Vanguard Advisers, inc. did not immediately update his registration to reflect Pennsylvania as his new place of employment. Vanguard Advisers, inc. self identified the issue.","ab":"Vanguard Advisers Inc","firms":[105958],"id":1527},{"d":"2017-12-19","di":"2017-12-19","dr":"2017-12-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1400000.0,"dk":"2014041808101","al":"Without admitting or denying the findings, the firm consented to the entry of the following findings by FINRA: the firm failed to identify and evaluate certain trades with extended settlement dates (es trades) across its product lines and business units for margin and net capital purposes. As a result, the firm for these trades failed to collect the requisite margin in violation of FINRA rules 4210 and 2010; take the appropriate net capital deduction in violation of section 15(c) of the Securities Exchange Act of 1934 (SEA) and rule 15C3-1(c) thereunder and FINRA rule 2010; prevent extension of credit in cash accounts in violation of FINRA rule 2010 by violating regulation t of the Board of Governors of the Federal Reserve system (reg t); maintain accurate schedules to the general ledger in violation of section 17(a) of the SEA and rule 17A-3 thereunder and FINRA rules 4511 and 2010; and file accurate FOCUS reports in violation of SEA rule 17A-5 and FINRA rule 2010. The firm also failed to establish, maintain and enforce a reasonable supervisory system, including written supervisory procedures (WSPS), designed to achieve compliance with applicable federal securities laws and regulations with respect to margin, net capital, books and records, and financial and operational combined uniform single (FOCUS) reports in violation of FINRA rule 3110, and its predecessor rule, NASD rule 3010. The firm's supervisory system and written procedures failed to identify and consider es trades across its product lines and business units. Although the firm was made aware of these supervisory deficiencies in April 2013 through findings made during a FINRA's department of member regulation member regulation examination, the firm failed to implement any remedial measures until MID-2014, and failed to implement a reasonable firm-wide supervisory system to identify and consider es trades until MID-2015.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $1,400,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1528},{"d":"2017-12-18","di":"2017-01-20","dr":"2017-12-18","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority 12 Endeavour Square, London, E20 1JN.","san":"Revocation","st":"Final","dk":"FRN REFERENCE NUMBER: 565008)","al":"Notion Capital Managers LLP had its licence revoked after it failed to file certain financial returns with its regulator. Changes of office meant that reminders did not reach the firm. On 18TH December 2017 the firm was re authorised by the FCA.","res":"Decision","sm":"Following the revocation of our licence in January 2017 the FCA agreed to re authorise Notion Capital Managers LLP No information Filed","ab":"Notion Capital Managers LLP","self":true,"firms":[301084],"id":1529},{"d":"2017-12-12","di":"2017-07-27","dr":"2017-12-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12178.0,"dk":"FI REF. 17-12676","al":"In July 2017, Atalan Capital Partners, LP (\"Atalan\") notified the sfsa of a net short position in the shares of a Swedish issuer. The notification occurred after the required date, as specified in regulation (EU) no. 236/2012, and was immediately reported to the sfsa upon discovery by Atalan.","res":"Decision","sd":"Atalan was ordered to pay a special fee of 97,500 Swedish kronor (approximately usd $12,178) upon the issuance of an invoice by the sfsa.","sm":"In its decision, the sfsa acknowledged that the special fee of 97,500 Swedish kronor (approximately usd $12,178) had been reduced from the guidelines normally used to assess such fees, given that Atalan self reported the late notification and had implemented additional controls to ensure timely reporting to the sfsa going forward.","ab":"Atalan Capital Partners, LP","self":true,"firms":[226714],"id":1530},{"d":"2017-12-12","di":"2017-07-27","dr":"2017-12-12","k":"Regulatory Action","rg":"Other","reg":"Swedish Financial Supervisory Authority (\"Sfsa\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14988.0,"dk":"FI REF. 17-12677","al":"In July 2017, Atalan Capital Partners, LP (\"Atalan\") notified the sfsa of a net short position in the shares of a Swedish issuer. The notification occurred after the required date, as specified in regulation (EU) no. 236/2012, and was immediately reported to the sfsa upon discovery by Atalan.","res":"Decision","sd":"Atalan was ordered to pay a special fee of 120,000 Swedish kronor (approximately usd $14,988) upon the issuance of an invoice by the sfsa.","sm":"In its decision, the sfsa acknowledged that the special fee of 120,000 Swedish kronor (approximately usd $14,988) had been reduced from the guidelines normally used to assess such fees, given that Atalan self reported the late notification and had implemented additional controls to ensure timely reporting to the sfsa going forward. No information Filed","ab":"Atalan Capital Partners, LP","self":true,"firms":[226714],"id":1531},{"d":"2017-12-11","di":"2017-11-30","dr":"2017-12-11","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":9000.0,"dk":"17-9364","al":"The market regulation department of the CME Group Inc. (\"CME\") determined, based on a self-report from Goldman Sachs & Co. LLC (the \"firm\"), that order modification or cancellation messages on certain firm systems identified the tag 50 id of the trader who originated an order, rather than the tag 50 id of the trader who modified or cancelled the order, in deemed violation of CME rule 576.","res":"Decision","sm":"The CME imposed a summary fine on the firm in the amount of $9,000.00, which was paid by submission of a wire on December 11, 2017.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1532},{"d":"2017-12-07","di":"2017-12-07","dr":"2017-12-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":20000.0,"dk":"2016049334801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it executed short sale orders in over-the-counter (OTC) equity securities and improperly marked the orders as short exempt. The findings stated that the firm executed short sale transactions in OTC equity securities and incorrectly reported the transactions to the OTC reporting facility with short exempt modifiers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $20,000.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1533},{"d":"2017-12-05","di":"2017-12-05","dr":"2017-12-05","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":400000.0,"dk":"3-18296","al":"The SEC alleged that Ratan and MS. Chopra willfully violated certain sections of the sections of the Investment Advisers Act of 1940, specifically violated section 207 of the Investment Advisers Act of 1940 (the \"Advisers Act\"), and section 206(4) of the Advisers Act and rule 206(4)-8 thereunder.thereunder.","res":"Settled","sd":"$200,000 for nehal Chopra and $200,000 for Ratan. Paid in December 2017.","sm":"On December 5, 2017, the SEC entered into a settlement order with Ratan and its managing partner, nehal Chopra, among others, settling an administrative action. The SEC found that from 2013 to 2014, Ratan and MS. Chopra failed to disclose that MS. Chopra's spouse provided certain investment and operational services to Ratan. MS. Chopra's spouse served as a consultant investment analyst to Ratan and made investment recommendations to Ratan and MS. Chopra while he was employed by another investment adviser utilizing a similar investment strategy. The SEC found that MS. Chopra's spouse shared research and confidential information obtained through his employment at the other investment adviser with MS. Chopra and Ratan. The SEC further found that Ratan and MS. Chopra willfully violated section 207 of the Advisers Act, and section 206(4) of the Advisers Act and rule 206(4)-8 thereunder due to the failure to disclose MS. Chopra's husband's role with Ratan. Ratan and MS. Chopra consented, without admitting or denying the findings, to cease and desist from committing or causing future violations of sections 207 and 206(4) of the Advisers Act and rule 206(4)-8 thereunder, and to pay a civil penalty of $200,000 each. No information Filed","ab":"Chopra, Nehal, Kamalapat","firms":[160440],"id":1534},{"d":"2017-12-01","di":"2017-12-01","dr":"2017-12-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":700000.0,"dk":"2014042582101","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of enforcement alleged that Goldman Sachs execution and clearing, L.P. (\"GSEC\"), a former affiliate of Goldman Sachs & Co. LLC (the \"firm\"), due to certain flaws in its prospectus-delivery system, failed to deliver certain ETF prospectuses that it intended to deliver in the period between June 2008 and October 2014. As a consequence of GSEC's alleged failure to establish, maintain and enforce a supervisory system and written supervisory procedures in connection with ETF prospectus delivery that were reasonably designed to achieve compliance with section 5(b) (2) of the Securities Act of 1933, the firm allegedly violated NASD rules 3010 (a) and (b) and 2110 and FINRA rule 2010. In addition, as a result of GSEC's alleged failure to establish, maintain and enforce supervisory control policies and procedures that adequately tested and verified that its supervisory procedures concerning ETF prospectus delivery were reasonably designed to achieve compliance with applicable securities laws and regulations, the firm allegedly violated NASD rules 3012 and 2110 and FINRA rule 2010. (FINRA rule 2010 replaced NASD rule 2110 effective December 15, 2008.) On June 12, 2017, GSEC and the firm consummated a merger of GSEC with and into the firm (the \"merger\"), with the firm surviving the merger and assuming any remaining GSEC assets, liabilities and operations. On June 13, 2017, GSEC filed a uniform request withdrawal from broker-dealer registration (form BDW) with the Securities and Exchange Commission, which became effective on August 11, 2017.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the rule violations, allegations or findings, the firm consented to a censure, a fine and an undertaking, and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on December 1, 2017, and on December 14, 2017, the firm submitted a wire in payment of a fine in the amount of $700,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1535},{"d":"2017-12-01","di":"2016-02-23","dr":"2017-12-01","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"CBOT 16-0382-BC","al":"Pursuant to an offer of settlement in which amp capital neither admitted nor denied the alleged rule contravention upon which the penalty was based in Q4 2017, amp capital was ordered by a panel of the CME group business conduct committee to pay a fine of $15,000. Please see below link to the notice of disciplinary action published on the CME's website in respect of the item reported. HTTPS://www.cmegroup.com/notices/disciplinary/2017/12/CBOT-16-0382-BC-AMP-CAPITAL-INVESTORS-LIMITED.HTML as is self- evident from the notice, the disciplinary action arose from exchange for related position (EFRP) transactions involving two amp capital managed funds in April 2015. The transactions, the subject of the notice, were for the benefit of and did not adversely impact the funds in question. The matter was the subject of a confidential settlement as we are unable to provide any further details.","res":"Settled","ab":"Dexus Capital Investors Limited","self":true,"firms":[162793],"id":1536},{"d":"2017-11-29","di":"2017-10-31","dr":"2017-11-29","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":52000.0,"dk":"AWC NO. 20140437801-02","al":"Bats Edgx Exchange alleged that the firm (1) failed to reasonably avoid displaying, and engaged in a pattern or practice of displaying, quotations that locked or crossed a protected quotation, in violation of edgx rules 11.8(c) and 11.10(f), and (2) failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with edgx rules 11.8(c) and 11.10(f) regarding displaying quotations that locked or crossed a protected quotation, in violation of edgx rules 3.1, 5.1, 5.2 and 5.3.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to the following sanctions: (1) a censure, and (2) a fine in the amount of $52,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1537},{"d":"2017-11-28","di":"2017-11-28","dr":"2017-11-28","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Suspension","st":"Final","dk":"N/A","al":"The Securities and Exchange Commission of the philippines (\"philippines SEC\") alleged that the firm did not meet certain reporting requirements in the philippines regarding its regional area headquarters (\"RHQ\"), which had not engaged in any operations in the philippines for decades and did not plan to engage in any operations in the philippines in the future.","res":"Order","sm":"An RHQ is a special type of \"branch\" whose authorized activities are limited to acting as an administrative branch of a multinational company engaged in international trade and principally serves as a supervision, communications and coordination center for its subsidiaries, branches or affiliates in the asia-pacific region and other foreign markets. The firm's RHQ had been dormant for decades and did not engage in any securities activities. As a means to deregister the RHQ, the firm requested that the philippines SEC suspend its license and the philippines SEC granted the firm's request.","ab":"Bank of America, National","firms":[142558],"id":1538},{"d":"2017-11-21","di":"2017-11-21","dr":"2017-11-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":1250000.0,"dk":"2016049305401","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that during the period from January 1, 2009 through May 2017, it failed to conduct timely or adequate background checks on approximately 8,670- or approximately 95%-of its non-registered associated persons. The findings stated that the firm did not fingerprint 1,880 of the 8,670 until after the start of its remediation process and did not fingerprint another 156 until after they began to work for the firm. The firm timely fingerprinted the remaining 6,634 associated persons, but screened them under section 19 of the federal insurance deposit act and an internally created list of crimes. The firm failed to screen any of the 8,670 for some types of felony convictions or regulatory actions, as required under the Securities Exchange Act of 1934. The findings also stated that least four persons who were subject to a statutory disqualification were allowed to associate, or remain associated, with the firm during the relevant period. The firm was unable to determine whether another 391 associated persons were subject to a statutory disqualification because when the firm conducted its review their associations had ended or they were on leave. The findings also included that the firm failed to create and maintain for the four associated persons who were subject to disqualification, questionnaires or applications approved in writing by an authorized representative of the firm that contained among other things, a record of the respective arrests and convictions. The firm also did not create and maintain fingerprint records for all of its eligible associated persons. FINRA found that the firm's failure to fingerprint or properly screen 8,670 of its associated persons arose from its failure to maintain a supervisory system or procedures to identify and properly screen all individuals who became associated with the firm in a non-registered capacity. The firm failed to establish and maintain a supervisory system to identify all of its associated persons to screen them for statutory disqualification and to fingerprint eligible associated persons. The firm also failed to establish, maintain and enforce written procedures that were reasonably designed to achieve compliance with applicable securities laws and regulations, including recordkeeping provisions, fingerprinting provisions and FINRA eligibility rules. The policies and procedures, with some limited exceptions, did not address methods for identifying firm non-registered associated persons or the need to screen under the Securities Exchange Act of 1934 standards. Further, the firm failed to enforce its written procedures requiring that all employees be fingerprinted prior to employment.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining the appropriate monetary sanction, FINRA considered the firm's cooperation in self-reporting and undertaking to remedy its violations.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1539},{"d":"2017-11-17","di":"2017-11-17","dr":"2017-11-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"2016049857301","al":"FINRA alleged that the firm did not send certain margin disclosures to clients as required under FINRA rule 2264(b) during 2012, 2013 and 2014 in violation of FINRA rules 2010 and 2264(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"On November 17, 2017, Morgan Stanley Smith Barney LLC was assessed a fine of $150,000 by FINRA in connection with allegations that the firm did not send certain margin disclosures to clients as required under FINRA rule 2264(b) during 2012, 2013 and 2014 in violation of FINRA rules 2010 and 2264(b).","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1540},{"d":"2017-11-13","di":"2017-11-13","dr":"2017-11-13","k":"Regulatory Action","rg":"Other","reg":"Ohio Department of Insurance","san":"Other","os":"N/a","st":"Final","fine":500.0,"dk":"N/A","al":"Failure to timely report a regulatory action on a professional license and provided an incorrect answer to the insurance license application/renewal.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1541},{"d":"2017-11-13","di":"2017-11-13","dr":"2017-11-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil money penalty","st":"Final","fine":3500000.0,"dk":"3-18279","al":"SEC admin release 34-82054, November 13, 2017: the SEC deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 against Wells fargo advisors, LLC. in anticipation of the institution of these proceedings, respondent 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, respondent consents to the entry of this order instituting administrative and cease-and-desist proceedings pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease- and-desist order. On the basis of this order and respondent's offer, the commission finds that these proceedings arise out of Wells fargo advisors' failure to file or timely file a number of suspicious activity reports (\"SARS\") from approximately March 2012 through June 2013. The majority of these failures involved the failure to timely file SARS on ongoing suspicious activity that continued after an initial sar filing by Wells fargo advisors on related suspicious activity. At the time, Wells fargo advisors' anti-money laundering (\"AML\") policies and procedures required the filing of SARS pursuant to the requirements of the Bank Secrecy Act (\"BSA\"), including the filing of SARS related to continuing suspicious activity. Despite these requirements, Wells fargo advisors failed to file or timely file at least 50 SARS, a majority of which related to continuing suspicious activity occurring in accounts held at Wells fargo advisors' U.S. branch offices that focused on international customers. As a result of this conduct, Wells fargo advisors willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder.","res":"Order","sm":"In determining to accept Wells fargo advisors' offer, the commission considered voluntary remedial acts promptly undertaken by respondent, including the firm's retaining a third party AML compliance firm to review certain of its sar investigations during the summer of 2014. In determining whether to accept the offer, the commission has also considered the undertakings enumerated in the order. In view of the foregoing, the commission deems it appropriate and in the public interest to impose the sanctions agreed to in respondent Wells fargo advisors' offer. Accordingly, pursuant to sections 15(b) and 21c of the Exchange Act it is hereby ordered that: respondent cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-8 promulgated thereunder; respondent is censured; and respondent shall, within 30 days of the entry of this order, pay a civil money penalty in the amount of $3,500,000.00 to the SEC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1542},{"d":"2017-11-13","di":"2017-11-13","dr":"2017-11-13","k":"Regulatory Action","rg":"Other","reg":"Office of Antiboycott Compliance, Bureau of Industry and Security, U.S. Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":44625.0,"dk":"CASE NO. 16-03","al":"The Office of Antiboycott Compliance, Bureau of Industry and Security, U.S. Department of Commerce (\"BIS\") alleged, as set forth in a proposed charging letter, that bank of america N.A. (\"BOFA\"), on thirteen occasions, violated the export administration regulations (currently codified at 15 C.F.R. 730-774 (2017) (\"regulations\"), which are issued under the authority of the export administration act of 1979, as amended. The allegations were resolved pursuant to a settlement agreement between BIS and BOFA. Under the settlement agreement, BIS entered an order imposing a civil penalty, but did not initiate any administrative or judicial proceeding or make a referral to the Department of Justice for criminal proceedings against BOFA with respect to section 8 of the export administration act or part 760 of the regulations. No findings of violations were made.","res":"Order","sm":"Bofa entered into a settlement agreement with bis. The settlement agreement resolved allegations by the bis that bofa, on thirteen occasions, violated the export administration regulations (currently codified at 15 C.F.R. 730-774 (2017) (\"regulations\"), which are issued under the authority of the export administration act of 1979, as amended. Under the settlement agreement, bis entered an order imposing a civil penalty, but did not initiate any administrative or judicial proceeding or make a referral to the Department of Justice for criminal proceedings against bofa with respect to section 8 of the export administration act or part 760 of the regulations. No findings of violations were made.","ab":"Bank of America, National","firms":[142558],"id":1543},{"d":"2017-11-08","di":"2017-11-08","dr":"2017-11-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"2017-03-00042","al":"The firm entered into an offer of settlement and consent for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings referred to in the offer of settlement. The offer of settlement reflects that on March 10, 2017, while having knowledge of the terms and conditions of an order to buy put options, a firm trader entered an order to effect transactions as hedges against the buy put options order prior to the conditions of the order being disclosed in violation of NYSE ARCA options rule 6.49(b).","res":"Decision & Order of Offer of Settlement","sm":"NYSE regulation took into consideration that the firm reported the relevant transaction on the trade date, and promptly provided follow-up information concerning the facts and circumstances of the violation. NYSE regulation provided the firm credit for self-reporting in determining the appropriate sanctions to assess.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1544},{"d":"2017-11-06","di":"2017-11-06","dr":"2017-11-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":30000.0,"dk":"2016051812801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report to TRACE the correct time of trade execution for 88 transactions in TRACE-eligible securitized products. The findings stated that the firm failed to report to TRACE 148 transactions in TRACE-eligible securitized products within 15 minutes of the time of execution.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $30,000. Fines paid in full on November 17, 2017.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1545},{"d":"2017-11-03","di":"2017-11-03","dr":"2017-11-03","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina Department of the Secretary of State Securities Division","san":"Cease and Desist","st":"Final","fine":18088.8,"dk":"09 SEC 057","al":"Failure to supervise the sale of auction rate securities.","res":"Consent","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1546},{"d":"2017-11-03","di":"2017-11-03","dr":"2017-11-03","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"15-0320-BC","al":"Alleged violation of NYMEX rules 432.w and 534 in that a trader for cgmi entered certain orders in various NYMEX futures products for different accounts wholly owned and controlled by cgmi and that cgmi failed to supervise its trader between November 26, 2014 and September 29, 2015.","res":"Settled","sm":"Without admitting or denying the allegations, the firm consented to a fine in the amount of $20,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1547},{"d":"2017-11-03","di":"2017-11-03","dr":"2017-11-03","k":"Regulatory Action","rg":"Other","reg":"Commodity Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"15-0320-BC","al":"Alleged violation of comex rules 432.w and 534 in that a trader for cgmi entered certain orders in various comex futures products for different accounts wholly owned and controlled by cgmi and that cgmi failed to supervise its trader between November 26, 2014 and September 29, 2015.","res":"Settled","sm":"Without admitting or denying the allegations, the firm consented to a fine in the amount of $20,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1548},{"d":"2017-11-01","dr":"2017-11-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":39500.0,"dk":"2015045105501","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of enforcement alleged that Goldman Sachs & Co. LLC (the \"firm\"): (a) during the period from December 11, 2014 through December 16, 2014, failed to report to the over-the-counter (\"OTC\") reporting facility (\"OTCRF\") the correct time of execution for certain transactions in reportable securities in violation of FINRA rule 7330(d)(4); and (b) during the periods from September 1, 2014 to December 31, 2014, and from January 1, 2015 to April 30, 2015, (I) failed to transmit to the OTCRF certain last sale reports of transactions in OTC equity securities within 10 seconds after execution, in violation of FINRA rule 6622(a) and FINRA rule 2010, and (II) did not have a supervisory system reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of NASD and FINRA, concerning OTC equity trade reporting; specifically, that the firm's written supervisory procedures were not sufficiently instructive as to how often the responsible supervisor(s) should take the specified steps designed to achieve compliance, and that the firm failed in certain respects to enforce its supervisory procedures concerning OTC equity trade reporting, in violation of NASD rule 3010 (for conduct prior to December 1, 2014), and FINRA rules 3110 (for conduct on and after December 1, 2014) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on November 1, 2017, and on November 10, 2017, the firm submitted a wire in payment of a fine in the amount of $39,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1549},{"d":"2017-10-31","di":"2017-10-16","dr":"2017-10-31","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3500.0,"dk":"CEI RSRH-17-4869","al":"On October 16, 2017 the CME Group issued JPMS a summary fine of $3500 for closing out positions on September 15, 2017 in the September gold contract after the deadline for position adjustments which resulted in a reduction in open interest of 27%.","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1550},{"d":"2017-10-31","di":"2017-10-31","dr":"2017-10-31","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":38000.0,"dk":"AWC NO. 20140437801-01","al":"Nasdaq Stock Market alleged that the firm (1) failed to reasonably avoid displaying, and engaged in a pattern or practice of displaying, quotations that locked or crossed a protected quotation, in violation of Nasdaq rules 4613(e) and 4755(a)(4), and (2) failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with Nasdaq rules 4613(e) and 4755(a)(4) regarding displaying quotations that locked or crossed a protected quotation, in violation of Nasdaq rules 2010a and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to the following sanctions: (1) a censure, and (2) a fine in the amount of $38,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1551},{"d":"2017-10-31","di":"2017-10-31","dr":"2017-10-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement and prejudgment interest: $338,709.11; civil money penalty of $300,000","st":"Final","fine":300000.0,"dk":"FILE NO. 3-18272","al":"Millennium Management LLC (the \"Millennium respondent\") was alleged to have violated rule 105 of Regulation M of the Securities Exchange Act of 1934 (\"rule 105\").","res":"Settled","sd":"Civil money penalty: $300,000 disgorgement and prejudgment interest: $338,709.11 (for a total of $638,709.11, which was paid on November 6, 2017.)","sm":"On October 31, 2017, the Millennium respondent consented, without admitting or denying the findings therein, to the entry of an order issued by the SEC finding that on four occasions in 2012 it violated rule 105 of Regulation M of the US Securities Exchange Act of 1934. (See SEC release no. 34-81989.) In settlement of this matter, the Millennium respondent agreed to pay a civil money penalty of $300,000, as well as disgorgement and prejudgment interest of $338,709.11 and to cease and desist from committing or causing any violations and any future violations of rule 105 of Regulation M of the Exchange Act.","ab":"Millennium Management LLC","self":true,"firms":[158117],"id":1552},{"d":"2017-10-24","di":"2017-10-24","dr":"2017-10-24","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Cease and Desist","st":"Final","fine":975000.0,"dk":"2016-502","al":"The New Jersey Bureau of Securities (BUREAU) alleged that LPL Financial LLC (LPL) failed to supervise its representatives' sales of certain alternative investments to New Jersey residents and failed to make and maintain accurate books and records relating to the sale of certain alternative investment transactions.","res":"Consent","sm":"The bureau alleged that during the period January 1, 2008 through December 31, 2015 (relevant period) LPL failed to adequately supervise its representatives' sales of certain alternative investments to New Jersey residents and failed to make and maintain accurate books and records relating to the sale of certain alternative investment transactions. Without admitting or denying the allegations, LPL agreed to (1) review its sales of certain non-traded alternative investment transactions and offer to repurchase products that were sold to New Jersey residents in violation of LPL's alternative investment guidelines and/or New Jersey prospectus requirements during the relevant period, and (2) to pay the bureau a civil penalty of $950,000 and remit $25,000 to New Jersey's investor education fund. Finally, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1553},{"d":"2017-10-21","di":"2017-09-26","dr":"2017-10-21","k":"Regulatory Action","rg":"NYSE","reg":"NYSE American LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":135000.0,"dk":"2016-07-01304","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it had a previously executed customer order nullified and adjusted to an inferior price, in violation of the firm's best execution obligations. The nullification and adjustment occurred without the customer's knowledge and consent, and to a price outside of NYSE American's best bid and offer. The findings stated that the firm failed to implement adequate supervisory systems and controls reasonably designed to achieve compliance with NYSE American rule 966NY, as well as NYSE American rules 16 and 476(a) (6) as they pertain to the best execution of client multi-leg options transactions. The findings also stated that the firm failed to implement adequate supervisory systems and controls, and adequate written supervisory procedures, reasonably designed to ensure the preservation of certain documents and information that the firm knew, or reasonably should have known, potentially were relevant to the possible regulatory action.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In connection with NYSE regulation's investigation, the firm paid its customer $20,000 in restitution.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1554},{"d":"2017-10-18","di":"2017-09-20","dr":"2017-10-18","k":"Regulatory Action","rg":"Other","reg":"Bats Edga Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10500.0,"dk":"2014041635005","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Action number 20140416350 includes 20150441761 and 20160512855","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1555},{"d":"2017-10-18","di":"2017-09-20","dr":"2017-10-18","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":21000.0,"dk":"2014041635006","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Action number 20140416350 includes 20150441761 and 20160512855","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1556},{"d":"2017-10-16","di":"2017-10-16","dr":"2017-10-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","dk":"2014042465601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that certain firm registered representatives recommended volatility-linked exchange-traded products (volatility etps) to brokerage customers without fully understanding their risks and features. The findings stated that the firm failed to vet or place restrictions on recommendations and purchases of volatility etps, and as a result, these products were made available to retail brokerage customers regardless of risk profile and investment objective. Certain firm representatives mistakenly believed that volatility etps could be used as a long-term hedge on their customers' equity positions in the event of a market downturn. In fact, volatility etps are generally short-term trading products that degrade significantly over time and should not be used as part of a long-term buy-and-hold investment strategy. Accordingly, in those instances, the representatives did not have a reasonable basis to recommend volatility etps as suitable to customers with conservative or moderate risk profiles and investment objectives and the representatives further failed to appropriately recommend the exit of these positions within a timely manner. In some instances, customers incurred significant losses. The findings also stated that the firm failed to establish and maintain a supervisory system, including written policies and procedures, reasonably designed to achieve compliance with NASD rule 2310 in connection with its sale of volatility etps. Although the firm should have been aware of the complexity and unique risks and features associated with volatility etps, the firm failed to implement a reasonable system to supervise its representatives' solicited sales of volatility etps. The findings also included that the firm's supervisory systems also did not include reasonable training for registered representatives and supervisors regarding the features and risks associated with volatility etps. Because the firm failed to establish and provide reasonable guidance, training or tools to educate its registered representatives and supervisors about volatility etps, certain retail brokerage customers were uninformed about the features and risks associated with volatility etps prior to purchasing them.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining to resolve this matter without the imposition of a fine, FINRA took the following into consideration: (I) prior to detection by FINRA, the firm corrected its supervisory deficiencies relating to volatility etps; (II) the firm was previously fined $2.1 million - after the misconduct and its remediation herein - for similar violations relating to non-traditional etps; and, (III) the firm provided substantial assistance to FINRA by, among other things, engaging at its own expense a consulting firm to review, compile, and calculate large amounts of data pertaining to sales of volatility etps for use in determining the appropriate restitution to be provided.","ab":"Wells Fargo Advisors; Wells Fargo Clearing","firms":[11025,19616],"id":1557},{"d":"2017-10-12","di":"2017-09-26","dr":"2017-10-12","k":"Regulatory Action","rg":"Other","reg":"Bangko Sentral NG Pilipinas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1306930.0,"dk":"NONE","al":"The Bangko Sentral NG Pilipinas (BS\") approved the imposition of a monetary penalty on the firm for the following violations of the manual of regulations on foreign exchange transactions: deficiency in e/foreign currency deposit unit (FCDU) asset cover requirement, false/erroneous certification of compliance with e/FCDU cover and breach on the cap on allowable lending of FCDU funds to regular banking units.","res":"Other","sm":"The monetary board imposed a penalty in the amount of PHP67,303,484.29 (approx. USD1,306,930) on the firm. Pursuant to the BSP's rules, the firm's demand deposit account with the BSP shall be automatically debited the above referenced amount upon the lapse of fifteen calendar days from receipt of the final billing letter. Therefore, the amount may be debited no earlier than October 12, 2017.","ab":"Bank of America, National","firms":[142558],"id":1558},{"d":"2017-10-11","di":"2017-02-17","dr":"2017-10-11","k":"Regulatory Action","rg":"Other","reg":"Commissione Nazionale Per la Societa' E la Borsa (Consob)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":86900.0,"dk":"0022744/17","al":"Alleged breach of rules on disclosure obligation to the market in relation to a transaction regarding an italian listed company active in the TMT sector","res":"Other","sd":"Consob issued a sanction order on 11 October 2017. Sanction ordered was a monetary penalty of $86,900.","sm":"Consob issued a sanction order on 11 October 2017. Mediobanca subsequently appealed the consob order but the order has been confirmed.","ab":"Mediobanca - Banca Di","firms":[139138],"id":1559},{"d":"2017-10-10","di":"2017-10-10","dr":"2017-10-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"20150440574-01","al":"Without admitting or denying the findings, the firm consented to the sanctions and entry of findings that during the period October 13, 2014 through May 31, 2015, the firm failed to timely report to the FINRA/Nasdaq trade reporting facility (\"FNTRF\") transactions that required an .RX modifier, a violation of FINRA rule 7230a(g). In addition, the firm's supervisory reviews regarding OTC exercise/assignments were not adequate, a violation of NASD rule 3010 (for conduct before December 1, 2014) and FINRA rules 2010 and 3110 (for conduct on or after December 1, 2014).","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1560},{"d":"2017-10-04","di":"2017-10-04","dr":"2017-10-04","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Department of Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"NC FILE NO: 14 SEC 087","al":"On October 10, 2017, J.P. Morgan Securities LLC (\"JPMS\") entered into an administrative consent order (\"order\") with the North Carolina securities division (\"NCSD\"). JPMS consented to the entry of the order that found violations of NCGS §78a­36(b) and 18 ncac 06A.1411(a). The order alleged that certain JPMS sales assistants (\"SAS\") for private wealth management (\"PWM\") and private client services (\"PCS\") accepted unsolicited orders at times when the SAS were not appropriately registered in the state of North Carolina, and that JPMS failed to establish an adequate supervisory system to monitor the registration status of persons accepting client orders, failed to ensure its SAS were registered in accordance with JPMS's written procedures, and failed in certain instances to record the identity of the persons accepting client orders through the topaz system until June of 2011.","res":"Settled","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1561},{"d":"2017-09-29","di":"2017-09-29","dr":"2017-09-29","k":"Regulatory Action","rg":"Federal Reserve","reg":"Governors of the Federal Reserve System (The \"Federal Reserve\")","san":"Cease and Desist","os":"Monetary fine","st":"Final","dk":"17-010-B-FB; 17-010-B-HC; 17-010-CMP-FB; 17-010-CMP-HC","al":"In September 2017, following the conclusion of the US Federal Reserve board's review of the effectiveness of HSBC's FX practices during the period of October 2008 through October 2013, HSBC Holdings PLC and HSBC north america holdings inc. entered into a consent order regarding certain deficiencies in HSBC's control and oversight over its FX business. HSBC through various subsidiaries of holdings, including hbeu and hbus, lacked adequate governance, risk management, compliance and audit policies and procedures to ensure that HSBC's covered FX activities complied with safe and sound banking practices and applicable internal policies. On August 18, 2023, the Federal Reserve board concluded that HSBC was in full compliance and terminated the consent order","res":"Consent","sd":"Pursuant to the federal deposit insurance act, the Federal Reserve issued a consent order to cease and desist and assessment of a civil money penalty (the \"order\"). Accordingly, HSBC shall cease and desist with respect to the deficiencies documented in the order and take affirmative action relating to internal controls and compliance oversight over certain markets activity. On September 29, 2017, HSBC paid a civil money penalty in the amount of $175,296,000.","sm":"In September 2017, following the conclusion of the US Federal Reserve board's review of the effectiveness of HSBC's FX practices during the period of October 2008 through October 2013, HSBC Holdings PLC and HSBC north america holdings inc. entered into a consent order regarding certain deficiencies in HSBC's control and oversight over its FX business (including HSBC's failure to detect and address its traders' misuse of confidential customer information, as well as the use of electronic chatrooms to communication with competitors about trading positions","ab":"HSBC Holdings PLC","firms":[154700],"id":1562},{"d":"2017-09-27","di":"2017-09-27","dr":"2017-09-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":400000.0,"dk":"2011030598001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to transmit 548,669,414 reportable order events (ROES) to the order audit trail system (OATS) during the review period. The findings stated that the firm failed to detect a technology issue that affected its reporting system, which caused the ROES generated by one of its sponsored access clients not to be transmitted to OATS. The firm failed to enforce its written supervisory procedures which specified that the firm would review its OATS web interface reports and data to ensure that all ROES were being submitted to OATS. Based on the volume of non-reporting and the extended period over which it occurred, the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with the securities laws and regulations, and FINRA rules regarding OATS. The findings also stated that in 171 instances, the firm accepted a short sale order from another person, or effected a short sale for its own account, without first borrowing the security, or entering into a bona-fide arrangement to borrow the security, and had a fail-to-deliver position at a registered clearing agency in such security that was not closed out in accordance with the requirements of paragraph (a) of SEC rule 204. In four instances, the firm executed a short sale order and failed to properly mark the order as short. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, concerning rule 204 of Regulation SHO. The findings also included that for 61 settlement dates, the firm reported 171 short interest positions totaling 4,706,076 shares when it should have reported 90 short interest positions totaling 747,865 shares. The violations resulted from a coding error that caused the firm to erroneously include short interest positions from certain accounts in the short interest reports the firm submitted to FINRA. 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 FINRA rules, concerning short interest position reporting.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined a total of $470,000, of which $400,000 is payable to FINRA. The remaining $70,000 will be paid to NYSE ARCA equities, inc. in a related matter.","sm":"In determining sanctions, FINRA considered that as of July 6, 2015, the firm had terminated the sponsored access business that resulted in the OATS violations cited herein. In unrelated FINRA matters, the firm retained an independent consultant and revised its written supervisory procedures related to OATS as of September 2016 and had revised its Regulation SHO written supervisory procedures as of March 10, 2015. Thus, the sanctions in this matter do not include an undertaking because of this conduct.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1563},{"d":"2017-09-26","di":"2017-09-26","dr":"2017-09-26","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Other","st":"Final","fine":70000.0,"dk":"2012033328201","al":"A FINRA hearing officer considered an offer of settlement and consent entered into between FINRA on behalf of NYSE ARCA inc. and the firm. The firm entered into an offer of settlement and consent for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings referred to in the offer of settlement. The hearing officer accepts the offer of settlement and consent and issues this decision. The findings stated that this matter involves the firm's failure to comply with supervision requirements of NYSE ARCA equities rule 6.18 regarding the close-out requirements of rule 204 of Regulation SHO, Securities Exchange Act of 1934 (rule 204). The firm's supervisory system was not reasonably designed to ensure compliance with the requirements of rule 204(a) of Regulation SHO. Specifically, the firm's allocation strategy contravened regulatory principles and rule 204, because it did not inherently ensure fails were being properly closed out and or allocated in accordance with rule 204(d) of Regulation SHO, and thus resulted in an increase in the number of securities that were required to be closed out, resulting in recurring fails. This failure resulted in the firm effecting short sale transactions for certain correspondent broker-dealers that increased the failure to deliver positions. Finally, the firm also failed to properly close out a fail that resulted from one of its retail clients' trading activity. The findings also stated that the firm's operational processes and systems were not reasonably designed to ensure compliance with the requirements of rule 204 of Regulation SHO. Specifically, the operational reports the firm used to identify fails did not include certain exchange-listed securities subject to the close-out provisions of rule 204(a). As a result, the firm failed to identify and properly close-out fails in these securities, as required by rule 204(a) of Regulation SHO.","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured and fined $70,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1564},{"d":"2017-09-25","di":"2017-09-25","dr":"2017-09-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and restitution","st":"Final","fine":3250000.0,"dk":"2016048805501","al":"Without admitting or denying the findings, the firm consented to sanctions and to the entry of findings that it violated NASD rule 3010 and FINRA rules 3110 and 2010 by failing to establish and maintain a supervisory system and written supervisory procedures (WSPS) reasonably designed to detect and prevent potentially unsuitable short-term trading of unit investment trusts (UITS), including that the firm failed to adequately supervise representatives' sales of UITS by providing insufficient guidance to supervisors regarding how they should monitor and review uit transactions to detect unsuitable short-term trading of UITS, including short-term rollovers. The firm also failed to conduct training for registered representatives specific to UITS during the relevant period and had an inadequate system, including no automated mechanism, to detect potentially unsuitable short-term uit rollovers. In June 2015, the firm modified its policies and procedures to include uit rollovers in the switch definition, thereby making uit rollovers executed more than 100 days prior to maturity subject to the firm's supervisory review and approval process.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In resolving this matter, FINRA has recognized the firm's cooperation in having: (1) initiated, prior to intervention by a regulator, a firm-wide investigation to identify the scope of potentially unsuitable short-term uit rollovers; (2) identified customers harmed by potentially unsuitable short-term uit rollovers and established a plan to provided remediation to those customers; and 3) provided substantial assistance to FINRA in its investigation.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1565},{"d":"2017-09-24","di":"2017-09-24","dr":"2017-09-24","k":"Regulatory Action","rg":"State regulator","reg":"The Secretary of State of North Carolina","san":"Cease and Desist","os":"Civil penalty and reimbursement of investigative costs.","st":"Final","fine":25000.0,"dk":"16 ADM 001","al":"The Secretary of State of North Carolina and securities administrator, alleged that LPL failed to reasonably supervise charles fackrell, one of its registered representatives, who, unbeknownst to LPL, operated a ponzi scheme in which he encouraged individuals to invest money in fictitious entities. Fackrell generally diverted the funds for personal expenses, although some funds were paid to investors to perpetuate the appearance of returns. After LPL was alerted to fackrell's criminal and unapproved activities, it immediately investigated and terminated him.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1566},{"d":"2017-09-22","di":"2017-09-19","dr":"2017-09-22","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Securities Division","san":"Cease and Desist","os":"Respondent shall obtain a branch office license for all places in the state of Nevada from which one or more sales","st":"Final","fine":5000.0,"dk":"I17-061","al":"An inspection of respondent's records was initiated because in July 2016, one of respondent's sales representatives moved from California to Nevada and appeared to transact securities-related business from his residence prior to obtaining a license for this branch office. It was determined that respondent maintained an unlicensed branch office in violation of NRS 90.360(2) and nac 90.392","res":"Order","sd":"Civil penalty and inspection fee paid on 09/19/2017.","sm":"At all times, the firm properly registered the branch office by filing form BR with the state of Nevada. The firm, however, did not timely file with the state of Nevada as a foreign corporation pursuant to NRS 80.010 which effectively rendered the branch office as deficient.","ab":"Lime Brokerage LLC","firms":[877],"id":1567},{"d":"2017-09-22","di":"2017-09-22","dr":"2017-09-22","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertakings","st":"Final","fine":2500000.0,"dk":"CFTC DOCKET NO. 17-25","al":"The Commodity Futures Trading Commission (CFTC) alleged that it had reason to believe that the firm (a) violated regulation 166.3, 17 C.F.R. § 166.3 (2016), under the Commodity Exchange Act (CEA) in connection with its alleged failure to supervise diligently the firm's response to the investigation by the CME group inc.'s market regulation department regarding recordkeeping and execution practices with respect to block trades; (b) violated regulation 166.3, 17 C.F.R. § 166.3 (2016), under the CEA in connection with its alleged inadequate procedures for preparing and maintaining records for block trades executed by the swaps desk, including procedures for recording accurate block trade execution times and not being diligent in ensuring that its existing procedures for preparing and maintaining records for block trades were being implemented; and (c) violated section 4g of the CEA, 7 U.S.C. § 6g (2012) and regulations 1.31 and 1.35 under the CEA, 17 C.F.R. §§ 1.31 and 1.35 (2016) in connection with its alleged failure to maintain certain books and records regarding the execution of block trades.","res":"Order","sm":"Without admitting or denying any of the findings or conclusions in the order, the firm consented to the imposition of the following sanctions: (1) to cease and desist from violating section 4g of the cea and regulations 1.31, 1.35 and 166.3 thereunder, (2) to pay a civil monetary penalty in the amount of $2,500,000, (3) to comply with certain undertakings.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1568},{"d":"2017-09-20","di":"2017-09-20","dr":"2017-09-20","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10500.0,"dk":"2014041635003","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Action number 20140416350 includes 20150441761 and 20160512855","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1569},{"d":"2017-09-19","di":"2017-09-19","dr":"2017-09-19","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10500.0,"dk":"2014041635001","al":"The firm entered into an offer of settlement and consent for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings referred to in the offer of settlement. 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.","res":"Decision & Order of Offer of Settlement","sm":"Action number 20140416350 includes 20150441761 and 20160512855","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1570},{"d":"2017-09-18","di":"2017-08-24","dr":"2017-09-18","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10500.0,"dk":"2014041635002","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Action number 20140416350 includes 20150441761 and 20160512855","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1571},{"d":"2017-09-13","di":"2017-09-13","dr":"2017-09-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1100000.0,"dk":"2012033515001","al":"Without admitting or denying the findings, the firm consented to the sanctions relating to FINRA's findings that during the period from June 9, 2010 through July 26, 2012: (1) the firm over-advertised certain trade volume on trade date plus three (\"t+3\") in violation of FINRA rule 5210 and 2010; and (2) that the firm-wide execution volume was not readily accessible which inhibited the firm's ability to adequately know and ensure the advertisement of certain volume was accurate and the firm failed to have a supervisory system including WSPS in place to review the accuracy of trade volume advertised on a t+3 basis in violation of NASD rule 3010 and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1572},{"d":"2017-09-13","di":"2017-06-21","dr":"2017-09-13","k":"Regulatory Action","rg":"Other","reg":"C2 Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"C2 17-0001 / 20150443193","al":"C2 Options Exchange, Incorporated (\"C2\") business conduct committee (the \"committee\") alleged that Goldman Sachs execution & clearing, L.P. (\"GSEC\"), a former affiliate of Goldman Sachs & Co. LLC (the \"firm\"), failed: (I) from on or about May 21, 2014 through on or about July 14, 2016, to qualify and register one associated person (the \"associated person\") in the appropriate category of registration with C2, and to register the associated person in the prerequisite registration category with C2; and (II) from on or about May 21, 2014 through on or about March 25, 2015, to register the minimum number of individuals required to be registered as a proprietary trader principal (TP) with C2, each in alleged violation of C2 rule 3.4. On June 12, 2017, GSEC and the firm consummated a merger of GSEC with and into the firm (the \"merger\"), with the firm surviving the merger and assuming any remaining GSEC assets, liabilities and operations. On June 13, 2017, GSEC filed a uniform request withdrawal from broker-dealer registration (form BDW) with the Securities and Exchange Commission, which became effective on August 11, 2017.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted an offer of settlement to the committee on August 8, 2017. On September 13, 2017, the committee issued a decision accepting the offer of settlement, and on September 20, 2017, the firm submitted a wire in payment of the fine in the amount of $10,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1573},{"d":"2017-09-13","di":"2017-06-21","dr":"2017-09-13","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":5000.0,"dk":"17-0046 / 20150443193","al":"Chicago Board Options Exchange, Incorporated (\"CBOE\") business conduct committee (the \"committee\") alleged that, from on or about November 5, 2011 through on or about July 14, 2016, Goldman Sachs execution & clearing, L.P. (\"GSEC\"), a former affiliate of Goldman Sachs & Co. LLC (the \"firm\"), failed to qualify and register one associated person (the \"associated person\") in the appropriate category of registration with CBOE, and failed to register the associated person in the prerequisite registration category with CBOE, in alleged violation of CBOE rule 3.6a. On June 12, 2017, GSEC and the firm consummated a merger of GSEC with and into the firm (the \"merger\"), with the firm surviving the merger and assuming any remaining GSEC assets, liabilities and operations. On June 13, 2017, GSEC filed a uniform request withdrawal from broker-dealer registration (form BDW) with the Securities and Exchange Commission, which became effective on August 11, 2017.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted an offer of settlement to the committee on August 8, 2017. On September 13, 2017, the committee issued a decision accepting the offer of settlement, and on September 20, 2017, the firm submitted a wire in payment of the fine in the amount of $5,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1574},{"d":"2017-09-13","di":"2017-09-13","dr":"2017-09-13","k":"Regulatory Action","rg":"Other","reg":"Box Options Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure & disgorgement","st":"Final","fine":45000.0,"dk":"2015046552701","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1575},{"d":"2017-09-13","di":"2017-09-13","dr":"2017-09-13","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Markets Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3000.0,"dk":"DECISION: 7/768/27.10.2016 (BAUPOST); 8/768/27.10.2016 (SETH KLARMAN)","al":"Pursuant to applicable greek law, the registrant was required to report an increase in its ownership of a listed warrant to both the Hellenic capital market commission (HCMC) and the issuer of the security following trading in October 2013. The issuer of the security was required to make the report public following receipt. The registrant caused the required notification to be submitted to the HCMC and the issuer within the statutory notification period. The issuer of the warrants claims that it did not timely receive the original report and ultimately was four days late in making the report public. The board of directors of the HCMC imposed an administrative fine of 3,000 euros in the aggregate on the registrant and its advisory affiliate, seth Klarman, for the late filing. The registrant and MR. Klarman disagree with the HCMC decision.","res":"Decision","sd":"A 1,000 euro fine was imposed on the registrant and a 2,000 euro fine was imposed on its advisory affiliate, seth Klarman.","sm":"The space provided). The board of directors of HCMC determined to impose an administrative sanction for the reporting breach, described above in item 7, on both the registrant and its advisory affiliate, seth Klarman. The monetary sanctions have been described above in item 12 and no additional proceedings are anticipated at this time. No information Filed","ab":"Klarman, Seth, Andrew","firms":[109530],"id":1576},{"d":"2017-09-08","di":"2017-09-08","dr":"2017-09-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":65000.0,"dk":"2015045971701","al":"Alleged violation of FINRA rules 7230a(b), 6622(a), 2010, and 3110 in that Citigroup Global Markets Inc. failed to accept or decline in the FINRA/Nasdaq trade reporting facility certain transactions in reportable securities within 20 minutes after execution, the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance, and failed to submit to the OTC reporting facility certain last sale reports of transactions within 10 seconds after execution during the periods January 1, 2015 through April 30, 2015 and September 1, 2014 through December 31, 2014.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $65,000, and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1577},{"d":"2017-09-07","di":"2017-09-07","dr":"2017-09-07","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6874000.0,"dk":"INSURANCE COMPLIANCE EXAMINATION DEPARTMENT (CASE NUMBER NOT AVAILABLE)","al":"Financial Supervisory Service alleged that Samsung Life Insurance (1) failed to pay accurate amount interest, (2) improperly terminated insurance policy when there were no breach of a duty of notification, and (3) improperly refused requests to cancel additional insurance coverage","res":"Decision","sd":"Financial Supervisory Service imposed a fine of KRW 7,365,000,000 (approximately usd 6,874,000) on Samsung Life Insurance and issued reprimand, warning and notification of wrongdoing against 5 incumbent and former executives","sm":"The Financial Supervisory Service issued a notice of its decision, finding Samsung Life Insurance liable for the allegation listed in our answer to question 7. As a result, financial service imposed a fine of KRW 7,365,000,000 (approximately usd 6,874,000) on Samsung Life Insurance","ab":"Samsung Life Insurance","firms":[158319],"id":1578},{"d":"2017-08-28","di":"2017-08-28","dr":"2017-08-28","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":77145.17,"dk":"13 SEC 088","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1579},{"d":"2017-08-22","di":"2017-08-22","dr":"2017-08-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and restitution","st":"Final","fine":500000.0,"dk":"2012034714701","al":"FINRA alleged that the firm failed to transmit trades to the TRF within the time limit required by FINRA rule 7230a.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 22, 2017, without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it routinely failed to show the correct time of order receipt and/or execution on the memorandum of brokerage orders for trades in national market system (NMS) stock executed through the firm's trade process by its preferred securities trading desk. The findings stated that the firm routinely failed to report the correct time of execution to the FINRA trade reporting facility (TRF) for trades in NMS stocks executed through the firm's trade process by its preferred securities trading desk. In addition, the firm failed to transmit such trades to the TRF within the time required by FINRA rule 7230a. The findings also stated that in 1,851 instances, the firm failed to contemporaneously or partially execute 683 customer orders in 66 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. In 74 transactions for or with a customer in preferred securities, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. FINRA found that in 100 instances, the firm failed to execute orders in preferred securities fully and promptly, and in 23 of those same instances, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. 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, concerning: (I) recordation of order receipt time and execution time, trade reporting, and best execution requirements as they pertain to NMS preferred securities; (II) FINRA rule 5320 (trading ahead) as it pertains to executed and unexecuted orders in OTC preferred securities; and (III) best execution requirements as they pertain to new issue non- convertible preferred OTC securities. The firm agreed to a censure and to a fine of $500,000 (comprised of $105,000 for recordkeeping and trade reporting violations, $160,000 for trading ahead violations, $10,000 for best execution violations, $25,000 for market order timeliness violations, and $200,000 for supervision violations), and agreed to pay restitution of $103,219.25, plus interest.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1580},{"d":"2017-08-21","di":"2017-08-21","dr":"2017-08-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil and administrative penalty/fine, disgorgement","st":"Final","fine":3946267.0,"dk":"3-18120","al":"Deerfield Management Company L.P. (\"Deerfield\") was alleged to have violated section 204a of the Investment Advisers Act of 1940 (the \"Advisers Act\") from 2012 through 2014. It was alleged that Deerfield failed to establish, maintain, and enforce policies and procedures reasonably designed to prevent the misuse of material, nonpublic information, particularly taking into consideration the nature of Deerfield's business. It was alleged that, as part of the firm's research in the healthcare sector, Deerfield engaged third party consultants and research firms, including firms that specialized in providing \"political intelligence\" regarding upcoming regulatory and legislative decisions, that Deerfield employees based trading recommendations on such information, and that hedge funds advised by Deerfield then made those trades.","res":"Decision & Order of Offer of Settlement","sd":"The civil penalty of $3,946,267, disgorgement of $714,110, prejudgment interest of $97,585 was paid to the Securities and Exchange Commission for the benefit of the United States Treasury on August 22, 2017.","sm":"On August 21, 2017, the SEC issued an order, instituting an administrative proceeding and accepting an offer of settlement from Deerfield, pursuant to sections 203(e) and 203(k) of the Advisers Act. The order required Deerfield to cease and desist from committing or causing any violations and any future violations of section 204a of the Advisers Act, censured the firm and provided that the firm pay disgorgement of $714,110, prejudgment interest of $97,585 and a civil money penalty of $3,946,267. Pursuant to the order and settlement, Deerfield neither admitted nor denied the findings of the SEC (other than those relating to the jurisdiction of the SEC over it and the subject matter of the action). No information Filed","ab":"Deerfield Management Company, L.P.","self":true,"firms":[157876],"id":1581},{"d":"2017-08-18","di":"2017-08-18","dr":"2017-08-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":110000.0,"dk":"2014039939801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it engaged in trading unit aggregation but failed to ensure that individual traders were assigned to only one aggregation unit (AGU) at any time, that AGU's had operated autonomously and engaged in separate trading strategies without regard to other trading units, and that AGU's had not coordinated trading activities or interacted or shared order or position information. The findings stated that the firm employed four individuals who acted as both a trader in one AGU and as a trader or supervisor in another AGU, including two individuals who served in such dual capacities. Such arrangement is improper because it could result in the coordination of trading strategies or trading based upon position or trading information of the other AGU. The findings also stated that the firm failed to provide adequate supervision to monitor for compliance with rule 200(f) of Regulation SHO. Aggregation of a unit's independent net position prior to each sale limits the potential for abuse associated with coordination among units. The firm's written plan of organization reflected unclear strategies, strategies that overlapped for multiple agus and traders that also acted as traders or supervisors in other agus. The firm also lacked adequate written supervisory procedures (WSPS) and supporting documentation reflecting its creation and approval of agus and its supervision of traders. The findings also included that the firm transmitted to OATS reports that contained inaccurate, incomplete, or improperly formatted data. The firm failed to report to OATS non-market making proprietary orders and erroneously submitted post-trade allocations as reportable order events to OATS. FINRA found that the firm failed on 26 occasions to provide written notification disclosing to its customer that a transaction was executed by the firm at an average price, that transaction details were available upon request, and/or its capacity in the transaction. FINRA also found that the firm inaccurately marked short sell orders as long. In addition, FINRA determined that the firm accepted a short sale order in an equity security from another person, or effected a short sale in an equity security for its own account, without borrowing the security, or entering into a bonafide arrangement to borrow the security or having reasonable grounds to believe that the security could be borrowed so that it could be delivered on the date delivery is due and documenting compliance with rule 203(b)(1) of Regulation SHO","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $110,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1582},{"d":"2017-08-17","di":"2017-08-17","dr":"2017-08-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":22500.0,"dk":"2016049381801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report 22,592 repo transactions effected in municipal securities to the real time reporting system (RTRS). The findings stated that the supervisory system on the desk responsible for effecting the relevant repo transactions did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the municipal securities rulemaking board (MSRB) rules, concerning the reporting of transactions in municipal securities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $22,500. The mitigated monetary sanction in this matter reflects the firm's self-reporting of the violations described above.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1583},{"d":"2017-08-16","di":"2014-12-30","dr":"2017-08-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":275000.0,"dk":"3-18113","al":"The SEC issued a request for information to Capital Dynamics, Inc. (\"CDI\") on December 30, 2014. The matter was settled on August 16, 2017, with CDI neither admitting nor denying the SEC's findings, which related to certain expenses allocated to a legacy fund. Many of the expenses had been identified during an internal audit that began in 2014 (prior to the SEC inquiry), and were voluntarily reimbursed to the fund, with interest, in 2015 and 2016. CDI was not censured and is not subject to ongoing monitoring obligations. CDI agreed to cease and desist from violating the relevant provisions of the Investment Advisers Act of 1940. The order did not require disgorgement by CDI, and any reimbursements made by CDI were voluntary. CDI also paid a civil monetary penalty of $275,000. The SEC order acknowledged CDI's cooperation during the investigation as well as the remedial measures taken by CDI, including voluntary reimbursement of the affected fund.","res":"Order","sd":"The SEC settlement order is final and the civil money penalty was paid within 10 days of the settlement.","ab":"Capital Dynamics, Inc.","self":true,"firms":[130320],"id":1584},{"d":"2017-08-15","di":"2017-08-15","k":"Regulatory Action","dk":"2015046971701","ab":"Allan, Nas, ADEL","firms":[7691],"id":1585},{"d":"2017-08-07","di":"2017-08-07","dr":"2017-08-07","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"2016-03-00089","al":"JPMS, without admitting or denying, consented to the findings that during the period January 1, 2014 through March 31, 2014 and January 1, 2015 through March 31, 2016 violated NYSE rule 123c by improperly cancelling a total of 362 market-on-close (\"MOC\"), limit-on-close (\"LOC\") and/or closing offset (\"CO\") orders after the prescribed cutoff time of 3:45 P.M., when cancellations are only permitted to correct legitimate errors; and violated NYSE rule 3110 and NYSE rule 342 by failing to implement adequate supervisory systems and controls reasonably designed to achieve compliance with NYSE rule 123c.","res":"Consent","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 7, 2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1586},{"d":"2017-07-27","di":"2017-07-27","dr":"2017-07-27","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange Inc","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":50000.0,"dk":"20120348296-05","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-5(b) and (c)(l)(II) and (c)(2), and edgx rules 5.1, 5.2, 5.3, and 3.1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/27/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1587},{"d":"2017-07-27","di":"2017-07-27","dr":"2017-07-27","k":"Regulatory Action","rg":"Other","reg":"Bats Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":15000.0,"dk":"20120348296-09","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to ensure compliance with all regulatory requirements, including supervising customer trading to detect and prevent potentially violative and manipulative activity, in violation of the Securities Exchange Act rules 15C3-5(b) and (c)(2), and byx rules 5.1, 5.2, 5.3, and 3.1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/27/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1588},{"d":"2017-07-27","di":"2017-07-27","dr":"2017-07-27","k":"Regulatory Action","rg":"Other","reg":"Bats BZX Exchange Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":110000.0,"dk":"20120348296-04","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-5(b) and (c)(l)(II) and (c)(2), and BZX rule 5.1, 5.2, 5.3, and 3.1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/27/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1589},{"d":"2017-07-27","di":"2017-07-27","dr":"2017-07-27","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Cease and Desist","st":"Final","dk":"17-023","al":"REIT's sold in amounts greater than 10 percent of clients LNW, violating prospectus guidelines.","res":"Consent","sd":"Money Concepts Capital Corp. voluntarily entered into a consent agreement with the Ohio Division of Securities. The firm agreed to offer rescission/restitution to Ohio investors identified as having been sold reits in excess of Ohio's 10 percent liquid net worth concentration limit. Total amount not yet known.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":1590},{"d":"2017-07-21","di":"2017-06-22","dr":"2017-07-21","k":"Regulatory Action","rg":"Other","reg":"Bats Byx Exchange, Inc.","st":"Final","fine":20625.0,"dk":"2013037651702","al":"Alleged non-compliance with certain regulatory NMS and Bats byx rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, fined $20,625 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and Bats byx rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1591},{"d":"2017-07-19","di":"2017-07-19","dr":"2017-07-19","k":"Regulatory Action","rg":"Other","reg":"Tokyo Stock Exchange, Inc. (\"Tokyo Stock Exchange\").","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":729000.0,"dk":"TORISAN NO.55","al":"The Tokyo stock exchange found that an employee's quoting and trading activities on the Tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares. As such, the Tokyo stock exchange found that the employee's trading violated article 159(2)(I) of the financial instruments and Exchange Act.","res":"Decision","sm":"On July 19, 2017, Morgan Stanley MUFG securities co., LTD. (MSMS) became subject to an order by the Tokyo stock exchange for payment of a monetary penalty of jpy 80,000,000 (729,000 usd) and received a three day trading suspension to begin on July 31, 2017 in connection with findings that that an employee's quoting and trading activities on the Tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares and therefore constituted a violation of article 159(2)(I) of the financial instruments and Exchange Act","ab":"Morgan Stanley MUFG","firms":[149777],"id":1592},{"d":"2017-07-19","di":"2017-07-19","dr":"2017-07-19","k":"Regulatory Action","rg":"Other","reg":"The Japan Securities Dealers Association","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":181753.0,"dk":"KISHIN 29 NO.121","al":"The Japan Securities Dealers Association found that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares. As such, The Japan Securities Dealers Association found that the employee's trading violated article 159(2)(I) of the financial instruments and Exchange Act.","res":"Decision","sm":"On July 19, 2017, Morgan Stanley MUFG securities co., LTD. (MSMS) became subject to an order by the Japan securities dealer association for payment of a monetary penalty of jpy 20,000,000(181,753 usd) in connection with findings that that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares and therefore constituted a violation of article 159(2)(I) of the financial instruments and Exchange Act.","ab":"Morgan Stanley MUFG","firms":[149777],"id":1593},{"d":"2017-07-19","di":"2017-07-19","dr":"2017-07-19","k":"Regulatory Action","rg":"Other","reg":"Osaka Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"TORISAN NO.71","al":"The Osaka Exchange found that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares. As such, the FSA found that the employee's trading violated article 159(2)(I) of the financial instruments and Exchange Act.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On July 19, 2017, Morgan Stanley MUFG securities co., LTD. (MSMS) became subject to an order of censure by the Osaka Exchange in connection with findings that that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would mislead others into believing sales and purchases of the shares of seibu holdings inc. were thriving and would cause fluctuations in the market of the shares and therefore constituted a violation of article 159(2)(I) of the financial instruments and Exchange Act.","ab":"Morgan Stanley MUFG","firms":[149777],"id":1594},{"d":"2017-07-18","di":"2017-07-18","dr":"2017-07-18","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":115000.0,"dk":"20120348296-03","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-5(b), (c)(l)(II) and (c)(2) and Nasdaq rules 3010 and 2010a.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/18/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1595},{"d":"2017-07-18","di":"2017-07-18","dr":"2017-07-18","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":85000.0,"dk":"20120348296-02","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-5(b) and (c)(l)(II) and NYSE rule 342 (prior to 12/1/2014) and NYSE rule 3110 (on or after 12/1/2014), and NYSE rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/18/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1596},{"d":"2017-07-18","di":"2017-07-18","dr":"2017-07-18","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Options Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20120348296-07","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016, the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-5(b) and (c)(l)(II), and chapter III, sections 1, 2(a) and 2(a)(I) of the Nasdaq option market rules, and Nasdaq rules 3010 and 2010a.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 07/18/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1597},{"d":"2017-07-18","di":"2016-08-08","dr":"2017-07-18","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":65000.0,"dk":"CBOT-16-0421-BC","al":"On November 3, 2015, and March 1, 2016, Alphadyne executed certain exchange for related position (\"EFRP\") transactions in U.S. Treasury futures contracts that were contingent upon the execution of other EFRP transactions. (CBOT rule 538.c. Exchange for related positions).","res":"Settled","sd":"The $65,000 fine was paid by the adviser on 7/20/2017. No portion of the fine was waived.","sm":"On November 3, 2015, and March 1, 2016, Alphadyne executed certain exchange for related position (\"EFRP\") transactions in U.S. Treasury futures contracts that were contingent upon the execution of other EFRP transactions. On July 18, 2017, the panel of the Chicago Board of Trade (\"CBOT\") business conduct committee concluded that Alphadyne violated CBOT rule 538.c. Exchange for related positions and ordered Alphadyne to pay a fine of $65,000 without admitting nor denying the findings. No information Filed","ab":"Alphadyne Asset Management LP","self":true,"firms":[154176],"id":1598},{"d":"2017-07-17","di":"2017-03-17","dr":"2017-07-17","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","st":"Final","fine":20000.0,"dk":"2016048918401","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $20,000.00.","sm":"Associated matter includes ise file nos. 2015-265, 2016-036, and 2016-247.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1599},{"d":"2017-07-17","di":"2017-07-17","dr":"2017-07-17","k":"Regulatory Action","rg":"Other","reg":"ICE Futues U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2017-034","al":"Alleged violation of rule 4.07(c) in that Citigroup Global Markets Inc. failed to report a block trade in a timely manner.","res":"Decision","sm":"Cgmi consented to a summary fine in the amount of $5,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1600},{"d":"2017-07-14","di":"2017-06-23","dr":"2017-07-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":250000.0,"dk":"2014043565901","al":"The Nasdaq PHLX LLC (\"PHLX\") business conduct committee alleged that during the period between January 19, 2010 and January 16, 2016, Goldman Sachs & Co. LLC (the \"firm\"): (I) failed to report and inaccurately reported certain option positions to the large options position reporting (\"LOPR\") system, in alleged violation of PHLX rules 1003 and 707; and (II) failed to establish and maintain an adequate supervisory system, including a system of follow-up and review, that was reasonably designed to achieve compliance with the rules governing the reporting of options positions to the LOPR system including sufficient written supervisory procedures to ensure the proper reporting of submissions to the LOPR, in alleged violation of PHLX rules 748(g) (for the period prior to November 23, 2012), 748(h) (for the period on and after November 23, 2012), and 707.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine, a censure, and an undertaking, and entered into an offer of settlement, stipulation of facts and consent to sanctions with the PHLX business conduct committee (the \"offer of settlement\"), which was accepted by the PHLX business conduct committee on June 26, 2017, and became final on July 14, 2017. On July 31, 2017, the firm submitted a wire in payment of the fine in the amount of $250,000. The offer of settlement was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following self- regulatory organizations: bats BZX exchange, inc.; Nasdaq ise, LLC (f/k/a the international securities exchange, LLC); and the Financial Industry Regulatory Authority, inc.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1601},{"d":"2017-07-14","di":"2017-07-14","k":"Regulatory Action","rg":"Other","reg":"Bats BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":525000.0,"dk":"2012031318002","al":"Bats BZX Exchange, Inc. (\"BZX\") alleged that during the period between at least February 19, 2010 and July 7, 2016, Goldman Sachs & Co. LLC (the \"firm\"): (I) failed to report and inaccurately reported certain option positions to the large options position reporting (\"LOPR\") system, in alleged violation of BZX rule 18.10; and (II) failed to establish and maintain an adequate supervisory system, including a system of follow-up and review, that was reasonably designed to achieve compliance with the rules governing the reporting of options positions to the LOPR system including sufficient written supervisory procedures to ensure the proper reporting of submissions to the LOPR, in alleged violation of BZX rules 3.1, 5.1, 5.2 and 5.3.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine, a censure, and an undertaking, and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by BZX on June 26, 2017, and became final on July 14, 2017. On July 31, 2017, the firm submitted a wire in payment of a fine in the amount of $525,000. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following self-regulatory organizations: Financial Industry Regulatory Authority, inc.; Nasdaq ise, LLC (f/k/a the international securities exchange, LLC); and Nasdaq PHLX LLC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1602},{"d":"2017-07-14","di":"2017-07-14","dr":"2017-07-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Ise, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":300000.0,"dk":"2012031318003","al":"Nasdaq Ise, LLC (\"ISE\") alleged that during the period between January 1, 2016 and July 7, 2016, Goldman Sachs & Co. LLC (the \"firm\"): (I) failed to report and inaccurately reported certain option positions to the large options position reporting (\"LOPR\") system, in alleged violation of ISE rule 415(a); and (II) failed to establish and maintain an adequate supervisory system, including a system of follow-up and review, that was reasonably designed to achieve compliance with the rules governing the reporting of options positions to the LOPR system including sufficient written supervisory procedures to ensure the proper reporting of submissions to the LOPR, in alleged violation of ISE rule 401.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine, a censure, and an undertaking, and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by ise on July 14, 2017, and on July 31, 2017, the firm submitted a wire in payment of a fine in the amount of $300,000. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following self-regulatory organizations: Financial Industry Regulatory Authority, inc.; bats BZX exchange, inc.; and Nasdaq PHLX LLC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1603},{"d":"2017-07-14","di":"2017-07-14","dr":"2017-07-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":1425000.0,"dk":"2012031318001","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman Sachs & Co. LLC (the \"firm\"): (I) during the period between at least January 9, 2010 and July 7, 2016, failed to report and inaccurately reported certain over-the-counter (\"OTC\") option positions to the large options position reporting (\"LOPR\") system, in alleged violation of FINRA rule 2360(b)(5); (II) during the period from July 31, 2012 through April 29, 2016, exceeded the positon limits in three different OTC options for certain customers and/or proprietary accounts, in alleged violation of FINRA rule 2360(b)(3), and (III) during the period between at least January 19, 2010 and July 7, 2016, failed to establish and maintain an adequate supervisory system, including a system of follow-up and review, that was reasonably designed to achieve compliance with the rules governing the reporting of options positions to the LOPR system and compliance with applicable position limits, including sufficient written supervisory procedures to ensure the proper reporting of submissions to the LOPR, in alleged violation of NASD rule 3010 (for conduct prior to December 1, 2014), and FINRA rules 3110 (for conduct on and after December 1, 2014) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine, a censure, and an undertaking, and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on July 14, 2017, and on July 27, 2017, the firm submitted a wire in payment of a fine in the amount of $1,425,000. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following self-regulatory organizations: bats BZX exchange, inc.; Nasdaq ise, LLC (f/k/a the international securities exchange, LLC); and Nasdaq PHLX LLC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1604},{"d":"2017-07-13","di":"2017-07-13","dr":"2017-07-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","os":"For sanctions, refer to item 12 below.","st":"Final","fine":725000.0,"dk":"2016049783001","al":"FINRA alleged that Edward jones failed to establish, maintain, and enforce an adequate supervisory system, including written procedures, concerning the creation and dissemination of consolidated reports in violation of NASD rule 3010(a) and FINRA rule 2010 during the time period April 2010 through 2014.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1605},{"d":"2017-07-12","di":"2017-07-12","dr":"2017-07-12","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"NC FILE NOS. 14 SEC 046 AND 14 SEC 047","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the North Carolina Securities Division (division) alleged that Citigroup Global Markets Inc. (CGMI) accepted client orders through sales assistants who were highly likely not registered in North Carolina, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in North Carolina. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in North Carolina through sales assistants that were highly likely not registered in North Carolina, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in North Carolina constituted bases for the assessment of a civil penalty and investigative costs. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, $25,000 for the civil penalty and $10,000 for the costs of investigation. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1606},{"d":"2017-06-29","di":"2017-06-29","dr":"2017-06-29","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","st":"Final","fine":78375.0,"dk":"2013037651706","al":"Alleged non-compliance with certain regulatory NMS and NYSE ARCA rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $78,375 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and NYSE ARCA rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1607},{"d":"2017-06-29","di":"2017-06-29","dr":"2017-06-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":78375.0,"dk":"2013037651705","al":"Alleged non-compliance with certain regulatory NMS and FINRA rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, fined $78,375 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and FINRA rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1608},{"d":"2017-06-27","di":"2017-06-27","dr":"2017-06-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20120348296-06","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-S(b) and (c)(l)(II) and NYSE ARCA options rule 11.18.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 6/27/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1609},{"d":"2017-06-27","di":"2017-06-27","dr":"2017-06-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":365000.0,"dk":"20120348296-01","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to (1) prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters; or that indicate duplicative orders, prevent the entry of orders that exceeded pre-set credit thresholds in the aggregate with regard to one client or (2) supervise customer trading to detect and prevent potentially violative and manipulative activity. The above findings are in violation of the Securities Exchange Act rules 15C3-5(b), (c)(1)(1) and (c)(l)(II), (c)(2) and NYSE ARCA equities rules 6.18 and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on June 27, 2017","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1610},{"d":"2017-06-27","di":"2017-06-27","dr":"2017-06-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":125000.0,"dk":"2013034947901","al":"In June 2017, Stifel entered into an acceptance, waiver and consent with FINRA to settle allegations that Stifel did not provide timely disclosures to a municipal issuer in connection with its role as placement agent in a placement of bonds issued by the municipal issuer in accordance with interpretive guidance issued by the municipal securities rulemaking board (\"MSRB\") regarding MSRB rule G-23. In May 2012, Stifel recommended that the issuer do a placement, in lieu of a public offering, in order to save on debt service costs. The issuer accepted Stifel's recommendation and agreed that Stifel would serve as placement agent. However, Stifel did not provide the disclosures regarding its role in a timely manner. As a result, the firm was alleged to have violated MSRB rule G-23 by serving as both financial advisor and placement agent on the same issue. While not admitting or denying the allegations, Stifel agreed to a regulatory censure and a monetary fine of $125,000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1611},{"d":"2017-06-26","di":"2017-06-26","dr":"2017-06-26","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20120348296-08","al":"JPMS, without admitting or denying the finding, consented to the sanctions and to the entry of findings that during the period from May 2012 through April 2016 the firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to prevent the entry of erroneous orders by rejecting orders that exceeded certain price or size parameters or that indicate duplicative orders, in violation of the Securities Exchange Act rules 15C3-S(b) and (c)(l)(II) and exchange rule 748.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on 6/26/2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1612},{"d":"2017-06-26","di":"2017-06-26","dr":"2017-06-26","k":"Regulatory Action","rg":"Federal Reserve","reg":"Federal Reserve Bank of New York and Board of Governors of the Federal Reserve System (Collectively, \"Federal Reserve\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Not applicable","st":"Final","fine":3000000.0,"dk":"DOCKET NO. 17-016-CMP-HC","al":"The Federal Reserve alleged violations of regulation y of the Board of Governors (12 C.F.R. § 225) for its regulatory accounting treatment of certain assets of variable interest entities (the \"vies\").","res":"Consent","sd":"A civil money penalty in the amount of $3,000,000. BNY mellon effected payment on or about June 27, 2017.","sm":"Provided). This action arises out of the Federal Reserve's assertion that BNY mellon failed to properly include approximately $14 billion of certain assets of variable interest entities (the \"vies\") in its calculation of its risk-based regulatory capital ratios. Beginning in the third quarter of 2010, the Federal Reserve found that BNY mellon accounted for these vie assets in its \"trading book,\" wherein it assigned the assets a zero-risk weighting under a value-at-risk model. It was determined that BNY mellon's regulatory accounting treatment of the vie assets was improper under then-applicable basel I regulatory risk capital rules. As the Federal Reserve consent order relates, BNY mellon deviated from the regulatory capital rules without the necessary authorization from the Federal Reserve and excluded these assets from its regulatory capital ratios for nearly 14 quarters, resulting in BNY mellon understating its risk-weighted assets and overstating its risk-based capital ratios. The Federal Reserve found that this conduct represents or resulted in unsafe or unsound practices, and a violation of regulation y of the Board of Governors (12 C.F.R. § 225). On June 26, 2017, the Federal Reserve announced that it had assessed BNY mellon a civil monetary penalty in the amount of $3 million.","ab":"The Bank of New York; The Bank of New York Mellon; The Bank of New York Mellon Corporation","firms":[231,105642,111208,145995],"id":1613},{"d":"2017-06-22","di":"2017-02-28","dr":"2017-06-22","k":"Regulatory Action","rg":"Other","reg":"Sweden's Finansinspektionen (Sfsa)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1700.0,"dk":"16-11812","al":"On February 28, 2017, FMR LLC, the registrant's ultimate parent company, received notice from sweden's finansinspektionen (the \"sfsa\") that the sfsa was issuing a fine, equivalent to approximately US$1,700, against FMR LLC based on a finding that a notification of a change in shareholdings in a swedish corporation, which shares were held by client accounts managed by FMR LLC's investment advisory subsidiaries, had been made two days late. The late notification was a result of incorrect data that had been supplied to FMR LLC's filing agent by a third-party vendor.","res":"Decision","sd":"Fine of approximately US$1,700 was paid by FMR LLC on June 22, 2017.","ab":"FMR, LLC","firms":[104555,301896,315088],"id":1614},{"d":"2017-06-20","di":"2016-06-13","dr":"2017-06-20","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt Fur Finanzdienstleistungsaufsicht (BAFIN)- (Germany)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":111000.0,"dk":"GZ WA 17-WP 3120-2013/0094; GZ WA 17-WP 3120-2014/0060; GZ WA 17-WP 3120-2014/0121","al":"Alleged failure to timely file three voting rights notifications with BAFIN and the issuers.","res":"Decision","sm":"Thornburg filed three subject voting rights notifications timely but with minor errors. By the time Thornburg was notified of the errors, corrected them and refiled the notifications, the notifications were no longer timely. Among other arguments, Thornburg argued that the initial filings were materially correct and therefore the filings were timely. The fine was 100,000 euros (approximately $111,000). There were no other conditions imposed. No information Filed","ab":"Thornburg Investment Management Inc","self":true,"firms":[106357],"id":1615},{"d":"2017-06-19","di":"2017-06-19","dr":"2017-06-19","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange, Inc.","st":"Final","fine":16500.0,"dk":"2013037651704","al":"Alleged non-compliance with certain regulatory NMS and edgx rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, fined $16,500 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and Bats edgx rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1616},{"d":"2017-06-19","di":"2017-06-19","dr":"2017-06-19","k":"Regulatory Action","rg":"Other","reg":"Bats Edga Exchange, Inc.","st":"Final","fine":57750.0,"dk":"2013037651703","al":"Alleged non-compliance with certain regulatory NMS and Bats edga rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, fined $57,750 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and Bats edga rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1617},{"d":"2017-06-19","di":"2017-05-23","dr":"2017-06-19","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, LLC.","st":"Final","fine":57750.0,"dk":"2013037651707","al":"Alleged non-compliance with certain regulatory NMS and NYSE rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $57,750 and undertakes to revise its written supervisory procedures.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of the findings that it was non- compliant with certain regulatory NMS and NYSE rules regarding the definitional requirements of intermarket sweep orders and related supervision.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1618},{"d":"2017-06-15","di":"2017-05-12","dr":"2017-06-15","k":"Regulatory Action","rg":"Other","reg":"Korean Securities and Futures Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fine in the amount of KRW 15 million","st":"Final","fine":13400.0,"dk":"201-414","al":"Violation of the short sale restriction provisions in the financial investment services and capital markets act.","res":"Decision","sd":"KRW 15,450,000 fine plus fees was paid by Russell investments on August 9TH, 2017. The amount listed in 12.a. Above is the approximate US dollar amount of KRW 15 million as of July 24TH, 2017.","sm":"On June 15, 2017, the securities and futures commission of korea determined to impose a KRW 15 million fine on Russell Investment Management, LLC, for negligence for violation of short sale restrictions of article 180(1) of the financial investment services and capital markets act. No information Filed","ab":"Russell Investment Management, LLC","self":true,"firms":[105734],"id":1619},{"d":"2017-06-15","di":"2016-07-18","dr":"2017-06-15","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Final","fine":3000000.0,"al":"The main allegation of the compliant in that plan fiduciaries violated ERISA by not offering the elast expensive s&p 500 index fund available.","res":"Settled","sd":"Class action was approved and settled for all persons who participated in the New York life insurance company employee progress-sharing investment plan or the New York life agents progress-sharing investment plan (collectively, the \"plans\") whose plan account included an investment in the mainstay s&p 500 index fund at any time during the period between July 18, 2010 and July 19, 2016 (the \"class period\"), including any beneficiary of a deceased person who participated in the plans at any time during the class period, and/or, alternate payees in the case of a person subject to a qualified domestic relations order who participated in the plans at any time during the class period.","ab":"New York Life Investment","firms":[173355],"id":1620},{"d":"2017-06-13","di":"2016-08-25","dr":"2017-06-13","k":"Regulatory Action","rg":"State regulator","reg":"State of California Department of Insurance","san":"Denial","os":"Revocation, civil and administrative penalty/fine, monetary penalty other than fines","st":"Final","dk":"PLBS 10541-AP (AR)","al":"On August 25, 2016 the State of California Department of Insurance (the \"department\") issued a statement of issues alleging that andrew Venturi (\"Venturi\") failed to disclose 2007 and 2008 misdemeanor convictions on an application with the department for a unrestricted license to act as an accident and health agent, a life-only agent with variable contracts authority in violation of California insurance code sections 1668(b), 1668(e) and 1668(h). On October 18, 2016, the department issued an order of denial of unrestricted license and for issuance of restricted license and for monetary penalty.","res":"Other","sd":"The order of denial was issued on 10/18/2016. The order of revocation of license was issued on 4/10/2017. The order of revocation was vacated by the department on 5/15/2017 due to mistake and inadvertence. Venturi informed the department that check payment was sent by mail in November 2016.","sm":"On April 10, 2017, State of California Department of Insurance issued in order of revocation of license for failure to pay monetary penalty. Venturi has informed the department that check payment was sent by mail in November 2016. State of California Department of Insurance issued an order vacating order of summary revocation on May 15, 2017 stating, \"whereas by mistake and inadvertence, an order in the above entitled matter dated April 10, 2017, revoking respondent's license and licensing rights was issued by the insurance commissioner. Now, therefore, good cause appearing, it is hereby ordered that said order of revocation of license for failure to pay monetary penalty be vacated as if the same had never been issued,without prejudice to the commissioner. Further, on June 13, 2017, State of California Department of Insurance issued an order removing restrictions on MR. Venturi's insurance license. No information Filed","ab":"Venturi, Andrew, K","firms":[301819],"id":1621},{"d":"2017-06-09","di":"2017-06-09","dr":"2017-06-09","k":"Regulatory Action","rg":"Other","reg":"Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Administrative fine, return of advisory fees","st":"Final","fine":75000.0,"dk":"2017-0016","al":"Commonwealth of Massachusetts alleged failure to register investment adviser representative who had a place of business in Massachusetts and to ensure investment adviser representative was properly registered with the commonwealth.","res":"Consent","sd":"Monetary fine of $75,000 paid on 06/14/2017","sm":"Monetary fine of $75,000 paid and Massachusetts investment adviser representative registration procedures reviewed to ensure compliance with registration requirements.","ab":"Raymond James Financial Services Advisors, Inc","self":true,"firms":[149018],"id":1622},{"d":"2017-06-02","di":"2017-06-02","dr":"2017-06-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","os":"For sanctions, refer to item 12 below.","st":"Final","fine":210000.0,"dk":"2015046579901","al":"FINRA alleged that Edward jones violated municipal securities rulemaking board rules G-15(f), G-15(f)(III), G-17, and G-47 in connection with transactions in certain municipal securities in amounts lower than the applicable minimum denominations occurring during the time period of December 1, 2013 through December 31, 2014.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1623},{"d":"2017-05-30","di":"2017-05-30","dr":"2017-05-30","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, undertaking","st":"Final","fine":41000000.0,"dk":"17-009-B-FB,17-009-B-FBR, 17-009-B-HC,17-009-B-SMB,17-009-CMP-FB,17-009-CMP-FBR,17-009-CMP-HC,17-009-CMP-SMB","al":"On May 30, 2017, the Board of Governors of the Federal Reserve, Deutsche bank AG, Deutsche bank AG's New York branch, DB USA corporation, and Deutsche bank trust company america entered into an order pursuant to 12 U.S.C. § 1818(b) and 12 U.S.C. § 1818(I). Specifically, the Board of Governors of the Federal Reserve found that (a) the most recent examination of the BSA/AML program at dbtca and the New York branch conducted by the Federal Reserve bank of New York identified significant deficiencies in dbtca's and the branch's risk management and compliance with BSA/AML requirements that resulted in a violation of the regulatory compliance program requirement, and (b) deficiencies in dbtca's transaction monitoring capabilities prevented dbtca from properly assessing BSA/AML risk for billions of dollars in certain potentially suspicious transactions.","res":"Order","sm":"Deutsche bank AG, Deutsche bank AG's New York branch, DB USA corporation, and Deutsche bank trust company america consented to the entry of the order signed on May 30, 2017 by the Board of Governors of the Federal Reserve bank, pursuant to which Deutsche bank (a) committed to pay a civil money penalty of $41 million, which Deutsche bank paid on June 6, 2017; and (b) committed to affirmative obligations including the retention of independent third parties to review dbtca's compliance with applicable BSA/AML requirements and to conduct a transaction review of dbtca's foreign correspondent banking activity from July 1, 2016 to December 31, 2016; and the submission of several distinct written remediation plans and programs targeted at strengthening the bank's compliance, risk management, and monitoring. These obligations have various due dates beginning 30 days after the order was signed.","ab":"Deutsche Bank AG, DB USA","firms":[300838],"id":1624},{"d":"2017-05-26","di":"2017-05-26","dr":"2017-05-26","k":"Regulatory Action","rg":"State regulator","reg":"Virginia Division of Securities and Retail Franchising","san":"Cease and Desist","st":"Final","fine":28095.38,"dk":"SEC-2015-00052","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Virginia Division of Securities and Retail Franchising (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Virginia representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Virginia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Virginia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,095.38. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1625},{"d":"2017-05-19","di":"2017-05-19","dr":"2017-05-19","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":834000.0,"dk":"INSURANCE COMPLIANCE EXAMINATION DEPARTMENT (CASE NUMBER NOT AVAILABLE)","al":"Financial Supervisory Service alleged that Samsung Life Insurance failed to (1) pay insurance when policy holders died by suicide two (2) or more years after the policy holders purchased life insurance, and (2) to properly provide explanation why the company refused to pay insurance when customers died by suicide.","res":"Decision","sd":"Financial Supervisory Service imposed a fine of KRW 894,000,000 (approximately usd 834,000) on and issued a warning against Samsung Life Insurance and issued reduction of salary, reprimand, and warning against 7 incumbent executives and employees and 6 former executives and employees.","sm":"The Financial Supervisory Service issued a notice of its decision finding Samsung Life Insurance liable for the allegation listed in our answer to question 7. As a result, financial service imposed a fine of KRW 894,000,000 (approximately usd 834,000) on Samsung Life Insurance.","ab":"Samsung Life Insurance","firms":[158319],"id":1626},{"d":"2017-05-16","di":"2017-05-16","dr":"2017-05-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure;restitution;undertaking;interest on restitution","st":"Final","fine":650000.0,"dk":"FINRA AWC NO. 2011028842101","al":"As related to the handling of certain customer orders in non-convertible preferred securities (NCPS), the Financial Industry Regulatory Authority (FINRA) found that the firm violated (a) NASD rule 2320 (or FINRA rule 5310 on or after May 31, 2012) and FINRA rule 2010 in connection with its failure, in certain instances, to use reasonable diligence to ascertain the best inter-dealer market and failure to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions; (b) FINRA rule 7230a in connection with the submission to the trade reporting facility (TRF), in certain instances, of last sale reports of transactions in reportable securities that included an inaccurate time of execution and mark-up or mark-down in the unit price; (c) section 17 of the Securities Exchange Act of 1934 (Exchange Act) and SEC rule 17a- 3 thereunder, NASD rule 3110 (or FINRA rule 4511 on or after December 5, 2011) and FINRA rule 2010 in connection with the failure to record the correct time of order entry and correct time of execution on the memorandum of brokerage orders, in certain instances; (d) section 10 of the Exchange Act and SEC rule 10B-10 thereunder, NASD rule 2230 (or FINRA rule 2232 on or after June 17, 2011), and FINRA rule 2010 in connection with the failure to disclose, in certain instances, on customer confirmations the difference between the price reported to the TRF and the price to the customer, which represented compensation to the firm and that the price disclosed to the customer did not match the price reported to the TRF but instead included a mark-up or mark- down; and (e) NASD rule 3010 and FINRA rule 2010 by failing to have in place adequate written supervisory procedures (WSPS) regarding equity trade reporting, the accuracy of customer confirmations and the accuracy of books and records on the firm's global banking & markets credit trading desk. As related to the handling of customer orders in over-the-counter convertible preferred securities (OTC CPS), FINRA also found that the firm violated (I) NASD rule 2320 (for FINRA rule 5310 on or after May 31, 2012) and FINRA rule 2010 in connection with its failure, in certain instances, to use reasonable diligence to ascertain the best inter-dealer market and failure to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions; (II) NASD rule 2111(a) (or FINRA rule 5310.01 for conduct on or after May 31, 2012) and FINRA rule 2010 in connection with the failure to execute orders, in certain instances; (III) violated section 17 of the Exchange Act and SEC rule 17A-3 thereunder, NASD rule 3110 (or FINRA rule 4511 on or after December 5, 2011) and FINRA rule 2010 in connection with the incorrect marking, in certain instances, of \"held\" market orders as \"not held\"; (IV) NASD rule 3010 and FINRA rule 2010 by failing to have in place adequate written supervisory procedures for the timely handling of market orders in OTC CPS handled by the firm's global wealth and retirement solutions block trading desk (block desk); and (v) NASD rule 3010 and FINRA rule 2010 by failing to provide documentary evidence that during the OTC CPS review period it performed the supervisory reviews set forth in its WSPS concerning best execution of customer orders in OTC CPS executed on the block desk.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In connection with the AWC, the firm agreed to an undertaking to submit a signed, dated letter or e-mail to FINRA acknowledging that it revised its written supervisory procedures to address certain of the matters discussed in the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1627},{"d":"2017-05-12","di":"2017-05-12","dr":"2017-05-12","k":"Regulatory Action","rg":"Other","reg":"Australian Securities and Investment Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"MDP 843/16","al":"Alleged violation of rules 3.1.7(1), 3.1.10 and 3.1.11 of subsection 798h(1) of the corporations act 2001 in that the sydney sales desk disclosed to the sydney rates trader information about the buy order 4 before that order had been submitted to the trading platform of the asx 24 market, the firm, through the sydney sales desk, had arranged the details of a potential trade between the chicago sales desk and the sydney rates trader which resulted in a trade of 200 BBZ6 at 97.14 arising from the matching of sell order 2 and buy order 4, and the firm, through the sydney sales desk, in executing the trade of 200 BBZ6 at 97.14 arising from the matching of sell order 2 and buy order 4, intended to exclude other market participants on 17 July 2015.","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a penalty in the amount of $50,000.","ab":"Citigroup Global Markets","firms":[7059],"id":1628},{"d":"2017-05-12","di":"2017-03-21","dr":"2017-05-12","k":"Regulatory Action","rg":"Other","reg":"Autorite Des Marches Financiers, French Financial Markets Regulator","san":"Other","os":"Settlement agreement","st":"Final","dk":"NA","al":"Failure to explicitly identify and disclose in fund offering documents structuring fees received by the firm in relation to some private debt investments;","res":"Settled","sm":"On May 12, 2017 Tikehau Investment Management signed an administrative settlement agreement pursuant to article L621-14-1 of the french monetary and finance code concluding an inspection by the french regulatory authority the AMF (autoritÉ des marches financiers) which had commenced on April 22, 2015. It should be noted that signature of an administrative settlement agreement with the regulator in France does not constitute an admission of responsibility on the part of the regulated entity. The AMF settlement procedure does not cover cases of market abuse (insider dealing, dissemination of false information and price manipulation) or offenses to market infrastructures (central securities depositories, securities settlement system operators, clearing houses and market operators). The settlement agreement provides for payment of eur 280,000 by Tikehau Investment Management, and the publication of the text of the settlement agreement on the AMF's website. The firm also gave an undertaking to take remedial action to address the point raised during the inspection and to present written evidence of that action within 2 months of the date of the settlement agreement. No information Filed","ab":"Tikehau Investment; Tikehau Investment Management","self":true,"firms":[289075,313036],"id":1629},{"d":"2017-05-04","di":"2017-05-04","dr":"2017-05-04","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Cease and Desist","st":"Final","fine":1000000.0,"dk":"R-2016-0095","al":"The Massachusetts Securities Division alleged that LPL Financial failed to supervise financial advisors located on credit union premises, including the supervision of certain compensation and certain aspects of disclosures related to its business conducted on the credit union premises.","res":"Order","sm":"On May 2, 2017, LPL submitted an offer of settlement to the division. LPL neither admitted nor denied the statement of facts and violations of law contained in the consent order related to an ongoing investigation by the division's registration, inspections, compliance and examinations section during the time period of December 27, 2011 to May 2, 2017.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1630},{"d":"2017-05-03","di":"2017-05-03","dr":"2017-05-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and untertaking","st":"Final","fine":225000.0,"dk":"20150464695-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"FINRA case number 20150464695 includes case numbers 20150465800, 20160492672, 20160494357, and 2016052372","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1631},{"d":"2017-05-02","di":"2017-05-02","dr":"2017-05-02","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"170018","al":"Firm employed one investment adviser representative in state who was not registered with state.","res":"Consent","sd":"Administrative assessment of $20000 was paid on 5.2.2017","sm":"Representative moved his office and firm failed to transfer registration to new state.","ab":"Private Advisor Group, LLC","self":true,"firms":[155216],"id":1632},{"d":"2017-05-01","di":"2017-05-01","dr":"2017-05-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"William blair was assessed a civil money penalty in the amount of $4,500,000","st":"Final","fine":4500000.0,"dk":"FILE NO. 3-17960","al":"The SEC alleged that from 2010 until 2014, as a result of erroneous payments, William blair negligently used mutual fund assets to pay for (I) distribution and marketing of fund shares outside of a written, board-approved rule 12B-1 plan and (II) sub-transfer agent (\"sub-ta\") services in excess of board-approved limits. The SEC alleged that William blair also failed to fully disclose to the funds' board of trustees that William blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the funds under a shareholder administration services agreement between certain of the funds and William blair.","res":"Decision & Order of Offer of Settlement","sd":"William blair was assessed a civil money penalty in the amount of $4,500,000 that it paid on May 8, 2017. Cease and desist proceedings were instituted pursuant to section 203(k) of the Investment Advisers Act of 1940 and section 9(f) of the Investment Company Act of 1940.","sm":"An order by the Securities and Exchange Commission (\"commission\") dated May 1, 2017 found that from 2010 until 2014, as a result of erroneous payments, William blair negligently used mutual fund assets to pay for (I) distribution and marketing of fund shares outside of a written, board-approved rule 12B-1 plan and (II) sub-transfer agent (\"sub-ta\") services in excess of board- approved limits. These payments totaled approximately $1.25 million and rendered certain of William blair funds' (\"funds\") disclosures concerning payments for distribution and sub-ta services inaccurate. As a result of this conduct, William blair violated section 206(2) of the Advisers Act and section 34(b) of the Investment Company Act, and caused the funds to violate section 12(b) of the Investment Company Act and rule 12B-1 thereunder. The SEC alleged that William blair also failed to fully disclose to the funds' board of trustees (\"board\") that William blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the funds under a shareholder administration services agreement between certain of the funds and William blair. As a result of this conduct, William blair violated section 206(2) of the Advisers Act. Without admitting or denying the findings, except as to the commission's jurisdiction over it and the subject matter of these proceedings, which are admitted, William blair consented to the entry of an order instituting cease-and-desist proceedings, pursuant to section 203(k) of the Investment Advisers Act of 1940 and section 9(f) of the Investment Company Act of 1940, making findings, and imposing a cease-and-desist order. William blair also was assessed by the commission a civil money penalty in the amount of $4,500,000.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":1633},{"d":"2017-05-01","di":"2017-05-01","dr":"2017-05-01","k":"Regulatory Action","rg":"State regulator","reg":"Vermont Securities Division","san":"Cease and Desist","st":"Final","fine":11074.81,"dk":"16-038-S","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Vermont Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Vermont representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Vermont residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Vermont residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $11,074.81. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1634},{"d":"2017-04-28","di":"2017-04-25","dr":"2017-04-28","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Pursuant to the Securities and Exchange Commission's order dated April 25, 2017 (the \"\"order\"\"), BlackRock fund advisors (\"\"bfa\"\") is to cease and desist from","st":"Final","fine":1500000.0,"dk":"3-17942","al":"\"The order specifically concerns the iShares msci russia capped ETF (\"\"russia fund ETF\"\"), managed by BlackRock fund advisors (\"\"bfa\"\") and whether it was covered by existing exemptive relief granted by Securities and Exchange Commission (\"\"SEC\"\"). In 2010, the russia fund ETF began selling its shares as the only series of shares of iShares msci russia capped ETF, inc. (\"\"russia fund company\"\"). The russia fund company did not have the required exemptive relief until January 2015. Accordingly, by operating the russia fund ETF from December 2010 to January 2015, bfa caused the russia fund company to violate the Investment Company Act.\"","res":"Order","sd":"A civil monetary penalty in the amount of $1,500,000 was paid on April 28, 2017\"","sm":"\"On April 25, 2017, bfa reached an agreement with the SEC resolving the matter regarding the russia fund ETF. Bfa, which did not admit or deny any of the SEC's findings, agreed to resolve the matter for a civil monetary penalty of $1,500,000.\"","ab":"BlackRock, Inc; BlackRock,Inc","firms":[106614,107105,290336],"id":1635},{"d":"2017-04-26","di":"2017-04-26","dr":"2017-04-26","k":"Regulatory Action","rg":"Other","reg":"Maine Office of Securities","san":"Cease and Desist","st":"Final","fine":11939.46,"dk":"16-12553","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the state of Maine Office of Securities (the office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Maine representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Maine residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Maine residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $11,939.46. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1636},{"d":"2017-04-20","di":"2017-04-20","dr":"2017-04-20","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":19710000.0,"dk":"17-009-B-FB; 17-009-CMP-FB","al":"On April 20, 2017, the Board of Governors of the Federal Reserve System and dbag entered into a consent order pursuant to section 8 of the federal deposit insurance act (12 U.S.C. § 1818) for failure to comply with section 13 of the bank holding company act of 1956 (12 U.S.C. 1851) and the regulations thereunder (the \"volcker rule\"). Specifically, the Federal Reserve determined that, as a result of the deficiencies identified in the order, dbag had not implemented a compliance program reasonably designed to ensure and monitor compliance with volcker rule requirements and had engaged in unsafe or unsound banking practices and violated provisions of the volcker rule","res":"Order","sm":"Dbag consented to the entry of the order on April 20, 2017 by the Federal Reserve, pursuant to which dbag: (a) was required to pay a civil monetary penalty of $19.71 million, which dbag paid on April 20, 2017; and (b) submit (1) a written plan to improve senior management's oversight of dbag's compliance with volcker rule requirements and (2) an enhanced written internal controls and compliance risk management program to comply with the volcker rule, in each case acceptable to the Federal Reserve bank of New York.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":1637},{"d":"2017-04-20","di":"2017-04-20","dr":"2017-04-20","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, undertaking","st":"Final","fine":136950000.0,"dk":"17-008-B-FB; 17-008-CMP-FB; 17-008-B-HC; 17-008-CMP-HC; 17-008-B-FBR; 17-008-CMP-FBR","al":"On April 20, 2017, the Board of Governors of the Federal Reserve System (the \"fed\"), dbag, DB USA corporation and dbag's New York branch (collectively, \"the bank\") entered into a consent order. Although the fed acknowledged that the bank \"fully cooperated\" with the fed and \"has made and continues to make progress in implementing enhancements to its firm-wide compliance systems and controls\", the fed found that during the review period from October 2008 through October 2013, the bank lacked adequate governance, risk management, compliance and audit policies and procedures to ensure that the bank's foreign exchange activities complied with safe and sound banking practices and applicable internal policies, which prevented the bank from detecting and addressing unsafe and unsound conduct by certain of its FX traders. As a result of this conduct, the fed found that the bank engaged in unsafe and unsound banking practices.","res":"Order","sm":"The bank consented to the entry of the order on April 20, 2017 by the fed, pursuant to which the bank: (a) shall pay a civil monetary penalty of $136,950,000, which the bank paid on April 20, 2017; (b) shall submit written plans to improve senior management oversight and the compliance risk management program, an enhanced written internal controls and compliance program, and an enhanced written internal audit program to the fed within 90 days of the order; (c) shall conduct periodic monitoring by senior management, an annual review of compliance policies and procedures and their implementation and an appropriate risk-focused sampling of other key controls, and a firm-wide risk assessment to evaluate current potential conduct risks; (d) for sub-sections b & c, shall adopt and promptly implement the approved plans and programs within 10 days of approval by the fed and thereafter fully comply with them; and (e) shall submit quarterly written progress reports to the fed.","ab":"Deutsche Bank AG (\"Dbag\"),","firms":[300838],"id":1638},{"d":"2017-04-07","di":"2017-04-07","dr":"2017-04-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":30000.0,"dk":"2015046460201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to submit to the over-the-counter (OTC) reporting facility (OTCRF) last sale reports of transactions in OTC equity securities within 10 seconds after execution. The findings stated that the firm's supervisory procedures were not reasonably designed to achieve compliance with respect to the applicable securities laws and regulations and to FINRA rules concerning late trade reporting. Specifically, the firm failed to identify, prevent and correct the firm's pattern or practice of late trade reporting resulting in violations of FINRA rule 6622(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $30,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1639},{"d":"2017-04-07","di":"2017-04-07","dr":"2017-04-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":20000.0,"dk":"2016049925401","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to execute 50 market orders in preferred securities fully and promptly. The findings stated that in 19 of those 50 transactions, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $20,000 and required to pay restitution in the total amount of $4,543.08, plus interest.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1640},{"d":"2017-04-07","di":"2016-10-03","dr":"2017-04-07","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Cease and Desist","os":"Censure, administrative fine and equitable relief","st":"Final","fine":1000000.0,"dk":"E-2016-0055","al":"The Massachusetts Securities Division alleged that Morgan Stanley Smith Barney LLC engaged in dishonest and unethical conduct in connection with an effort within the metrowest-ri complex to make lending products available to eligible customers. The Massachusetts Securities Division also alleged that this effort constituted a sales contest in contravention of Morgan Stanley Smith Barney LLC internal policy, and that the firm failed to terminate the effort immediately after it became aware of it.","res":"Settled","sm":"On April 7, 2017, Morgan Stanley Smith Barney LLC (firm) and the Massachusetts Securities Division entered into a consent order in connection with allegations that, from September 1, 2013 through April 30, 2015, the firm failed to observe high standards of commercial honor and just an equitable principles of trade, and failed reasonably to supervise, in connection with an effort within the metrowest-ri complex to make lending products available to eligible customers. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to entry of findings and the imposition of a censure and fine of $1,000,000.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1641},{"d":"2017-04-04","di":"2017-04-04","dr":"2017-04-04","k":"Regulatory Action","rg":"Other","reg":"The Federal Financial Supervisory Authority of Germany (BAFIN)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":78800.0,"dk":"WA 17-WP 3120-2015 / 0120-0124","al":"The BAFIN alleged that magim did not have procedures in place to ensure compliance with german law regarding notification to the BAFIN of significant shareholdings in german securities.","res":"Order","ab":"M&G Investment; M&G Investment Management Ltd.","self":true,"firms":[114527,283173],"id":1642},{"d":"2017-04-03","dr":"2017-04-03","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"17-9164","al":"The market regulation department of the CME Group Inc. (\"CME\") determined that certain Goldman, Sachs & co. (the \"firm\") trade data for the trade dates of January 3, 2017 through January 24, 2017 reflected a computerized trade reconstruction (CTR) error rate in excess of applicable threshold levels, in deemed violation of chicago mercantile exchange inc. rule 536.f.","res":"Decision","sm":"The CME imposed a fine on the firm in the amount of $2,500, which was paid by submission of a wire on April 5, 2017.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1643},{"d":"2017-04-03","dr":"2017-04-03","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"17-0624","al":"Alleged violation of rule 576 in that Citigroup Global Markets Inc. did not register certain tag 50 ids in the exchange fee system.","res":"Decision","sm":"Cgmi was issued a summary fine in the amount of $5,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1644},{"d":"2017-03-31","di":"2017-03-31","dr":"2017-03-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2015046456601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that failed to report information regarding purchase and sale transactions effected in municipal securities to the real-time transaction reporting system (RTRS) in the manner prescribed by municipal securities rulemaking board (MSRB) rule G-14 RTRS procedures and the RTRS users manual. The findings stated that specifically, the firm failed to report information about such transactions within 15 minutes of time of trade to an RTRS portal. The findings also stated that the firm failed to enforce its written supervisory procedures (WSPS) concerning trade reporting in municipal securities. Specifically, the firm did not conduct a \"daily to weekly\" review of the firm's order management system cancel and late trade reports as stated in its WSPS.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $20,000.","sm":"On 3/31/2017 the firm was censured and fined $20,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1645},{"d":"2017-03-30","di":"2016-08-22","dr":"2017-03-30","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"CBOT 16-0384-BC","al":"On February 22 and 23 2016, funds managed by Two Sigma Investments, LP (\"TSI\") and its affiliate held aggregated wheat futures positions in excess of the standard all month limit under Chicago Board of Trade rule 562.","res":"Settled","sd":"Monetary penalty ordered of $25,000 which was paid on March 30, 2017","sm":"On February 22 and 23 2016, funds managed by tsi and its affiliate, held aggregated wheat futures positions in excess of the standard all month limit under Chicago Board of Trade rule 562. On March 28, 2017, a panel of the Chicago Board of Trade's business conduct committee accepted tsi's offer of settlement pursuant to which tsi agreed to pay a fine in the amount of $25,000 while neither admitting nor denying any rule violation.","ab":"Two Sigma Investments, LP","self":true,"firms":[137137],"id":1646},{"d":"2017-03-27","di":"2016-06-07","dr":"2017-03-27","k":"Regulatory Action","rg":"Other","reg":"Federal Department of Finance FDF (Switzerland)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15060.0,"dk":"442.2-197 AND 442.2-231","al":"Suspected violation of art. 151 in conjunction with art. 134 of the federal act on financial market infrastructures and market conduct in securities and derivatives trading of 19 June 2015 (financial market infrastructure act, fmia; SR 958.1) in conjunction with (FORMER) art. 20 of the federal act on stock exchanges and securities trading (stock Exchange Act, sesta; ST 954.1) and art. 134 fmia (late notice filings).","res":"Settled","sd":"Fpa agreed to a reparation payment in the amount of CHF 15,000 (US$15,060). This amount was provided to fpa's legal counsel on March 28, 2017, with instructions to immediately pay the total amount to the swiss federal department of finance per the terms of our settlement agreement.","sm":"In March 2017, fpa entered into a settlement agreement with the swiss federal department of finance (\"FDF\") in connection with certain late reporting of transactions and ownership filings required pursuant to the swiss financial market infrastructure act and the swiss federal act on stock exchanges and securities trading. The transactions in question occurred during the fourth quarter of 2014 and the third quarter of 2015. Fpa acknowledged the late submissions and agreed to a reparation payment in the amount of CHF 15,000 (US$15,060). No information Filed","ab":"First Pacific Advisors, LP","self":true,"firms":[141823],"id":1647},{"d":"2017-03-16","di":"2016-08-18","dr":"2017-03-16","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"CASE-16-0487","al":"This followed an incident whereby giml executed two exchange for related position (\"EFRP\") transactions in the 10-year U.S. Treasury note futures market that were contingent upon each other for the purpose of offsetting the related position without the incurrence of market risk. A panel of the CBOT found that these transactions were transitory in nature and, therefore, were not bona fide. Additionally, the panel found that the quantity of the related position was not approximately equivalent to the quantity of the exchange component of the EFRP. The panel thus concluded that giml thereby violated CBOT rules 538.c. And 538.e.","res":"Decision & Order of Offer of Settlement","sd":"In 2017 gam international management limited agreed to an offer of settlement with the Chicago Board of Trade (\"CBOT\") in which gam international management limited neither admitted nor denied a rule violation and agreed to pay a fine of $25,000.","sm":"The offer of settlement has been agreed but not settled.","ab":"Gam London Limited","self":true,"firms":[110670],"id":1648},{"d":"2017-03-13","di":"2017-03-13","dr":"2017-03-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":300000.0,"dk":"3-17879","al":"The SEC alleged that Stifel violated section 206(4) of the Investment Advisers Act of 1940 (the \"Advisers Act\") and rule 206(4)-7 thereunder, which require investment advisers to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder.","res":"Order","sm":"In March 2017, Stifel consented to the entry of a cease and desist order (\"order\") by the SEC in which Stifel was found to have violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder by failing to adopt or implement adequate policies and procedures to track and disclose the trading away practices of certain third party investment managers in several of Stifel's discretionary wrap fee programs, including information about additional costs incurred by clients as a result of the investment manager's use of another broker to execute transactions away from Stifel. Stifel neither admitted nor denied the findings contained in the order, except those related to jurisdiction and the subject matter of the proceeding. Stifel made several undertakings enumerated in the order related to the trading away practices of third party managers, including a review and update of its policies and procedures, providing information to financial advisors and clients, and training financial advisors. Stifel was ordered to pay a civil penalty of $300,000 and ordered to cease and desist from committing or causing violations of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1649},{"d":"2017-03-09","di":"2017-03-09","dr":"2017-03-09","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"65556-S","al":"N/a","res":"Order","sd":"03/09/2017 - $10,000 administrative fine paid in full.","sm":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1650},{"d":"2017-03-06","di":"2016-09-20","dr":"2017-03-06","k":"Regulatory Action","rg":"Other","reg":"Federal Department of Finance - Switzerland (\"FDF\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000.0,"al":"The FDF alleged that Wellington had not filed, within the specified time period, reports that its collective ownership of a swiss security crossed an ownership threshold.","res":"Settled","sd":"The amount of the settlement was CHF7,000 (approximately USD7,000.)","sm":"We consented to the fine in full settlement of the matter. There were no additional conditions imposed.","ab":"Wellington Management","firms":[106595],"id":1651},{"d":"2017-03-02","di":"2017-03-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":180000.0,"dk":"2011030345701","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1652},{"d":"2017-03-01","di":"2017-03-01","dr":"2017-03-01","k":"Regulatory Action","rg":"State regulator","reg":"Ontario Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500000.0,"al":"Sentry Investments Inc. entered into a settlement agreement with staff of the OSC. The agreement was in respect of the firm's non-compliance with national instrument 81-105 - mutual fund sales practices. Pursuant to the settlement agreement, the firm agreed to pay an administrative penalty in the amount of $1,500,000, costs of the OSC investigation in the amount of $150,000 and other non-monetary terms, including submitting to a review of its practices and procedures by at third party consultant.","res":"Settled","sm":"Pursuant to the settlement agreement, the firm agreed to pay an administrative penalty in the amount of $1,500,000, costs of the OSC investigation in the amount of $150,000 and other non-monetary terms, including submitting to a review of its practices and procedures by at third party consultant. No information Filed","ab":"Sentry Investments Inc.","firms":[156752],"id":1653},{"d":"2017-02-24","di":"2017-02-24","dr":"2017-02-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":675000.0,"dk":"2013038331001","al":"Without admitting or denying any wrongdoing, JPMorgan securities LLC (JPMS) agreed to pay a $675,000 fine and enter into an acceptance waiver & consent (AWC) with FINRA resolving allegations that its misunderstanding of reporting requirements for fixed-income securities caused it to report hundreds of thousands of client-sided transactions late and incorrectly. The AWC states that from 2008 to 2013, the company violated FINRA and MSRB rules by failing to report within the 15-minute window portions of its executed transactions. When those transaction parts were eventually reported, JPMS didn't provide the correct timing of the trades. The transactions at issue involved JPMS's riskless principal transactions, which are client transactions that are bought and sold with the street and then offset with corresponding transactions with the clients. The firm timely reported the street side of those transactions to two systems - FINRA's trade reporting and compliance engine, or TRACE, and MSRB's real-time transaction reporting system, or RTRS - but not the client side transactions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent dated February 24, 2017.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1654},{"d":"2017-02-22","di":"2017-02-22","dr":"2017-02-22","k":"Regulatory Action","rg":"Other","reg":"Capital Market Authority of the Kingdom of Saudi Arabia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2666.67,"dk":"S/3/7/876/17","al":"In a letter to Goldman Sachs Saudi arabia (\"GSSA\") dated February 16, 2017, that was received by hand delivery on February 22, 2017, from the kingdom of saudi arabia capital market authority (the \"cma\"), the cma informed GSSA of a cma decision alleging a delay of more than three days in providing the cma with the certain account information required by virtue of cma circular no. s/6/6/9214/16, dated December 6, 2016, in alleged violation of section (a) of article 3 of the authorized persons regulations.","res":"Decision","sm":"Gssa agreed to the payment of a financial penalty to the cma in the amount of 10,000 saudi arabian riyals (SAR), which was paid by submission of a wire on March 1, 2017.","ab":"Goldman Sachs Saudi","firms":[361],"id":1655},{"d":"2017-02-21","di":"2016-12-07","dr":"2017-02-21","k":"Regulatory Action","rg":"Other","reg":"Frankfurt Stock Exchange","san":"Reprimand","st":"Final","dk":"H 15-2016","al":"The Frankfurt Stock Exchange (\"FSE\") sanctions committee (the \"sanctions committee\") alleged that Goldman Sachs international (\"GSI\") violated SEC. 72a of the exchange rules of the FSE by conveying certain unlabeled orders generated by algorithmic trading to the xetra trading platform of the FSE in the period from March 29, 2016 to September 20, 2016.","res":"Decision","sm":"The fse issued a reprimand to gsi, and required gsi to pay a 500 euro fee for the proceedings. In its decision, the fse noted that gsi discovered the error itself and then immediately disclosed and remedied it.","ab":"Goldman Sachs","firms":[361],"id":1656},{"d":"2017-02-17","di":"2016-06-20","dr":"2017-02-17","k":"Regulatory Action","rg":"Other","reg":"Securities and Exchange Board of India","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"EFD/DRA-III/MC/NRM/16529/2016","al":"In a notice to GS Mace Holdings Limited (\"GSMH\") and Goldman Sachs investments (MAURITIUS) I limited (\"GSIM\"), the Securities and Exchange Board of India (\"SEBI\") alleged a delay in an ownership threshold disclosure in alleged violation of regulation 7(1) of the SEBI (substantial acquisition of shares and takeover) regulations, 1997.","res":"Dismissed","sm":"On February 17, 2017, sebi notified GSMH and gsim that it has withdrawn its notice of adjudication proceedings against GSMH and gsim.","ab":"GS Mace Holdings Limited","firms":[361],"id":1657},{"d":"2017-02-16","di":"2017-02-16","dr":"2017-02-16","k":"Regulatory Action","rg":"Other","reg":"Missouri","san":"Other","os":"Monetary fine - $24,672.17 to the Missouri secretary of state investor education and protection fund","st":"Final","fine":25672.17,"dk":"AP-17-01","al":"Respondent failed to reasonably supervise the IRA distributions from 08/07/2001 to 07/29/2007 in violation of section 409.4-412(d) (9)","res":"Consent","sm":"Respondent shall maintain and enforce procedures and systems for supervising the activities of agents, employees, and Missouri office operations in a manner reasonably designed to achieve compliance with applicable state and federal securities laws and regulations, and the rules of the Financial Industry Regulatory Authority.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1658},{"d":"2017-02-15","di":"2017-02-15","dr":"2017-02-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, disgorgement/restitution","st":"Final","fine":115000.0,"dk":"20140402891-01","al":"FINRA alleged that the firm violated MSRB rules G-17, G-30(a) and G-30(b) by purchasing or selling certain municipal securities for its own account to a customer at a price that was not fair and reasonable, or including a commission or service charge that was in excess of a fair and reasonable amount.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, on February 15, 2017, Morgan Stanley Smith Barney LLC (firm) and FINRA entered into a letter of acceptance, waiver, and consent (AWC) to settle allegations that the firm violated MSRB rules G-17, G-30(a) and G-30(b) by purchasing or selling certain municipal securities for its own account to a customer at a price that was not fair and reasonable, or including a commission or service charge that was in excess of a fair and reasonable amount. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to entry of findings and the imposition of a censure and fine of $115,000, as well as agreeing to pay restitution of $57,159.52.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1659},{"d":"2017-02-14","di":"2017-02-14","dr":"2017-02-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil monetary penalty in the amount of $180,000","st":"Final","fine":180000.0,"dk":"ADMINISTRATIVE PROCEEDING NO. 3-17847","al":"On February 14, 2017, Heartland Advisors, Inc. (\"Heartland\") settled an administration proceeding brought by the SEC resolving alleged violations of sections 13(d) and 16(a) of the Securities Exchange Act of 1934 and rules 13D-1, 13D-2, 16A-2 and 16A-3 promulgated thereunder. While Heartland neither admitted nor denied the findings, Heartland agreed to the entry of a cease and desist order requiring future compliance with section 13(d) and section 16(a) and the rules cited above and payment of a $180,000 civil penalty. The order resolves allegations that Heartland failed to timely file beneficial ownership reports in violation of the aforementioned rules.","res":"Order","sd":"Payment of the $180,000 penalty was made by Heartland on February 21, 2017.","sm":"The matter was settled without admitting or denying the SEC's findings as described in items 7 and 12 above. No information Filed","ab":"Heartland Advisors, Inc.","self":true,"firms":[29433],"id":1660},{"d":"2017-02-14","di":"2017-02-14","dr":"2017-02-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, cease and desist order","st":"Final","fine":8000000.0,"dk":"3-17845","al":"Between early 2010, and MID-2015, MSSB failed to adequately implement its internal policies applicable to solicited investments in eight single inverse ETFS in some non-discretionary advisory accounts, which the SEC alleged violated the Investment Advisers Act, section 206(4) and rule 206(4)-7.","res":"Order","sm":"On February 14, 2017, the SEC instituted an order to settle an administrative action with Morgan Stanley Smith Barney LLC concerning the implementation of internal policies applicable to solicited investments in eight single inverse ETFS (SIETFS) in some non-discretionary advisory accounts from early 2010 through mid- 2015 that the SEC alleged constituted a violation of the Investment Advisers Act, section 206(4) and rule 206(4)-7. The order included a censure, cease and desist, and fine as described above.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1661},{"d":"2017-02-01","di":"2017-02-01","dr":"2017-02-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":125000.0,"dk":"2016048760501","al":"FINRA alleged that Edward jones did not adequately supervise its system for determining the interest rate applied to certain margin loans to customers in violation of NASD rule 3010(a) and FINRA rules 2010 and 3110(a).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1662},{"d":"2017-01-30","di":"2017-01-30","k":"Regulatory Action","dk":"2024-06228","ab":"Friedman, Dina, M","firms":[7691],"id":1663},{"d":"2017-01-30","di":"2017-01-30","dr":"2017-01-30","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services\" (\"DFS\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":425000000.0,"al":"On January 30, 2017, the New York state department of financial services, dbag and dbag's New York branch entered into a consent order under New York banking law §§ 33, 44 and 44a. Specifically, the DFS found that dbag suffered from serious compliance deficiencies that allowed certain bank traders and offshore entities to improperly and covertly transfer more than $10 billion out of russia, by using the services of Deutsche bank operations in moscow, London and New York to convert rubles into dollars through security trades that had no discernable economic purpose. The DFS found that dbag and dbag's New York branch conducted their banking business in an unsafe and unsound manner, in violation of New York banking law §§ 44, 44a, failed to maintain an effective money laundering program, in violation of 3 N.Y.C.R.R. § 116.2, and failed to maintain and make available true and accurate books, accounts and records reflecting all transactions and actions, in violation of New York banking law § 200c.","res":"Order","sm":"Dbag and dbag's New York branch consented to the entry of the order on January 30, 2017 by the DFS, pursuant to which dbag and dbag's New York branch: (a) shall pay a civil monetary penalty of $425 million, which dbag paid on February 3, 2017; and (b) engage an independent monitor within 60 days of the order to conduct a comprehensive review of existing BSA/AML compliance programs, policies and procedures in place at the bank that pertain to or affect activities conducted by or through (a) Deutsche bank trust company americas and (b) dbag's New York branch, recommend corrective actions, and oversee the implementation of corrective actions the DFS deems necessary.","ab":"Deutsche Bank AG\"","firms":[300838],"id":1664},{"d":"2017-01-30","di":"2017-01-30","dr":"2017-01-30","k":"Regulatory Action","rg":"U.K. FCA","reg":"Financial Conduct Authority\" (\"FCA\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":163076224.0,"al":"On January 30, 2017, the financial conduct authority (\"FCA\") entered a final notice under principle 3 (management and control) and senior management arrangements, systems and controls (SYSC) rules 6.1.1 r and 6.3.1 r between January 1, 2012 and December 31, 2015 (the relevant period). Specifically, the FCA found that with respect to dbag, the AML control framework was substantially inadequate, and the risks raised were highlighted by certain trading arranged by Deutsche bank's russia-based subsidiary (DB moscow) and booked to Deutsche bank's trading books in London. The FCA found that the way these trades were conducted in combination with their scale and volume were highly suggestive of financial crime. The FCA found that the suspicious securities trades, which it referred to as \"mirror trades,\" were used by customers of Deutsche bank and DB moscow that were connected to each other to transfer more than usd 6 billion from russia, through Deutsche bank in the UK, to overseas bank accounts. The orders for both sides of the mirror trades were received by DB moscow, which executed both sides at the same time. The FCA found that dbag breached principle 3 and SYSC rules 6.1.1. R and 6.3.1 r in that, during the relevant period, in its corporate banking & securities division business, (1) its \"customer due diligence (\"CDD\") and enhanced due diligence (\"EDD\") was inadequate in that it failed to obtain sufficient information about its customers to inform the risk assessment process and to provide a basis for transaction monitoring; (2) its culture failed to instill a sense of responsibility in the front office business for the identification and management of non-financial risks, particularly in the London front office, which failed to appreciate that it was ultimately responsible for Deutsche bank's kyc obligations; (3) it used flawed AML customer and country risk rating methodologies which meant that customers were assigned inappropriate risk ratings; (4) its AML policies and procedures were deficient; (5) its AML it infrastructure was inadequate and failed to provide a single authoritative repository of kyc information; (6) it lacked automated AML systems for detecting suspicious trades and lacked an effective system for monitoring money flows associated with transactions; and (7) it failed to provide adequate oversight of trades booked in the UK by the moscow front office as well as other non-UK transactions.","res":"Order","sm":"Dbag consented to the entry of the final notice on January 30, 2017 by the FCA, pursuant to which dbag shall pay a civil monetary penalty of £163,076,224, which dbag paid on February 1, 2017.","ab":"Deutsche Bank AG","firms":[300838],"id":1665},{"d":"2017-01-27","di":"2016-12-01","dr":"2017-01-27","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Restitution","os":"Cease and desist, censure, monetary fine, disgorgement, internal investigation","st":"Final","fine":975000.0,"dk":"E-2016-0039","al":"The enforcement section alleges that LPL advisor, roger s. Zullo, fabricated the suitability profiles of numerous LPL clients, selling them scores of large, illiquid, unsuitable, high commission variable annuities, at substantial upfront profits to himself and LPL, in violation of sections 101, 102, and 204(a)(2)(g) of the act. The enforcement section further alleges that LPL failed in its responsibility to supervise roger s. Zullo, in violation of section 204(a)(2)(j).","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1666},{"d":"2017-01-27","di":"2017-01-27","k":"Regulatory Action","dk":"PLBS 11034-A (AR)","ab":"Dehn, Daryl, W","firms":[7691],"id":1667},{"d":"2017-01-26","di":"2017-01-26","dr":"2017-01-26","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, disgorgement, civil penalty","st":"Final","fine":80000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17815","al":"On January 26, 2017, Palestra voluntarily agreed, without admitting or denying any allegations, to a settlement with the SEC relating to rule 105 of Regulation M under the Securities Exchange Act of 1934 (\"rule 105\"). Rule 105 applies irrespective of any intent to violate the rule.","res":"Decision & Order of Offer of Settlement","sd":"Palestra agreed to pay a total of $180,968 in disgorgement, interest and penalities. Palestra made such payments on January 31, 2017.","sm":"Order is final and the disgorgement, interest and penalties have been paid by Palestra on January 31, 2017. No information Filed","ab":"Palestra Capital Management LLC","self":true,"firms":[160535],"id":1668},{"d":"2017-01-25","di":"2017-01-17","dr":"2017-01-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist undertaking","st":"Final","fine":340000.0,"dk":"3-17786","al":"G g y (y p p p ) the U.S. Securities and Exchange Commission (\"SEC\") found that a historic version of BlackRock inc.'s (\"BlackRock\") form employee separation and release agreement (\"agreement\") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The agreement, which was in use between October 2011 and March 2016, did not prohibit former employees from reporting alleged wrongdoing to the SEC. however, employees who accepted a voluntary separation payment from BlackRock waived their right to recover a monetary reward from the SEC in connection with its whistleblowing program. BlackRock stopped using the agreement at issue before being contacted by the SEC and the SEC was unaware of any instances in which former BlackRock employees were prevented from communicating with the SEC.","res":"Order","sd":"BlackRock paid the $340,000 civil monetary penalty on January 25, 2017.","sm":"On January 17, 2017, BlackRock inc. reached an agreement with the SEC to resolve allegations that a historic version of BlackRock's form employee separation and release agreement (\"agreement\") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The settlement with the SEC included a $340,000 payment, which was paid on January 25, 2017. BlackRock also agreed to notify former employees who signed an agreement to advise them that BlackRock does not prevent former employees from collecting a monetary award for reporting information to the SEC under its whistleblower program.","ab":"BlackRock, Inc.","firms":[106614],"id":1669},{"d":"2017-01-25","di":"2017-01-17","dr":"2017-01-25","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist undertaking","st":"Final","fine":340000.0,"dk":"3-17786","al":"The U.S. Securities and Exchange Commission (\"SEC\") found that a historic version of BlackRock inc.'s (\"BlackRock\") form employee separation and release agreement (\"agreement\") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The agreement, which was in use between October 2011 and March 2016, did not prohibit former employees from reporting alleged wrongdoing to the SEC. however, employees who accepted a voluntary separation payment from BlackRock waived their right to recover a monetary reward from the SEC in connection with its whistleblowing program. BlackRock stopped using the agreement at issue before being contacted by the SEC and the SEC was unaware of any instances in which former BlackRock employees were prevented from communicating with the SEC.","res":"Order","sd":"BlackRock paid the $340,000 civil monetary penalty on January 25, 2017.","sm":"On January 17, 2017, BlackRock inc. reached an agreement with the SEC to resolve allegations that a historic version of BlackRock's form employee separation and release agreement (\"agreement\") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The settlement with the SEC included a $340,000 payment, which was paid on January 25, 2017. BlackRock also agreed to notify former employees who signed an agreement to advise them that BlackRock does not prevent former employees from collecting a monetary award for reporting information to the SEC under its whistleblower program.","ab":"BlackRock, Inc.","firms":[107105,282125,290336],"id":1670},{"d":"2017-01-24","di":"2017-01-24","dr":"2017-01-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":2250000.0,"dk":"3-17809","al":"From August 2010 to July 2011, Citigroup global markets, inc. developed a foreign exchange trading program, known as citifx alpha; Citigroup global markets, inc. provided written materials and oral presentations that were rendered materially misleading and failed to adequately disclose to the 15 relevant investors that they could be placed into a program using leverage and that mark-ups would be charged on each trade. MSSB financial advisors did not question the materials provided by Citigroup global markets, inc.","res":"Decision","sm":"On January 24, 2017, the U.S. Securities and Exchange Commission issued an order instituting cease and desist proceedings and imposing the following sanctions: disgorgement of $624,458.27, prejudgment interest of $89,277.34 and civil money penalty of $2,250,000 in connection with the above allegations.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1671},{"d":"2017-01-20","di":"2017-01-25","dr":"2017-01-20","k":"Regulatory Action","rg":"Other","reg":"Securities and Futures Commission of Hong Kong (\"SFC\")","san":"Reprimand","st":"Final","fine":516000.0,"al":"The SFC reprimanded and fined Value Partners Limited (\"VPL\") and Value Partners Hong Kong Limited (\"VPHK\") pursuant to section 194 of the securities and futures ordinance. The issues that arose were in respect of two of the funds namely Value Partners China greenchip fund limited, managed by VPL, and Value Partners greater China high yield income fund, managed by VPHK, had issued shares in excess of their authorized share capital as provided in their memorandum and articles of association. The issues were rectified with remedial actions taken and there were no apparent investor losses. Details can be found in SFC website: HTTP://www.sfc.hk/edistributionweb/gateway/en/news-and-announcements/news/doc? Refno=17PR13","res":"Settled","sd":"VPL and VPHK each paid a fine of $HK2MILLION on 18 jan 2017 and SFC acknowledged receipt on 20 jan 2017.","sm":"The issues were rectified with remedial actions taken and there were no apparent investor losses. Value Partners had, among other things, increased the authorised share capital of the two funds in their memorandum and articles of association through ordinary resolutions of their shareholders. No information Filed","ab":"Value Partners Hong Kong Limited","firms":[143177],"id":1672},{"d":"2017-01-19","di":"2017-01-19","k":"Regulatory Action","dk":"OFR FILE NO.: 93747","ab":"Chang, Warren","firms":[7691],"id":1673},{"d":"2017-01-17","di":"2017-01-17","dr":"2017-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure","st":"Final","fine":75000.0,"dk":"FILE NO: 3-17780","al":"Alleged violations of section 206(4) of the Advisers Act and rule 206(4)-5 thereunder, which makes it unlawful for any investment adviser registered with the SEC to provide investment advisory services for compensation to a government entity within two years after a contribution to an official of the government entity is made by the investment adviser or any covered associate of the investment adviser.","res":"Settled","sd":"Civil monetary penalty of $75,000 which was paid on January 24, 2017.","sm":"The action was resolved pursuant to a January 17, 2017 SEC order: in the matter of The Banc Funds Company, L.L.C., administrative proceeding file no. 3-17780. Pursuant to this order, The Banc Funds Company, L.L.C. Was ordered to 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)-5 thereunder. The Banc Funds Company, L.L.C. Was censured pursuant to this order. Additionally, The Banc Funds Company, L.L.C. Was ordered to pay a civil monetary penalty in the amount of $75,000 to the SEC. No information Filed","ab":"The Banc Funds Company, L.L.C.","self":true,"firms":[106305],"id":1674},{"d":"2017-01-17","di":"2017-01-17","dr":"2017-01-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 4608","al":"On January 17, 2017, the SEC instituted administrative proceedings against the registrant, pursuant to section 203(e) and 203(k) of the Advisers Act, finding that the registrant had violated Advisers Act rule 206(4)-5 when a former employee made a $500 personal political contribution to a candidate for the democratic party nomination for governor of Massachusetts (the \"contribution\") while the registrant advised a fund where a Massachusetts government entity (the \"investor\") was an investor. The SEC found that, after the contribution was made, its return was sought and received, and noted that Advisers Act rule 206(4)-5 does not require a showing of quid pro quo or actual intent to influence an elected official or candidate.","res":"Order","sd":"Without admitting to any allegations, the registrant consented to the issuance of an order and paid a civil money penalty of $75,000 on January 18, 2017.","sm":"On January 17, 2017, the registrant and the U.S. Securities and Exchange Commission (the \"commission\") entered into a settlement regarding a previously reported campaign contribution by a former employee made in violation of the commission's rules governing political contributions by investment adviser employees and the registrant's own compliance policies. Without admitting or denying liability, the registrant agreed to pay $75,000 to resolve this matter. The $500 contribution in question was to the sister of a personal friend of the former employee. The friend's sister was trying, unsuccessfully, to enter one of the gubernatorial primaries in Massachusetts. The contribution was made over two years after a Massachusetts pension fund first invested with the registrant's funds. The former employee requested that the contribution be returned, and it was refunded. The registrant was unaware of the contribution at the time it was made. Upon learning of the contribution, the registrant filed an exemption application with the commission's division of investment management stating that it should not bear any liability for its former employee's error. As made clear in the exemption application, the $500 contribution, which was $350 greater than permitted by commission rules, was made by a former employee who was not a member of the registrant's investor relations group and was not responsible for securing or retaining investments in the registrant's funds. The contribution was made in direct violation of the registrant's written compliance policies and was contrary to a subsequent certification by the employee that he had complied with the registrant's policies governing political campaign contributions. Moreover, at precisely the same time as the unreported contribution, the registrant's chief executive officer william a. Ackman requested permission from the registrant's compliance group to make an identical contribution to the same person in Massachusetts. When informed of the $150 limit, MR. ackman made a $150 contribution, as permitted by law. The order settling this matter briefly describes the circumstances that serve as the basis for the violation, which are set forth in greater detail in the registrant's exemption application and which, as of the date hereof, is available on the commission's website. The order also finds that the rule in question does not require a showing of actual intent to influence a candidate for elected office, and that the commission was not required to show that the registrant was even aware that it was violating the rule. The registrant follows rigorous compliance procedures, takes all reasonable steps to enforce its policies, and carefully trains and periodically reminds all employees and related parties of those policies. No information Filed","ab":"Pershing Square Capital Management, L.P.","self":true,"firms":[132982],"id":1675},{"d":"2017-01-13","dr":"2017-01-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty and undertakings","st":"Final","fine":13000000.0,"dk":"3-17773","al":"The SEC found that from 2009 through 2015, MSSB inadvertently charged advisory fees in excess of what had been disclosed to, and agreed to by, its legacy CGM clients, and, from 2002 to 2009 and from 2009 to 2016, MS&co. and MSSB, respectively, inadvertently charged fees in excess of what was disclosed to and agreed to by their clients. The SEC also found that MSSB failed to comply with requirements regarding annual surprise custody examinations for the years 2011 and 2012, did not maintain certain client contracts, and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Investment Advisers Act of 1940 (the \"Advisers Act\"). The SEC found that MSSB willfully violated sections 204(a), 206(2) and 206(4) of the Investment Advisers Act of 1940 and rules 204-2(a)(10), 204-2(e)(1), 206(4)-2 and 206(4)-7 thereunder.","res":"Order","sm":"In determining to accept the offer resulting in the January 13, 2017 order, the SEC considered the remedial efforts promptly undertaken by MSSB.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1676},{"d":"2017-01-12","di":"2017-01-12","dr":"2017-01-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil monetary penalty","st":"Final","fine":6600000.0,"dk":"SEC RELEASE NO. 34-79777; ADMINISTRATIVE PROCEEDING FILE NO. 3-17768","al":"The SEC staff alleged violations of sections 13(b)(2)(a) & (b) of the Securities Exchange Act of 1934 for books and records and internal regulatory accounting control deficiencies in connection with the calculation of risk-based regulatory capital ratios presented in annual and quarterly reports filed with the SEC.","res":"Order","sd":"A civil money penalty in the amount of $6,600,000. BNY mellon will effect payment on a date TBD.","sm":"Provided). This action arises out of the SEC's assertion that BNY mellon failed to properly include approximately $14 billion of certain assets of variable interest entities (the \"vies\") in its calculation of risk-based regulatory capital ratios presented in annual and quarterly reports filed with the SEC. beginning in the third quarter of 2010, the SEC found that BNY mellon was required to consolidate the accounts of certain vies - which took the form of collateralized loan obligations (\"CLOS\") - onto its balance sheet pursuant to applicable guidance issued by the financial accounting standards board in June 2009 (now codified in asc 810). As a result of asc 810, it was determined that risk-based capital rules required BNY mellon to include the assets of these vies in its risk-weighted assets for purposes of calculating its regulatory capital ratios. As the SEC order relates, BNY mellon, however, deviated from the regulatory capital rules without the necessary authorization from the Federal Reserve board and excluded these assets from its regulatory capital ratios after making a determination that the vies did not pose a risk to the firm. The SEC found that (1) BNY mellon's exclusion of the vies caused the firm to misreport its risk-based regulatory capital ratios in each of its quarterly and annual reports from the third quarter of 2010 through the first quarter of 2014, (2) throughout this time period, BNY mellon failed to make and keep accurate books and records with respect to its risk-weighted assets and regulatory capital ratios, and (3) BNY mellon also failed to devise and maintain a system of internal regulatory accounting controls sufficient to provide reasonable assurances that its financial statements were prepared in conformity with applicable criteria. On January 12, 2017, the SEC announced that it had entered into an administrative settlement on a neither-admit-nor-deny basis with BNY mellon in which BNY mellon agreed to pay $6.6 million.","ab":"The Bank of New York; The Bank of New York Mellon; The Bank of New York Mellon Corporation","firms":[231,105642,111208,145995],"id":1677},{"d":"2017-01-11","di":"2017-01-11","dr":"2017-01-11","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":900000.0,"dk":"CFTC DOCKET NO 17-04","al":"On January 11, 2017, the Commodity Futures Trading Commission (\"CFTC\") entered an order instituting proceedings pursuant to sections 6(c) and 6(d) of the commodity Exchange Act, making findings and imposing remedial sanction (\"order\") that finds that during the period 2010-2014, JPMS failed to diligently supervise its officers', employees', and agents' processing of exchange and clearing fees (\"exchange fees\") it charged certain customers in connection with futures and options transactions, in violation of regulation 166.3.","res":"Order","sm":"Without admitting or denying any of the findings or conclusions, JPMS consented to the entry of the order. The allegations, dispositions, findings and sactions of the order are described above in items 7 and 12.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1678},{"d":"2017-01-11","di":"2017-01-11","k":"Civil Judicial Action","st":"Pending","al":"Claimant alleges registered representative breached fiduciary duties in connection with her accounts. Activity dates 2004-2010.","ab":"Cohen, Rose","firms":[7059],"id":1679},{"d":"2017-01-04","di":"2017-01-04","dr":"2017-01-04","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Mississippi Secretary of State","san":"Other","os":"None stated","st":"Final","fine":50000.0,"dk":"LS-14-0977-A; LS014-0977-B; LS-15-1435; LS-15-1463","al":"On January 4, 2017, an administrative consent order (\"order\") was entered against Stifel, Nicolaus & Company, inc. (\"Stifel nicolaus\") and a former registered representative associated with Stifel nicolaus by the Securities Division of the Mississippi Secretary of State (\"division\") resolving an investigation into certain activities occurring in two branch offices during the period of September 2000 through November 2013. Without admitting or denying the findings in the order, Stifel nicolaus agreed to the entry of the order directing Stifel nicolaus to cease and desist from violating rule 5.15 of the Mississippi Securities Act of 2010, a books and records rule, and to pay the division $49,500 on its behalf as well as $500 on behalf of the former registered representative.","res":"Order","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1680},{"d":"2017-01-03","di":"2017-01-03","dr":"2017-01-03","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Bureau of Securities Regulation","san":"Restitution","os":"In addition to the agreement to repurchase certain auction rate securities (\"ARS\") sold to eligible investors prior to February","st":"Final","fine":97706.22,"dk":"12009000013","al":"The investigation concerned alleged misrepresentations and omissions in connection with the marketing, sale and distribution of auction rate securities.","res":"Consent","sm":"The action related to allegations with respect to misrepresentations and omissions in connection with the marketing, sale and distribution of auction rate securities. As described herein, the principal terms of the settlement were negotiated with the nyag and the state of Florida office of financial regulation on behalf of the nasaa task force that contemplates separate similar agreements with other states.","ab":"JPMorgan Chase & Co.","firms":[79,20989,134776,135960],"id":1681},{"d":"2016-12-29","di":"2016-12-29","dr":"2016-12-29","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"FILE NO. 15-0020 / 20150442656 AND 20150466721","al":"The business conduct committee of the Chicago Board Options Exchange, Incorporated (\"CBOE\") alleged that, from in or about January 1, 2009 through on or about June 15, 2015, Merrill lynch, (1) on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available and, on numerous occasions, failed to use due diligence to execute orders at the best prices available in violation of CBOE rules 6.45a, 6.45b and 6.73, and (2) failed to supervise its associated persons to assure compliance with CBOE rules 6.45a, 6.45b, and 6.73 in connection with the above mentioned conduct in violation of CBOE rule 4.2.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the violations alleged in the statement of charges and letter of consent, Merrill lynch agreed to a $7,500 fine and a censure.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1682},{"d":"2016-12-22","di":"2016-12-07","dr":"2016-12-22","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"16-8954","al":"CME Group Inc. (\"CME\") market regulation issued a summary fine notice to Goldman, Sachs & co. (the \"firm\") stating that CME market regulation discovered that the firm failed to maintain a complete audit trail with respect to certain trading systems for a minimum of five years in violation of CME rule 536.B.2.","res":"Decision","sm":"The summary fine, in the amount of $5,000, was paid by submission of a wire on December 22, 2016.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1683},{"d":"2016-12-21","di":"2016-12-21","dr":"2016-12-21","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / undertaking","st":"Final","fine":120000000.0,"dk":"17-03","al":"On December 21, 2016, the Commodity Futures Trading Commission (\"CFTC\") entered an order instituting proceedings pursuant to sections 6(c) and 6(d) of the Commodity Exchange Act, making findings and imposing remedial sanctions (the \"order\") against The Goldman Sachs Group, inc. (\"GS group\") and Goldman, Sachs & co. (the \"firm\", and together with GS group, \"Goldman\") relating to attempted manipulation of the U.S. dollar international swaps and derivatives association fix (\"usd isdafix\"), an interest rate benchmark. Specifically, the CFTC found that, from January 2007 through March 2012, certain traders on the firm's interest rate products trading desks submitted bids and offers, and executed trades, that were designed to attempt to manipulate the usd isdafix. In addition, the CFTC found that these traders attempted to affect the rate at which usd isdafix was set by making false, misleading, or knowingly inaccurate submissions to certain swaps brokers for inclusion in the calculation of the daily rates. The order also states that the traders submitted oral and written requests for certain rates to be submitted, which would benefit the firm's trading positions. The CFTC found that Goldman violated Commodity Exchange Act sections 6(c), 6(d), and 9(a)(2), 7 U.S.C. §§ 9, 13b, 13(a)(2) (2006), and for conduct occurring on or after August 15, 2011, sections 6(c)(1), 6(c)(1)(a), 6(c)(3), 6(d), and 9(a)(2), 7 U.S.C. §§ 9(1), 9(1)(a), 9(3), 13b, 13(a)(2) (2012), and CFTC regulations 180.1(a) and 180.2, 17 C.F.R. §§ 180.1(a), 180.2 (2015).","res":"Order","sm":"Without admitting or denying the violations, Goldman consented to the entry of the order on December 21, 2016 by the CFTC, pursuant to which Goldman: (a) shall cease and desist from violating Commodity Exchange Act sections 6(c)(1), 6(c)(1)(a), 6(c)(3), 6(d), and 9(a)(2), 7 U.S.C. §§ 9(1), 9(1)(a), 9(3), 13b, 13(a)(2) (2012), and CFTC regulations 180.1(a) and 180.2, 17 C.F.R. §§ 180.1(a), 180.2 (2015); (b) pay a civil monetary penalty of $120 million, which the firm paid on December 28, 2016; and (c) comply with the undertakings set forth in the order, including providing a report to the CFTC within 120 days of the order, addressing remediation efforts both prior to and since the entry of the order, and providing an additional report to the CFTC, no later than 365 days of the entry of the order, explaining how it has complied with the undertakings set forth in the order.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1684},{"d":"2016-12-21","di":"2016-12-21","dr":"2016-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":900000.0,"dk":"2015045887301","al":"Without admitting or denying the findings, LPL Financial LLC (\"the firm\") consented to the sanctions and to the entry of findings that it failed to send and create records that it had sent to customers, more than 1.6 million account notices required under rule 17A-3(a)(17) of the Exchange Act. The firm is required to send these account notices to customers at 36 month intervals for each account in which a suitability determination was made. Over a seven-year period, the firm failed to send over 25 percent of the required notices. In addition, the firm failed to establish, maintain, and enforce a supervisory system and written supervisory procedures reasonably designed to achieve compliance with applicable laws and regulations in relation to the creation and distribution of such account records.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1685},{"d":"2016-12-21","di":"2016-12-21","dr":"2016-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":750000.0,"dk":"2014043539001","al":"Without admitting or denying the findings, LPL Financial LLC (\"the firm\") consented to the sanctions and to the entry of findings that it failed to maintain over 18.3 million electronic communications in non-erasable and no re-writable format, known as worm (\"write once, read many\") format. The findings stated that the worm format is intended to prevent the alteration or destruction of broker dealer records maintained on electronic storage media. In addition, the firm failed to retain check registers in worm format. The findings also stated that the firm's written supervisory procedures failed to have an adequate supervisory process concerning worm compliance.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1686},{"d":"2016-12-21","di":"2016-12-21","dr":"2016-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":1500000.0,"dk":"2016050274801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, with two other firms, failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, known as worm \"write once, read many\" format. The findings stated that worm format is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the firm, with the other two firms, failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of the accounts. The findings also included that the firm failed to notify FINRA, its designated examining authority, at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA found that the firm failed to implement an audit system for those records they failed to maintain in worm format. FINRA also found that the firm failed to provide its third-party vendors full access to, and the ability to download information from, its electronic storage systems. In addition, FINRA determined that the firm failed to implement an adequate supervisory system, and failed to enforce written procedures, concerning the firm's ready access to electronic broker-dealer records and its storage of such records in worm format.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors; Wells Fargo Clearing","firms":[11025,19616],"id":1687},{"d":"2016-12-21","di":"2016-12-21","dr":"2016-12-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":3500000.0,"dk":"2016049821601","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1688},{"d":"2016-12-20","di":"2016-12-20","dr":"2016-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2015046471201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed, within 10 seconds after execution, to transmit last sale reports of transactions in NMS securities to the FINRA/Nasdaq trade reporting facility (FNTRF) and failed to report the correct time of execution to the FNTRF in that it failed to append the stop stock time on last sale reports of transactions in NMS securities. The findings stated that the firm failed to adequately supervise its trade reporting and input of trade data to the FNTRF.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to a censure and fine of $20,000.","sm":"The firm was censured and fined $20,000. The fine was paid January 18 2017.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1689},{"d":"2016-12-19","di":"2016-12-19","dr":"2016-12-19","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":800000.0,"dk":"CFTC DOCKET NO. 17-02","al":"On December 19, 2016 Convergent Wealth advisors, LLC agreed to a civil monetary penalty without admitting or denying the findings and conclusions in the order of settlement of $800,000 issued by the U.S. Commodity Futures Trading Commission arising out of with the fraudulent omissions and false statements of an employee related to the employee's outside business activities. The employee is no longer with Convergent Wealth advisors, LLC.","res":"Settled","ab":"Convergent Wealth","firms":[31194],"id":1690},{"d":"2016-12-16","di":"2016-12-06","dr":"2016-12-16","k":"Regulatory Action","rg":"Other","reg":"Japanese Financial Services Agency (FSA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1864582.0,"al":"The Japanese FSA found that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would \"mislead others into believing sales and purchases of the shares [of seibu holdings inc.] were thriving and would cause fluctuations in the market of the shares.\" As such, the FSA found that the employee's trading violated article 159(2) (I) of the financial instruments and Exchange Act.","res":"Decision","sm":"On December 16, 2016, Morgan Stanley MUFG securities co., LTD. (MSMS) became subject to a summary order by the Japanese financial services agency for payment of an administrative monetary penalty of jpy 219,880,000 (approx. $1,864,582 usd) in connection with findings that that an employee's quoting and trading activities on the tokyo stock exchange on 14 days in September and October 2015 would \"mislead others into believing sales and purchases of the shares [of seibu holdings inc.] were thriving and would cause fluctuations in the market of the shares\" and therefore constituted a violation of article 159(2)(I) of the financial instruments and Exchange Act.","ab":"Morgan Stanley MUFG","firms":[149777],"id":1691},{"d":"2016-12-15","di":"2016-12-15","dr":"2016-12-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":30000.0,"dk":"2015043999801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it exceeded the relevant position limit in two different securities for two different customers (exceeding the relevant position limit in a range of between 102.5% and 538.5%) for five days, respectively. The findings stated that the firm failed to maintain an adequate system of supervision, including systems of follow-up and review, which were reasonably designed to achieve compliance with the rules governing the reporting of options position limits to the large options position reports (LOPR) system.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $30,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1692},{"d":"2016-12-14","di":"2016-12-14","dr":"2016-12-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil money penalty, censure","st":"Final","fine":275000.0,"dk":"FILE NO. 3-17722","al":"The settlement order, entered by the Securities and Exchange Commission on December 14, 2016 (the \"settlement order\"), arose from investments made by two private funds (collectively, the \"NSR funds\") advised by New Silk Route Advisors, L.P. (\"NSR\") in four portfolio companies in which another private equity fund (the \"related fund\") advised by vedanta management, L.P., an investment adviser affiliated with NSR also invested (such investments, the \"co-investments\"). The settlement order included findings that (1) NSR failed to obtain the limited partner advisory board consents for the co-investments required under the NSR funds' limited partnership agreements and (2) NSR did not adopt or implement written policies and procedures reasonably designed to prevent violations. As a result, the settlement order finds that NSR violated sections 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended, and rule 206(4)-8 thereunder. NSR consented to the settlement order without admitting or denying the SEC's findings.","res":"Settled","sd":"Pursuant to the settlement order, NSR was ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended, and rules 206(4)-7 and 206(4)-8 thereunder, and agreed to pay a civil money penalty of $275,000. NSR was also censured pursuant to the terms of the settlement order.","sm":"Pursuant to the settlement order, NSR was ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended, and rules 206(4)-7 and 206(4)-8 thereunder, and agreed to pay a civil money penalty of $275,000. NSR was also censured pursuant to the terms of the settlement order. The settlement order provides that payment shall be made within 15 days of the entry of the order. No claims were made against any of NSR's advisory affiliates.","ab":"New Silk Route Advisors, L.P.","self":true,"firms":[161339],"id":1693},{"d":"2016-12-08","di":"2016-07-07","dr":"2016-12-08","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":35000.0,"dk":"16-0021/ 20150459492","al":"The business conduct committee of the Chicago Board Options Exchange, Incorporated (\"CBOE\") alleged that, from in or about March 2012 through in or about March 2013, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") (1) mismarked numerous orders as short exempt when the subject orders did not satisfy the requirements of Regulation SHO rule 201 in violation of CBOE rule 4.2, section 17(a) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3 thereunder, and Regulation SHO rules 200 and 201, (2) failed to have adequate supervisory policies and procedures to identify short exempt orders that were not eligible for such marking and failed to regularly surveil to ascertain the effectiveness of the policies and procedures required by Regulation SHO rule 201 and take prompt action to remedy deficiencies in such policies and procedures in violation of CBOE rule 4.2 and Regulation SHO rule 201, and (3) failed to adequately supervise to assure compliance with the requirements of rules 200 and 201 of Regulation SHO pertaining to the accurate marking of sale orders in violation of CBOE rule 4.2.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the violations alleged in the statement of charges, Merrill lynch agreed to a $35,000 fine and a censure. The fine was paid on January 4, 2017.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1694},{"d":"2016-12-07","di":"2016-12-07","dr":"2016-12-07","k":"Regulatory Action","rg":"Other","reg":"The European Commission (\"The Commission\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":37802250.0,"al":"In December 2016, the european commission (the 'commission') issued a decision that in early 2007 HSBC, among other banks, colluded on euro interest rate derivative pricing elements, and exchanged related sensitive information, in breach of EU antitrust rules. The commission determined that the duration of HSBC's infringement was 1 month and fined HSBC 33,606,000 euros. HSBC appealed the decision to the general court of the european union, which in 2019 annulled the fine for failure to provide reasons, but upheld HSBC's liability. In 2021 the european commission imposed a revised fine of 31,700,000 euros (usd $37,802,250 which utilizes the closing FX rate as of the date of issuance for the amended fine and as reflected in section 12.a ). HSBC appealed to the liability findings to the court of justice of the european union, which upheld HSBC's liability in January 2023. HSBC continues to maintain an appeal before the general court against the 2021 commission decision imposing a revised fine.","res":"Other","sd":"HSBC continental europe in accordance with the 2021 decision paid a fine in the amount of 31,700,000 euros. See information with respect to the appeal above. The fine is converted to usd $37,802,250 (closing FX rate as of the date of issuance for the amended fine) as reported above in section 12.a.","sm":"HSBC paid the revised fine of 31,700,000 euros (usd $37,802,250 which utilizes the closing FX rate as of the date of issuance for the amended fine and as reflected in section 12.a ) in 2021. In November 2024, the general court dismissed HSBC's appeal against the fine","ab":"HSBC Holdings PLC","firms":[154700,324468],"id":1695},{"d":"2016-12-07","di":"2016-12-07","dr":"2016-12-07","k":"Regulatory Action","rg":"Other","reg":"The European Commission (The \"Commission\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":378022500.0,"al":"In December 2016, the european commission (the 'commission') issued a decision that in early 2007 HSBC, among other banks, colluded on euro interest rate derivative pricing elements, and exchanged related sensitivei nformation, in breach of EU antitrust rules. The commission determined that the duration of HSBC's infringementwas 1 month and fined HSBC 33,606,000 euros. HSBC appealed the decision to the general court of the european union, which in 2019 annulled the fine for failure to provide reasons, but upheld HSBC's liability. In 2021 the european commission imposed a revised fine of 31,700,000 euros (usd $37,802,250 which utilizes the closing FX rate as of the date of issuance for the amended fine and as reflected in section 12.a). HSBC appealed to the liability findings to the court of justice of the european union, which upheld HSBC's liability in January 2023. HSBC continues to maintain an appeal before the general court against the 2021 commission decision imposing a revised fine. It should be noted that both HSBC (on liability) and the commission (on whether it adequately explained the fine quantum) are appealing to the court of justice of the european union.","res":"Settled","sm":"HSBC paid the revised fine of 31,700,000 euros (usd $37,802,250 which utilizes the closing FX rate as of the date of issuance for the amended fine and as reflected in section 12.a) in 2021. In November 2024, the general court dismissed HSBC's appeal against the fine.","ab":"HSBC Holdings PLC","firms":[172522],"id":1696},{"d":"2016-12-05","di":"2016-12-05","dr":"2016-12-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":1000000.0,"dk":"2015043740201","al":"Without admitting or denying the findings, the firm and its affiliate consented to the sanctions and to the entry of findings that they failed to establish, maintain, and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through a particular application (the application) that the firms made available to their registered representatives. The findings stated that the firm and its affiliate permitted their registered representatives to use up to 10 or more different applications to create consolidated reports, including the application. The application was the most widely used consolidated reporting application at the firms. The findings also stated that when preparing application reports, the firms' representatives were permitted to manually enter information regarding customers' external accounts, assets and liabilities into a centralized assets and liabilities table, which the firms maintained. The application would pull that information from the table to populate the application reports, including those that were then sent to the firms' customers. The firms reviewed a random sampling of only 2 percent of the application reports. The firm and its affiliate did not, and had no system in place to, review the contents of the application reports, including information about customers' holdings away from the firms. The findings also included that the firms' supervisory systems and procedures were inadequate because there was no mechanism allowing their representatives to designate which application reports were actually provided to customers. The firms could not distinguish between draft application reports and reports that were completed and sent to customers, which should have been subjected to the firms' supervisory systems designed to review customer communications.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors","firms":[11025,19616],"id":1697},{"d":"2016-12-02","di":"2016-12-02","dr":"2016-12-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":850000.0,"dk":"2012032923301","al":"Alleged violation of NASD rules 3010(a) and (b), section 15c of the Exchange Act of 1934 and rule 15C3-1(c)(2)(VII) thereunder, section 17a of the Exchange Act and rules 17A-3 thereunder, and FINRA rules 4511 and 2010 in that Citigroup Global Markets Inc. failed to establish and maintain supervisory systems, procedures and written supervisory procedures reasonably designed to ensure that it accurately calculated the value of the securities it held from 2009 through at least June 2012 and the firm's system for applying required deductions to the value of certain of its mortgage-backed securities positions when computing the firm's net capital was inadequate from December 2010 trhough July 2011.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine in the amount of $850,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1698},{"d":"2016-12-01","di":"2016-12-01","dr":"2016-12-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure, undertaking, disgorgement and prejudgment interest","st":"Final","fine":18300000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17701","al":"On December 1, 2016, PIMCO entered into an agreement with the U.S. Securities and Exchange Commission (\"SEC\") to settle charges relating to the PIMCO total return active exchange-traded fund (\"BOND\"). The SEC alleged that from February 29, 2012 to June 30, 2012, PIMCO did not sufficiently disclose the sources of performance for BOND, inaccurately valued 43 smaller-sized (\"odd lot\") positions of non-agency mortgage backed securities using third-party vendor prices, and did not adopt and implement adequate written policies and procedures related to these matters. The SEC found, and PIMCO neither admitted nor denied, that PIMCO violated section 206(2) of the Investment Advisers Act of 1940 (\"Advisers Act\"), section 206(4) of the Advisers Act and rules 206(4)-7 and 206(4)-8 thereunder, section 34(b) of the Investment Company Act, and rule 22C-1 under the Investment Company Act.","res":"Settled","sd":"Pursuant to the settlement, the SEC ordered a civil monetary penalty in the amount of $18.3 million, $1.33 million of disgorgement, and $198,179.04 of prejudgment interest. The penalty, disgorgement, and prejudgment interest will be paid within 14 days of the entry of the order. No portion of the penalty was waived. The settlement also required PIMCO to retain an independent compliance consultant to review its policies and procedures for valuing odd lots as described in the order.","sm":"On December 1, 2016, the Securities and Exchange Commission (\"SEC\") announced an agreement with PIMCO to settle the charges relating to bond. The SEC administrative order is final. The civil monetary penalty, disgorgement and prejudment interest will be paid within 14 days of the entry of the order. PIMCO will retain an independent compliance consultant within 30 days of the issuance of the order, the consultant will submit a report to PIMCO and the SEC staff within 120 days from the date of the order, and PIMCO will adopt the recommendations contained in the report within 90 days of receipt.","ab":"Pacific Investment Management Company LLC","self":true,"firms":[104559],"id":1699},{"d":"2016-12-01","di":"2016-12-01","dr":"2016-12-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1500000.0,"dk":"2014042651801","al":"FINRA alleged that Morgan Stanley Smith Barney LLC experienced unrelated technical issues that temporarily disabled certain prospectus hyperlinks on the MS online website, and prevented certain client profile confirmation letters from being generated. The settlement recognized Morgan stanley's extraordinary cooperation in identifying and quickly resolving the prospectus issue, and further recognized that prospectuses were available elsewhere on MS online, and client profile information continued to be reflected on customer account statements.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On December 1, 2016, Morgan Stanley Smith Barney LLC and FINRA entered into a letter of acceptance, waiver, and consent (AWC) in connection with allegations that, the firm experienced unrelated technical issues that temporarily disabled certain prospectus hyperlinks on the MS online website, and prevented certain client profile confirmation letters from being generated. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to entry of findings and the imposition of a censure and fine of $1,500,000. The fine was paid on 12/15/2016.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1700},{"d":"2016-11-30","di":"2016-11-30","dr":"2016-11-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; restitution; prejudgment interest","st":"Final","fine":6250000.0,"dk":"2014042578001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it did not establish and maintain adequate supervisory systems, and did not establish, maintain, and enforce adequate written procedures, reasonably designed to achieve compliance with applicable securities laws and regulations governing the use of proceeds from loans originated under a securities-based lending program called loan management accounts (LMAS). The findings stated that the firm did not adequately educate its representatives about LMAS or train them on the differences between purpose and nonpurpose LMAS, the contractual and firm prohibition against using proceeds from non-purpose LMAS to buy margin stock, or the regulatory requirements applicable to LMAS used to buy margin stock. The firm also did not reasonably supervise the lma account-opening process. The findings also stated the firm did not establish and maintain reasonable supervisory systems, or establish, maintain, and enforce adequate written procedures, designed to prevent, deter, and detect the use of proceeds from non-purpose LMAS to purchase margin stock. Except in limited situations where a customer had an open margin debit balance or a pending trade, there was no effective control in place to prevent customers from transferring proceeds from a non-purpose lma to their firm brokerage account and immediately purchasing margin stock, nor any effective post-transaction review to detect such prohibited use of the lma proceeds. This failure to supervise extended to the firm's policies and procedures, which prohibited the use of proceeds from non-purpose LMAS to purchase securities generally, and to the lma agreements, which prohibited the use of proceeds from non-purpose LMAS to purchase margin stock. Likewise, because the firm did not have adequate systems to monitor whether proceeds from non-purpose LMAS were used to purchase margin stock, the firm failed to adequately monitor to ensure the collateral requirement was met in those instances when lma proceeds were, in fact, used to purchase margin stock. As a result of these failures, during the lma review period, the firm customers drew down on non- purpose LMAS, transferred the funds to their firm brokerage accounts, and within a short timeframe (often the same day) on thousands of occasions purchased margin stock. The findings also included that the firm failed to establish and maintain a supervisory system, and failed to establish, maintain, and enforce written procedures, reasonably designed to ensure the suitability of transactions in Puerto Rico municipal bonds and Puerto Rico closed-end funds (PR securities) in certain circumstances. Many Puerto Rico customers were concentrated in PR securities, and many used leverage to buy additional PR securities either through LMAS or through the use of margin in their securities accounts. Leveraged customers were required to maintain account equity in order to provide adequate collateral to support their leverage. Despite the risk of customers who were both leveraged and highly concentrated in PR securities, the firm did not establish and maintain adequate supervisory systems and procedures to ensure that, where customers were both highly concentrated in PR securities and using leverage, transactions were suitable in light of the customers' risk objectives and profiles. FINRA found that several hundred customer accounts in the firm's Puerto Rico branch with modest net worth and conservative or moderate investment objectives had 75","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining the appropriate sanction, FINRA considered the following factors: prior to detection by a regulator, the firm conducted a comprehensive internal review of the use of non-purpose lma proceeds to purchase margin stock and took remedial measures to strengthen its related controls and procedures; the firm reported to FINRA certain of the violations addressed in the AWC; and the firm provided substantial assistance during FINRA's investigation by sharing the results of its internal investigation with FINRA.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1701},{"d":"2016-11-29","di":"2016-11-25","dr":"2016-11-29","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":780.0,"al":"Failing to disclose certain trades in a Swiss security on a timely basis - per the Swiss takeover rules. The Swiss Federal Department of Finance imposed an administrative fine of CHF760.","res":"Decision","sd":"A fine of CHF 760 was paid - the matter is closed","sm":"A fine of CHF 760 was paid - the matter is closed No information Filed","ab":"Silchester International Investors LLP","self":true,"firms":[110987],"id":1702},{"d":"2016-11-17","di":"2016-11-17","dr":"2016-11-17","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Civil money penalty and undertakings","st":"Final","fine":61932500.0,"dk":"16-22-B-HC AND 16-22-CMP-HC","al":"On November 17, 2016, JPMorgan Chase & Co. (\"JPMC\") entered into a settlement with the Board of Governors of the Federal Reserve System (\"FRB\") resulting in the FRB issuing an order (\"order\"). The order finds that from at least 2008 through 2013, JPMC's asia- pacific region investment banking group operated a referral hiring program whereby candidates who were referred, directly or indirectly, by foreign government officials and existing or prospective commercial clients, and who in most instances were less qualified than non-referred candidates who were hired through the JPMC's standard hiring programs, were offered internships, training, and other employment opportunities in order to obtain improper business advantages for JPMC.","res":"Settled","sm":"The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12. In coordination with the FRB settlement, JPMC and certain of its affiliates also entered into settlements with other agencies to resolve concurrent investigations arising out of the same conduct. Those settlements are as follows: JPMorgan apac entered into a non- prosecution agreement with the Department of Justice and consented to the issuance of a criminal fine for violations of federal anti-bribery laws and the U.S. Securities and Exchange Commission entered an administrative cease-and-desist order against JPMC finding violations of federal anti-bribery and securities laws.","ab":"JPMorgan Chase & Co.","firms":[79,20989,134776,135960],"id":1703},{"d":"2016-11-17","di":"2016-11-17","dr":"2016-11-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement, pre-judgment interest, and undertakings","st":"Final","dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17684","al":"On November 17, 2016, JPMorgan Chase & Co. (\"JPMC\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") under which JPMC consented to the entry of an order (the \"order\") that finds that JPMC violated sections 13(b)(2)(a), 13(b)(2)(b) and 30a of the Securities Exchange Act of 1934 (\"Exchange Act\"). The order finds that JPMC violated the anti-bribery provisions of the federal securities laws by corruptly providing valuable internships and employment to relatives and friends of foreign government officials (\"referral hires\") in order to assist JPMC in retaining and obtaining business. In addition, the order finds that JPMC violated the books and records provisions and the internal accounting controls provisions of the foreign corrupt practices act (\"FCPA\") in conjunction with certain referral hires.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, JPMC admitted the SEC's jurisdiction and the subject matter of these proceedings and consented to the order. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12. In coordination with the SEC settlement, JPMC and certain of its affiliates also entered into settlements with other agencies to resolve concurrent investigations arising out of the same conduct. Those settlements are as follows: JPMorgan apac entered into a non-prosecution agreement with the Department of Justice that acknowledges responsibility for criminal conduct relating to certain findings in the order and the Board of Governors of the Federal Reserve system entered an administrative cease-and-desist order against JPMC.","ab":"JPMorgan Chase & Co.","firms":[79,20989,134776,135960],"id":1704},{"d":"2016-11-17","di":"2016-11-17","dr":"2016-11-17","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"N/A","al":"Alleged violation BSEF rule 516 in that Citibank, N.A. failed to notify and receive approval from BSEF prior to entering into offsetting and correcting trades.","res":"Settled","sm":"The firm consented to a fine in the amount of $2,000","ab":"Citibank, N.A.","firms":[7059],"id":1705},{"d":"2016-11-17","di":"2016-11-17","dr":"2016-11-17","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1750.0,"dk":"N/A","al":"Alleged violation of BSEF rule 516 in that Citibank, N.A. failed to notify and receive approval from BSEF prior to entering into offsetting and correcting trades.","res":"Settled","sm":"The firm consented to a fine in the amount of $1,750","ab":"Citibank, N.A.","firms":[7059],"id":1706},{"d":"2016-11-17","di":"2013-05-31","dr":"2016-11-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":30000.0,"dk":"2013037025101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in three instances, the firm had a fail-to-deliver position at a registered clearing agency in an equity security that resulted from a long sale, and did not close out the fail-to-deliver position by purchasing or borrowing securities of like kind and quantity within the time frame prescribed by SEC rule 204(a)(1). The findings stated that in eight instances, the firm had a fail-to deliver position at a registered clearing agency in an equity security that the seller was deemed­to­own pursuant to § 242.200 and intended to deliver once all restrictions on delivery had been removed, and did not close out the fail-to-deliver position by purchasing or borrowing securities of like kind and quantity within the time frame prescribed by SEC rule 204(a)(2) of Regulation SHO. The firm also executed 16 sale orders and failed to properly mark the orders as short.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1707},{"d":"2016-11-14","di":"2016-10-13","dr":"2016-11-14","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":45000.0,"dk":"16-0030","al":"Registrant is alleged to have violated SEC rules 15C3-1, 17A-4, and 17A-5.","res":"Settled","sd":"$45,000 paid by Ursa Fund Management, LLC on 11/18/16","sm":"This action has been fully resolved and disposed. No information Filed","ab":"Hahn, Andrew, Philip","firms":[283363],"id":1708},{"d":"2016-11-09","di":"2016-11-09","dr":"2016-11-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":300000.0,"dk":"2013035823501","al":"Alleged violation of SEC rules 17A-3 and 605 and 606 of regulation NMS, FINRA rules 4511, 2010, 7450, 7230a, and 2265, and NASD rules 6955 and 6130 in that Citigroup Global Markets Inc. identified a system issue which caused the incorrect marking of certain short sales as long sales on its books and records between January 8, 2013 and October 16, 2013; identified OATS reporting issues causing OATS reporting violations between November 21, 2008 and December 3, 2013 and between June 1, 2012 and June 1, 2015; two separate issues caused the firm to include certain orders in its SEC rule 605 of regulation NMS reports between January 1, 2013 and March 13, 2014 that should not have been included; and the firm made reports publicly available on its routing of non-directed orders in covered securities that included incomplete information as to a material aspect of the firm's relationship with one affiliated venue to which it routed large percentages of it's total non-directed orders during the third and fourth calendar quarters of 2015 and the first calendar quarter of 2016.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a $300,000 fine","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1709},{"d":"2016-11-07","di":"2015-03-11","dr":"2016-11-07","k":"Regulatory Action","rg":"Other","reg":"Bundesanstalt FÜR Finanzdienstleistungsaufsicht (German Federal Financial Supervisory Authority ­ \"BAFIN\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":94500.0,"dk":"WA 17-WP 3120-2013/0165-0169, 0174-0179, WP 3121-2012/0012, 0020-0025, 2014/0011,0012","al":"BAFIN alleged non-compliance with the german disclosure rules for holdings in german listed entities pursuant to the german securities trading act by one or several Morgan stanley entities between May 2011 and September 2013 in relation to holdings in several german listed entities.","res":"Decision","sm":"On November 7, 2016, Morgan Stanley & Co. international PLC (MSIP) became subject to a summary order by Bundesanstalt fÜr finanzdienstleistungsaufsicht (german federal financial supervisory authority - \"BAFIN\") for payment of an administrative fine of 94,500 euros (plus costs of proceedings of 4,725 euros) in connection with findings that one or several Morgan stanley entities failed to comply with the german disclosure rules for holdings in german listed entities between May 2011 and September 2013 pursuant to the german securities trading act. The original notice was issued to Morgan stanley and the administrative fine was assessed against MSIP.","ab":"Morgan Stanley & Co.","firms":[149777],"id":1710},{"d":"2016-11-03","di":"2016-11-03","dr":"2016-11-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":500000.0,"dk":"2014040597101","al":"Without admitting or denying the findings, the firm consented to a censure and $500,000 fine for failing, during the period from January 1, 2013 through December 31, 2015 to adequately supervise the execution and approval of powers of attorney (\"poa's\") for J.P. Morgan private bank (\"private bank\") customer accounts submitted to the firm by non-U.S. resident customers.","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1711},{"d":"2016-11-03","di":"2016-11-03","dr":"2016-11-03","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"CME-RSRH-16-4489","al":"Alleged violation of CME rule 811 in which Citigroup Global Markets Inc. had reporting infractions during the period of September 1-30, 2016.","res":"Settled","sm":"The firm consented to a summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1712},{"d":"2016-11-03","di":"2016-11-03","dr":"2016-11-03","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"NYMEX-RSRH-16-4489","al":"Alleged violation of NYMEX rule 811 in which Citigroup Global Markets Inc. had reporting infractions during the period of September 1-30, 2016.","res":"Settled","sm":"The firm consented to a summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1713},{"d":"2016-11-03","di":"2016-11-03","dr":"2016-11-03","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000.0,"dk":"CBT-RSRH-16-4489","al":"Alleged violation of CBT rule 811 in which Citigroup Global Markets Inc. had reporting infractions during the period of September 1-30, 2016.","res":"Settled","sm":"The firm consented to a summary fine of $4,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1714},{"d":"2016-11-03","di":"2016-11-03","k":"Regulatory Action","dk":"66023-SR","ab":"Eustaquio, Jose,","firms":[7691],"id":1715},{"d":"2016-11-03","dr":"2016-11-03","k":"Regulatory Action","st":"Final","res":"Decision","sm":"Refer to advisory affiliate's DRP.","ab":"Pacific Alliance","firms":[161814],"id":1716},{"d":"2016-11-02","di":"2016-11-02","dr":"2016-11-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"$15,000 fine","st":"Final","fine":15000.0,"dk":"20160499654","al":"It was alleged that during the review period the firm failed to report reportable order events and failed to comply with related supervisory requirements.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, Davenport consented to the described sanctions and to the entry of findings. The firm was censured and fined $15,000.00","sm":"Without admitting or denying the allegations or findings, Davenport, on November 2, 2016 executed a letter of acceptance, waiver and consent, paid the fine and agreed to revise the firm's written supervisory procedure with the respect to the areas on question. No information Filed","ab":"Davenport & Company LLC","self":true,"firms":[1588],"id":1717},{"d":"2016-10-31","di":"2016-10-31","dr":"2016-10-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure;restitution;undertaking;other;interest","st":"Final","fine":52500.0,"dk":"2013036708101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that, in 86 instances during the July 1, 2012 through September 30, 2014 review period, it accepted and held an order in an OTC equity security (limited to unlisted, pink sheet securities) from its own customer, or a customer or another broker-dealer, and traded that security on the same side of the market for its own account at a price that would have satisfied the customer order without immediately thereafter executing the customer order up to the size and at the same or better price at which it traded for its own account. The findings stated that, in 38 of the above 86 instances, the firm also 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. Futhermore, on 13 occasions involving either a trading ahead and/or crossing failure, the firm failed to execute a marketable customer order fully and promptly. The findings also stated the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to trading ahead of customer orders. Specifically, the firm, when performing its trading ahead reviews in OTC securities, failed to identify price exceptions of market held orders, and ensure that customer orders were executed within 60 seconds of the firm's proprietary trade and up to the lesser of the proprietary or customer order share quantity. The findings also included that the firm's trading supervision checklist did not evidence a supervisory review related to trading ahead of customer orders, and it also failed to provide to the staff evidence of a supervisory review related to trading ahead of customer orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $52,500, ordered to pay restitution in the amount of $582.72 plus interest, and undertakes to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1718},{"d":"2016-10-31","di":"2016-10-31","dr":"2016-10-31","k":"Regulatory Action","rg":"State regulator","reg":"State of New York Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":732067.0,"dk":"2016-001-A","al":"As a result of a routine market conduct examination of the affairs of New York Life Insurance company for the period from January 1, 2005 through December 31, 2009, the New York state department of financial services found that New York life violated section 53-3.5(a), 53-3.2(a)(2) and 53-3.6(b) of the department regulation no. 74 as well as New York insurance law section 3201(b) (1).","res":"Consent","sd":"As a result of a routine market conduct examination of the affairs of New York Life Insurance company for the period from January 1, 2005 through December 31, 2009, the New York state department of financial services found that New York life violated section 53-3.5(a), 53-3.2(a)(2) and 53-3.6(b) of the department regulation no. 74 as well as New York insurance law section 3201(b)(1).","sm":"As a result of a routine market conduct examination the affairs of New York Life Insurance company for the period from January 1, 2005 through December 31, 2009, the New York state department of financial services found that New York life violated section 53-3.5(a), 53-3.2(a)(2) and 53-3.6(b) of the department regulation no. 74 as well as New York insurance law section 3201(b)(1).","ab":"New York Life Insurance","firms":[107717],"id":1719},{"d":"2016-10-31","di":"2016-10-31","dr":"2016-10-31","k":"Regulatory Action","rg":"State regulator","reg":"State of New York Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fined $732,067","st":"Final","fine":732067.0,"dk":"2016-001-A","al":"As the result of a routine market conduct examination of the affairs of New York Life Insurance company for the period from January 1, 2005 through December 31, 2009, the New York state department of financial services found that New York life violated sections 53-3.5(a), 53-3.2(a)(2) and 53-3.6(b)of the department regulation NO.74 as well as New York insurance lawsection 3201(b) (1).","res":"Consent","sd":"Fined 732,067","ab":"New York Life Insurance","firms":[169553,173355,309234],"id":1720},{"d":"2016-10-27","di":"2016-10-27","k":"Regulatory Action","dk":"R2016-0088","ab":"Zimmerman, Andrew,","firms":[7691],"id":1721},{"d":"2016-10-25","di":"2016-10-25","k":"Regulatory Action","rg":"Other","reg":"Investment Industry Regulatory Organization of Canada","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250000.0,"dk":"16-0260","al":"Investment Industry Regulatory Organization of Canada (\"IIROC\") alleged that Edward Jones (Ontario, L.P.) (\"Edward jones Canada\") failed to adequately supervise retail accounts in violation of IIROC dealer member rules 38.1 and 2500.","res":"Settled","sm":"See above.","ab":"Edward Jones (Ontario,","firms":[250],"id":1722},{"d":"2016-10-25","di":"2016-09-26","dr":"2016-10-25","k":"Regulatory Action","rg":"Other","reg":"Bats BZX Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"20120344693-02","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a letter of acceptance, waiver and consent (the \"consent\") with Bats BZX Exchange, Inc. (\"Bats BZX\"). The consent finds that Merrill lynch violated rule 15C3-5 under the Securities Exchange Act of 1934 (\"Exchange Act\") and Bats BZX rules 3.1, 3.2, and 5.1 by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Solely for the purpose of settling these proceedings, Merrill lynch entered into the consent without admitting or denying the findings referred to in the consent. The allegations, dispositions, findings and sanctions of the consent are described above in items 7 and 12. Pursuant to Bats BZX rules, the decision in this matter is final 20 business days after the issuance of the consent. This AWC became final October 25, 2016.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1723},{"d":"2016-10-25","di":"2016-09-29","dr":"2016-10-25","k":"Regulatory Action","rg":"Other","reg":"Bats Byx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"20120344693-03","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a letter of acceptance, waiver and consent (the \"consent\") with Bats Byx Exchange, Inc. (\"Bats byx\"). The consent finds that Merrill lynch violated rule 15C3-5 under the Securities Exchange Act of 1934 (\"Exchange Act\") and Bats byx rules 3.1, 3.2, and 5.1 by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Solely for the purpose of settling these proceedings, Merrill lynch entered into the consent without admitting or denying the findings referred to in the consent. The allegations, dispositions, findings and sanctions of the consent are described above in items 7 and 12. Pursuant to Bats byx rules, the decision in this matter is final 20 business days after the issuance of the consent. This AWC became final October 25, 2016.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1724},{"d":"2016-10-20","di":"2016-10-20","dr":"2016-10-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":42500.0,"dk":"2015046578401","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it effected 39 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 rule. The findings stated that the firm failed to disclose all material facts concerning 39 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, or that the municipal securities contained a resale restriction which could affect the liquidity of the customer's position.","res":"Acceptance, Waiver & Consent(AWC)","sm":"N/a","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1725},{"d":"2016-10-19","di":"2016-10-19","dr":"2016-10-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":22500.0,"dk":"20150442305-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1726},{"d":"2016-10-18","di":"2016-10-18","dr":"2016-10-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":975000.0,"dk":"20140413771-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1727},{"d":"2016-10-17","di":"2016-10-17","dr":"2016-10-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure;undertaking","st":"Final","fine":2800000.0,"dk":"2013035822901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it submitted to the FINRA/Nasdaq trade reporting facility (TRF) millions of inaccurate trades in which purchases were reported as principal sales and agency crosses. The firm also submitted millions of trades it was not required to submit. The findings stated that the firm also submitted millions of inaccurate or incomplete reportable order events (ROES) to the order audit trail system (OATS) including the submission of new orders with inaccurately placed cancel stamps, new order reports for modifications of existing orders, broker-dealer orders reported as customer orders, inaccurate good till time (GTT) time in force designations, and intermarket sweeps orders (ISOS) without the required iso special handling code. The firm also failed to report millions of execution reports to OATS. The findings also included that the firm failed to capture the minimum quantity (MQT) special handling instructions on millions of order tickets which are used for transactions that should be canceled if a specified minimum quantity cannot be executed. The firm also recorded incorrect receipt and route timestamps on millions of order tickets. In addition, FINRA found that the firm included incorrect information as to cancelled shares in its rule 605 report. FINRA found that the firm's written supervisory procedures (WSPS) were not reasonably designed to ensure compliance with FINRA's trade and OATS reporting rules, customer confirmation rules, and the books and records requirements in SEC rule 17A-3. The firm's WSPS required supervision of a number of modifiers but failed to call for a supervisory review of the .RX modifier which concern transactions reported for regulatory transaction fees. The firm's OATS reporting WSPS required the review of a small number of OATS reports on a monthly basis to ensure the accuracy of such reports. Given the volume of the firm's OATS reporting obligations, the scope of the firm's WSPS was not reasonably designed to capture and identify any reporting problems. The firm's books and records, customer confirmations and OATS WSPS required the review of a small number of books and records and customer confirmations on a monthly basis to ensure the accuracy of such records. Given the volume of the firm's books and records, customer confirmations and OATS reporting obligations, the scope of the firm's WSPS was not reasonably designed to capture and identify the accuracy of such records.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $2,800,000, and undertakes to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1728},{"d":"2016-10-17","di":"2016-10-17","dr":"2016-10-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2200000.0,"dk":"20150441008-01","al":"FINRA alleged that the firm violated FINRA rules 2360(b)(5) and 2010 by reporting numerous options positions to the large options positions report system (LOPR): a) without the requisite in-concert identification; b) without tax identification numbers or social security numbers; c) in the wrong account type, in that the firm reported \"customer\" positions with an inaccurate account type of \"firm\"; d) with account names extending into the address field, with incomplete address fields, or with street addresses that included additional information; and e) without a zip code. In addition, FINRA alleged that in connection with reporting numerous options positions to the LOPR, the firm violated FINRA rules 2360(b)(5) and 2010 by failing to: a) capture for in-concert reporting certain joint and partnership accounts, accounts with a status of closed or \"swung\" (client account transferred to new account number), certain foreign accounts, certain financial advisor and portfolio manager accounts, and accounts with third-party trading authority over non-discretionary accounts; b) include flex options in its LOPR aggregation; c) include options marked as inactive in its LOPR position file; and d) correctly populate the effective date of options positions with the submission date rather than the trade date. FINRA also alleged that the firm violated NASD rule 3010 and FINRA rules 3110 and 2010 by failing to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with option reporting rules and by lacking adequate written supervisory procedures requiring reviews to ensure that its submissions to the LOPR were complete and accurate.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On October 17, 2016, Morgan Stanley Smith Barney LLC (firm) and FINRA entered into a letter of acceptance, waiver, and consent (AWC) to settle allegations that the firm violated FINRA rules 2360(b)(5) and 2010 by reporting numerous options positions to the large options positions report system (LOPR): a) without the requisite in-concert identification; b) without tax identification numbers or social security numbers; c) in the wrong account type, in that the firm reported \"customer\" positions with an inaccurate account type of \"firm\"; d) with account names extending into the address field, with incomplete address fields, or with street addresses that included additional information; and e) without a zip code. In addition, FINRA alleged that in connection with reporting numerous options positions to the LOPR, the firm violated FINRA rules 2360(b)(5) and 2010 by failing to: a) capture for in-concert reporting certain joint and partnership accounts, accounts with a status of closed or \"swung\" (client account transferred to new account number), certain foreign accounts, certain financial advisor and portfolio manager accounts, and accounts with third-party trading authority over non-discretionary accounts; b) include flex options in its LOPR aggregation; c) include options marked as inactive in its LOPR position file; and d) correctly populate the effective date of options positions with the submission date rather than the trade date. FINRA also alleged that the firm violated NASD rule 3010 and FINRA rules 3110 and 2010 by failing to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the option reporting rules and by lacking adequate written supervisory procedures requiring reviews to ensure that its submissions to the LOPR were complete and accurate. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to entry of findings and the imposition of a censure and fine of $2,200,000, of which $550,000 was paid to FINRA and the balance was paid to NYSE MKT LLC pursuant to an equivalent settlement agreement entered concurrently between the firm and NYSE MKT LLC.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1729},{"d":"2016-10-17","di":"2016-10-17","dr":"2016-10-17","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1650000.0,"dk":"20150441008-02","al":"NYSE MKT LLC (exchange) alleged that the firm violated exchange rule 906(a).NY by reporting numerous options positions to the large options positions report system (LOPR): a) without the requisite in-concert identification; b) without tax identification numbers or social security numbers; c) in the wrong account type, in that the firm reported \"customer\" positions with an inaccurate account type of \"firm\"; d) with account names extending into the address field, with incomplete address fields, or with street addresses that included additional information; and e) without a zip code. In addition, the exchange alleged that in connection with reporting numerous options positions to LOPR, the firm violated exchange rule 906(a).NY by failing to: a) capture for in-concert reporting certain joint and partnership accounts, accounts with a status of closed or \"swung\" (client account transferred to new account number), certain foreign accounts, certain financial advisor and portfolio manager accounts, and accounts with third-party trading authority over non-discretionary accounts; b) include flex options in its LOPR aggregation; c) include options marked as inactive in its LOPR position file; and d) correctly populate the effective date of options positions with the submission date rather than the trade date. The exchange also alleged that the firm violated exchange rule 320.NY by failing to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's option reporting rules and by lacking adequate written supervisory procedures requiring reviews to ensure that its submissions to the LOPR were complete and accurate.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On October 17, 2016, Morgan Stanley Smith Barney LLC (firm) and NYSE MKT LLC (exchange) entered into a letter of acceptance, waiver, and consent (AWC) to settle allegations that the firm violated exchange rule 906(a).NY by reporting numerous options positions to the large options positions report system (LOPR): a) without the requisite in-concert identification; b) without tax identification numbers or social security numbers; c) in the wrong account type, in that the firm reported \"customer\" positions with an inaccurate account type of \"firm\"; d) with account names extending into the address field, with incomplete address fields, or with street addresses that included additional information; and e) without a zip code. In addition, the exchange alleged that in connection with reporting numerous options positions to LOPR, the firm violated exchange rule 906(a).NY by failing to: a) capture for in-concert reporting certain joint and partnership accounts, accounts with a status of closed or \"swung\" (client account transferred to new account number), certain foreign accounts, certain financial advisor and portfolio manager accounts, and accounts with third-party trading authority over non-discretionary accounts; b) include flex options in its LOPR aggregation; c) include options marked as inactive in its LOPR position file; and d) correctly populate the effective date of options positions with the submission date rather than the trade date. The exchange also alleged that the firm violated exchange rule 320.NY by failing to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's option reporting rules and by lacking adequate written supervisory procedures requiring reviews to ensure that its submissions to the LOPR were complete and accurate. Without admitting or denying the underlying allegations and without adjudication of any issue of law or fact, the firm accepted and consented to entry of findings and the imposition of a censure and fine of $2,200,000, of which $1,650,000 was paid to the exchange and the balance was paid to FINRA pursuant to an equivalent settlement agreement entered concurrently between the firm and FINRA.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1730},{"d":"2016-10-17","di":"2016-10-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":102500.0,"dk":"2014043135901","al":"FINRA alleged that the firm submitted late trade reports for certain TRACE-eligible securities from 3Q14 through 1Q2015.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On October 17, 2016, FINRA and Morgan Stanley Smith Barney, LLC entered into a letter of acceptance, waiver and consent (\"AWC\") to settle allegations that the firm: (1) violated FINRA rules 2010 and 6730(a) by failing to timely file reports to TRACE, for certain TRACE-eligible securities from 3Q14 through 1Q2015; (2). Without denying or admitting the underlying allegations and without adjudication of any issue or law or fact, the firm accepted and consented to the entry of findings, the imposition of a censure and a fine of $102,500.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1731},{"d":"2016-10-14","di":"2013-07-31","dr":"2016-10-14","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Compromise which was made and authorized by the court.","st":"Final","al":"The plaintiff is one of the investors of a japanese investment trust fund (the \"fund\") which was managed by shinko asset management co., LTD (\"shinko\", merged to diam co., LTD. and name changed to Asset Management One Co., Ltd. as of October 1ST, 2016). The fund was a privately placed fund for qualified institutional investors. Shinko sold equities in the fund in accordance with redemption request from the plaintiff. Later the same day, it was turned out that the amount of redemption was one figure greater than plaintiff' intended amount. Shinko bought back the equities but a loss eventuated to the fund during selling and buying. The plaintiff alleged that shinko has caused a financial loss to the plaintiff.","res":"Other","sd":"The court case between the plaintiff and shinko asset management co., LTD. (defendant, which merged into am one on October 1, 2016), filed to the tokyo district court on July 31, 2013. The plaintiff is one of the investors of a japanese investment trust fund (the \"fund\") which was managed by shinko asset management co., LTD. (the fund was a privately placed fund for qualified institutional investors.) On September 30, 2016, the court handed down a judgment that the defendant should pay yen 40 million to the plaintiff. Such amount was only part of the amount claimed by plaintiff, because of comparative fault (the court found both party's negligence.) Neither party made an appeal and the case have been closed.","ab":"Asset Management One Co., Ltd.","self":true,"firms":[110843],"id":1732},{"d":"2016-10-13","di":"2015-05-19","dr":"2016-10-13","k":"Regulatory Action","rg":"Other","reg":"District of Columbia - Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"SB-14-16","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the District of Columbia department of insurance, securities and banking (department) alleged that Citigroup Global Markets Inc. (CGMI) accepted client orders through sales assistants who were highly likely not registered in the District of Columbia, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in the District of Columbia. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the department alleged that the acceptance of client orders in the District of Columbia through sales assistants that were highly likely not registered in the District of Columbia, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in the District of Columbia constituted bases for the assessment of an administrative fine pursuant to D.C. Official code § 31­5606.02(b). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the department a sum in the amount of $35,000, the District of Columbia's allocated portion of the amount agreed to with nasaa. Finally, the department and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1733},{"d":"2016-10-12","di":"2016-07-07","dr":"2016-10-12","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","st":"Final","fine":30000.0,"dk":"16-0022/20150459490","al":"JPMS received a statement of charges from the Chicago Board Options Exchange (CBOE) for alleged violations of rules 200 and 201 of Regulation SHO. Specifically, the CBOE alleges that (1) JPMS mismarked certain orders as sse when the subject orders did not satisfy the requirements of Regulation SHO rule 201; (2) JPMS' supervisory system did not provide for supervision reasonably designed to identify sse orders that were not eligible for such marking, including failure to surveil to ascertain the effectivness of its policies and procedures required under Regulation SHO and to take prompt action to remedy deficiencies in such policies and procedures; and (3) the firm's supervisory system did not provide for adequate supervision to ensure that JPMS' compliance with the requirements of rules 200 and 201 of reg sho pertaining to the accurate marking of sale orders. The CBOE deems the conduct described above as a violation of exchange rule 4.2, section 17(a) of the Exchange Act and rule 17A-3 thereunder, and Regulation SHO rules 200 and 201.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the findings, JPMS consented to a fine of $30,000 to settle allegations reflected in the Chicago Board Options Exchange (CBOE) statement of charges relating to violations of rules 200 and 201 of Regulation SHO. Specifically, the CBOE alleged that during the period from February 2011 through February 2012 JPMS mismarked orders as short sale exempt (\"SSE\")when the subject orders did not satisfy the requirements of Regulation SHO rule 201; (2) JPMS' supervisory system did not provide for supervision reasonably designed to identify SSE orders that were not eligible for such marking, including failure to surveil to ascertain the effectivness of its policies and procedures required under Regulation SHO and to take prompt action to remedy deficiencies in such policies and procedures; and (3) the firm's supervisory system did not provide for adequate supervision to ensure that JPMS' compliance with the requirements of rules 200 and 201 of reg sho pertaining to the accurate marking of sale orders. The CBOE deems the conduct described above as a violation of exchange rule 4.2, section 17(a) of the Exchange Act and rule 17A-3 thereunder, and Regulation SHO rules 200 and 201. This is a final action resolved by decision accepting offer of settlement, approved on 10/12/2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1734},{"d":"2016-10-12","di":"2016-06-13","dr":"2016-10-12","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","st":"Final","fine":25000.0,"dk":"16-0018/ 20160501291","al":"It is alleged that Wedbush: (I)failed to mark numerous orders with the proper origin code; (II) failed to maintain accurate books and records as a result of mismarking numerous agency orders with principal order origin codes; (III) failed to implement adequate supervisory policies and procedures related to origin code marking on CBSX; and failed to supervise to assure compliance with the order origin code marking requirements on CBSX. (Violation of exchange rules 4.2, 6.51 and 15.1, and section 17(a) of the Exchange Act and rule 17A-3 thereunder)","res":"Decision & Order of Offer of Settlement","sd":"A $25,000 fine and a censure.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1735},{"d":"2016-10-06","di":"2016-10-06","dr":"2016-10-06","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2016-020","al":"Alleged violation of exchange rule 27.12a in that Citigroup Global Markets Inc. failed to provide electronic audit trail data for certain orders entered onto the ets in 2015.","res":"Settled","sm":"The firm consented to a summary fine $5,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1736},{"d":"2016-10-05","di":"2016-10-05","dr":"2016-10-05","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":60000.0,"dk":"20160490438-04","al":"Alleged violation of edgx rules 11.5, 3.1, and 5.1 in that Citigroup Global Markets Inc. entered certain orders into edgx that failed to indicate the correct capacity and 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 edgx rules between June 1, 2012 and September 30, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, fine of $60,000 and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1737},{"d":"2016-10-05","di":"2016-10-05","dr":"2016-10-05","k":"Regulatory Action","rg":"Other","reg":"Bats Edga Exchange, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":60000.0,"dk":"20160490438-03","al":"Alleged violation of edga rules 11.5, 3.1, and 5.1 in that Citigroup Global Markets Inc. entered certain orders into edga that failed to indicate the correct capacity and 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 edga rules between June 1, 2012 and September 30, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $60,000 and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1738},{"d":"2016-09-30","di":"2016-09-30","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"CME-RSRH-16-4447","al":"Alleged violation of CME rule 811 in which Citigroup Global Markets Inc. inaccurately reported to the exchange open interest positions during the period of August 1-31, 2016.","res":"Settled","sm":"The firm consented to a summary fine in the amount of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1739},{"d":"2016-09-30","di":"2016-09-30","dr":"2016-09-30","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"NYMEX-RSRH-16-4447","al":"Alleged violation of NYMEX rule 811 in which Citigroup Global Markets Inc. inaccurately reported to the exchange open interest positions during the period of August 1-31, 2016.","res":"Settled","sm":"The firm consented to a summary fine of $2,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1740},{"d":"2016-09-29","di":"2016-09-29","dr":"2016-09-29","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":30000.0,"dk":"16-017","al":"Wedbush Securities in January 1986 through June 1987 cleared trades for correspondent broker-dealers Tennessee clients without being registered as a broker-dealer in the state as required by Tennessee comp. R. & Regs. 0780-4-3.01(1)(e).","res":"Consent","sd":"Wedbush Securities was fined $30,000 and agreed to a period of probation for two years.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1741},{"d":"2016-09-29","di":"2016-09-29","dr":"2016-09-29","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Censure","os":"Fine, undertaking","st":"Final","fine":60000.0,"dk":"20160490438-01","al":"Alleged violation of NYSE ARCA rules 7.33, 6.18(b) and 6.18(c) in that Citigroup Global Markets Inc. entered certain orders into the NYSE ARCA marketplace that failed to indicate the correct capacity and 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 NYSE rules between June 1, 2012 and September 30, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $60,000 and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1742},{"d":"2016-09-29","di":"2016-09-29","dr":"2016-09-29","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1350000.0,"dk":"20120344693-06","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a letter of acceptance, waiver and consent (the \"consent\") with the Nasdaq Stock Market LLC (\"Nasdaq\"). The consent finds that Merrill lynch violated rule 15C3-5 under the Securities Exchange Act of 1934 (\"Exchange Act\") and Nasdaq rules 3010, 2010a (for conduct on or after nov. 21, 2012) and 2110 (for conduct prior to nov. 21, 2012), and 4611(d) by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, Merrill lynch entered into the consent without admitting or denying the findings referred to in the consent. The allegations, dispositions, findings and sanctions of the consent are described above in items 7 and 12.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1743},{"d":"2016-09-29","di":"2016-09-29","dr":"2016-09-29","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency (OCC)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program and","st":"Final","fine":20000000.0,"dk":"AA-EC-2016-68 & AA-EC-2016-69","al":"Without admitting or denying the findings, Wells fargo bank, N.A. (WFBNA) consents to the finding that between 2007 and 2014, WFBNA failed to accurately disclose some service member's military status in affidavits filed in eviction proceedings and between 2006 and 2011, failed to obtain court orders prior to repossesing services member's automobiles.","res":"Order","sm":"N/a","ab":"Wells Fargo Bank, N. A.","firms":[11025,19616],"id":1744},{"d":"2016-09-29","di":"2016-09-29","dr":"2016-09-29","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program.","st":"Final","fine":60000.0,"al":"Without admitting or denying the findings, Wells fargo bank, N.A. (WFBNA) consents to the finding that between January 1, 2008 and July 1, 2015, WFBNA violated the servicemember civil releif act (SCRA) by failing to obtain court orders prior to repossessing services member's automobiles.","res":"Consent","sd":"$60,000.00 fine paid","ab":"Wells Fargo Bank, N. A.","firms":[11025,19616],"id":1745},{"d":"2016-09-27","di":"2016-09-27","dr":"2016-09-27","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","os":"Fine, undertaking","st":"Final","fine":60000.0,"dk":"20160490438-02","al":"Alleged violation of Nasdaq rules 4611(a)(6), 3010 and 2110 in that Citigroup Global Markets Inc. entered certain orders into the Nasdaq market center that failed to indicate the correct capacity and 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 Nasdaq rules between June 1, 2012 and September 30, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, fine of $60,000 and an undertaking to revise the firm's written supervisory procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1746},{"d":"2016-09-27","di":"2016-09-27","dr":"2016-09-27","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil monetary fine of $400,000.","st":"Final","fine":400000.0,"dk":"CFTC DOCKET NO 16-32","al":"The CFTC found that between March 1, 2013 and November 13, 2015, every large trader report (\"LTR\") submitted by Wells fargo bank, N.A. failed to meet the part 20 requirements. LTRS submitted by the bank omitted required data elements and reported certain data in a manner that did not conform to the specifications required by the CFTC. Accordingly, the bank violated section 4s(f)(1)(a) of the Commodity Exchange Act, 7 U.S.C. SEC. 6s(f)(1)(a) (2012), and regulations 20.4 and 20.7, 17 C.F.R. Secs. 20.4 and 20.7 (2015). Without admitting or denying the findings, the bank consented to entry of the CFTC's order.","res":"Order","sm":"N/a","ab":"Wells Fargo Bank, N. A.","firms":[11025,19616],"id":1747},{"d":"2016-09-26","di":"2016-09-26","dr":"2016-09-26","k":"Regulatory Action","rg":"Other","reg":"Bats Edgx Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":200000.0,"dk":"20120344693-04","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a letter of acceptance, waiver and consent (the \"consent\") with Bats Edgx Exchange, Inc. (\"Bats edgx\"). The consent finds that it violated rule 15C3-5 under the Securities Exchange Act of 1934 (\"Exchange Act\") and Bats edgx rules 3.1, 3.2, and 5.1 by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, Merrill lynch entered into the consent without admitting or denying the findings referred to in the consent. The allegations, dispositions, findings and sanctions of the consent are described above in items 7 and 12.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1748},{"d":"2016-09-26","di":"2016-09-26","dr":"2016-09-26","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":12500000.0,"dk":"3-17573","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a settlement with the Securities and Exchange Commission (\"SEC\") resulting in the SEC issuing an order. Merrill lynch consented to the entry of the order (the \"order\") that finds that it violated section 15(c)(3) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 15C3-5 thereunder (the \"market access rule\"). The order finds that Merrill lynch violated the market access rule by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of its market access activity. In particular, Merrill lynch failed to establish pre-trade risk management controls reasonably designed to prevent the entry of erroneous orders, to establish pre-trade risk management controls reasonably designed to prevent the entry of orders that would exceed pre-set credit or capital limits for several of its trading desks, to establish required controls and procedures for fixed income securities, to review adequately the effectiveness of its risk management controls and supervisory procedures required by the market access rule, particularly for preventing the entry of erroneous orders, and to comply with the rule's CEO certification requirements.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, Merrill lynch consented to the order without admitting or denying the findings in the order, except as to the SEC's jurisdiction over it and the subject matter. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1749},{"d":"2016-09-26","di":"2016-09-26","dr":"2016-09-26","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":525000.0,"dk":"20120344693-05","al":"On September 26, 2016, Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") entered into a letter of acceptance, waiver and consent (the \"consent\") with the New York Stock Exchange LLC (\"NYSE\"). The consent finds that Merrill lynch violated rule 15C3-5 under the Securities Exchange Act of 1934 (\"Exchange Act\") and NYSE rules 342 and 2010 by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access.","res":"Settled","sm":"Solely for the purpose of settling these proceedings, Merrill lynch entered into the consent without admitting or denying any allegations or findings referred to in the consent. The allegations, dispositions, findings and sanctions of the consent are described above in items 7 and 12. Pursuant to NYSE rules, the consent shall be deemed final on October 7, 2016, unless review by the NYSE exchange board of directors is requested.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1750},{"d":"2016-09-26","di":"2016-09-26","dr":"2016-09-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":12500.0,"dk":"2014040421301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it traded ahead of customer orders and also executed customer orders outside normal market hours, contrary to the customers' instructions. The findings stated that the firm also failed to have adequate supervision concerning the trading ahead rule, in that its written supervisory procedures failed to provide for the minimum requirements for adequate written supervisory procedures concerning order protection requirements applicable to customer orders in OTC securities.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $12,500, pay restitution to customers in the total amount of $125.54, plus interest, and undertakes to revise its written supervisory procedures.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1751},{"d":"2016-09-20","di":"2016-09-20","dr":"2016-09-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":5000.0,"dk":"2014042145301","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1752},{"d":"2016-09-20","di":"2016-09-20","dr":"2016-09-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":50000.0,"dk":"2011028816701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in customer transactions executed on the firm's alternative trading system, it failed to use reasonable diligence to ascertain the best inter- dealer market and failed to buy or sell in such market so that the resultant price to the customer was as favorable as possible under prevailing market conditions. 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 FINRA rules, concerning best execution. Specifically, the firm, when performing its best execution reviews for transactions executed on its alternative trading system, failed to use an independent data source to evaluate executions or to review the market data used by the alternative trading system for order handling and execution.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $50,000, and undertakes to submit to FINRA, no later than 30 days after the AWC becomes final, a signed, dated letter or e-mail of the registered principal acknowledging that the firm revised its written supervisory procedures (WSPS) to address the deficiencies described in the AWC, and the date the revised procedures were implemented.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1753},{"d":"2016-09-14","di":"2015-12-16","dr":"2016-09-14","k":"Regulatory Action","rg":"Other","reg":"Commissione Nazionale Per la Societa' E la Borsa (Consob)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"37969/2015 (95029/15)","al":"Alleged breach of disclosure of net short positions on the shares of an italian listed company active in the TMT sector","res":"Dismissed","sd":"Consob dismissed the allegations against Mediobanca. No sanction was issued.","ab":"Mediobanca - Banca Di","firms":[139138],"id":1754},{"d":"2016-09-14","di":"2016-09-14","dr":"2016-09-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":3500000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17538","al":"The SEC alleged that first reserve (I) did not provide appropriate disclosure or receive effective consent regarding certain buyout funds bearing certain expenses of two entities formed as investment advisers to (and owned by) a portfolio company of those buyout funds that was a pooled investment vehicle, (II) caused the first reserve funds to pay insurance premiums for a liability policy covering first reserve for risks that did not entirely arise from its management of the first reserve funds and (III) did not provide disclosure that first reserve received a legal fee discount from a law firm for itself for certain services while the first reserve funds did not receive a discount on the same services (although the funds received certain discounts on other types of services). In addition, first reserve did not adopt and implement written policies and procedures reasonably designed to prevent the above violations of the Advisers Act.","res":"Settled","sd":"The order imposes a civil penalty of $3.5 million. Pursuant to the order, the penalty will be paid within 10 business days of the entry of the order.","sm":"The SEC administrative order is final. The civil penalty will be paid within 10 business days of the entry of the order. No information Filed","ab":"First Reserve Management, L.P.","self":true,"firms":[157056],"id":1755},{"d":"2016-09-13","di":"2015-05-04","dr":"2016-09-13","k":"Civil Judicial Action","san":"Injunction","os":"Mediate current or former California customers who incurred fees or were harmed as a result of the unauthorized","st":"Final","fine":50000000.0,"al":"The complaint alleges that Wells fargo personnel engaged in various allegedly improper acts and practices designed to meet sales goals and quotas, such as opening accounts without customer authorization, misrepresenting that certain products were available only in packages with other products, misusing customer data in connection with the foregoing, and not disclosing such alleged misuse to customers. The complaint alleges that customers were harmed by, among other things, incurring unauthorized fees.","res":"Judgment Rendered","sd":"Fine of $50,000,000.00 paid","ab":"Wells Fargo & Company","firms":[11025,19616],"id":1756},{"d":"2016-09-12","di":"2016-09-12","dr":"2016-09-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":30000.0,"dk":"2014043168701","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1757},{"d":"2016-09-12","di":"2016-09-12","k":"Civil Judicial Action","os":"Unspecified damages to be determined at trial","st":"Pending","al":"Plaintiffs allege the following against the applicant, its control affiliate and other defendants: 1. A derivative claim for aiding and abetting breach of fiduciary duty against all defendants. 2.a derivative claim for unjust enrichment/constructive trust against all defendants. 3.a class action claim for breach of contract against the Santander entity defendants 4.a class action claim for breach of the covenant of good faith and fair dealing against the Santander entity defendants. Plaintiffs allege the following only against other defendants: 1.a derivative claim for violation of fiduciary duties owed to the funds and their shareholders pursuant to the general corporations act of the commonwealth of Puerto Rico against the director defendants. 2.a derivative claim for violation of duties as agent of the funds pursuant to the civil code of the commonwealth of Puerto Rico against Santander asset management.","ab":"Banco Santander, S.A.","firms":[143883],"id":1758},{"d":"2016-09-08","di":"2016-09-08","dr":"2016-09-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","os":"N/a","st":"Final","fine":600000.0,"dk":"3-17531","al":"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.","res":"Order","sd":"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.","sm":"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.","ab":"Raymond James &; Raymond James & Associates, Inc.","self":true,"firms":[705,149018],"id":1759},{"d":"2016-09-08","di":"2016-09-08","dr":"2016-09-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","os":"N/a","st":"Final","fine":250000.0,"dk":"3-17532","al":"SEC ia release 4526/September 8, 2016: the Securities and Exchange Commission (commission) deems it appropriate that cease-and- desist proceedings be, and hereby are, instituted pursuant to section 203(k) of the Investment Advisers Act of 1940 (Advisers Act), against Robert W. Baird & Co. Incorporated. This matter arises from the firm's failure to adopt and implement adequate policies and procedures to track and disclose trading away practices by certain of the subadvisors participating in the firm's wrap fee programs. The firm, in its advisory capacity, offers its advisory clients the opportunity to invest in separately managed wrap fee programs. Through these programs, the firm's advisory clients pay an annual fee in exchange for receiving access to select subadvisors and trading strategies, advice from the firm's financial advisors, and trade execution services through the firm at no additional cost. However, if a subadvisor chooses not to direct the execution of particular equity trades through the firm and the executing broker charges a commission or fee, the firm's advisory clients often are charged additional commissions or fees for those transactions. This practice is referred to as \"trading away\" and these types of trades are frequently called \"trade aways.\" Historically, the firm did not track or monitor which subadvisors were trading away from the firm, how often those subadvisors were trading away, or the specific costs associated with those trade aways. The firm began collecting cost information from subadvisors who were trading away but failed to adopt or implement any policies and procedures designed to provide information to the firm's clients and financial advisors about the amount of the additional costs of trading away. Without the availability of such information, the firm's financial advisors could not separately consider the costs associated with trading away practices in conducting their initial and periodic suitability analyses for advisory clients in wrap fee programs whose funds were managed by certain subadvisors. By failing to adopt and implement such policies and procedures, the firm violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.","res":"Order","sd":"The firm was ordered to cease and desist, fined $250,000 and ordered to comply with the undertakings enumerated in the order.","sm":"Baird, without admitting or denying the findings, consented to the sanctions and findings of the SEC that it violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder by failing to adopt and implement adequate policies and procedures to track and disclose trading away practices by certain of the subadvisors participating in baird's wrap fee programs offered through its private wealth management department. Through these programs, baird's advisory clients pay an annual fee in exchange for receiving access to select subadvisors and trading strategies, advice from baird's financial advisors, and trade execution services through baird at no additional cost. However, if a subadvisor chooses not to direct the execution of particular equity trades through baird in order to fulfill its best execution obligation and the executing broker charges a commission or fee, baird's advisory clients often are charged additional commissions or fees for those transactions, which is often embedded in the price paid or received for the security. This practice is referred to as \"trading away\" and these types of trades are frequently called \"trade aways.\" Baird was found to have failed to adopt or implement policies and procedures designed to provide specific information to baird's clients and financial advisors about the costs of trading away. Baird agreed to provide additional disclosure to clients and review and, as necessary, update its policies and procedures.in resolving this matter, the SEC recognized both the voluntary remedial acts promptly undertaken by baird and its cooperation with the SEC staff.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1760},{"d":"2016-09-06","di":"2016-09-06","k":"Regulatory Action","rg":"OCC","reg":"Comptroller of the Currency (OCC)","san":"Cease and Desist","os":"Compliance and risk management plan; pay reimbursement to affected consumers; civil money penalty.","st":"Final","fine":35000000.0,"dk":"AA-EC-2016-66 AND AA-EC-2016-67","al":"Without admitting or denying the findings, Wells Fargo Bank, N.A. (\"WFBNA\") consented to the entry of an order that its community bank group had unsafe or unsound practices in risk management and oversight of sales practices, and unsafe or unsound sales practices by selling unwanted deposit or credit card accounts, the unauthorized opening of such accounts, the transfer of funds to unauthorized accounts, and unauthorized credit inquiries to open the accounts.","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1761},{"d":"2016-09-04","di":"2016-09-04","dr":"2016-09-04","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau (CFPB)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Civil money penalties of $100,000,000.00; compliance and redress plans; independent consultant review, pay redress to affected","st":"Final","fine":100000000.0,"dk":"2016-CFPB-0015","al":"Without admitting or denying the findings, Wells Fargo Bank, N.A. (\"WFBNA\") consented to the entry of an order that its community bank group engaged in unfair and abusive practices by opening deposit accounts, transferring funds between accounts, applying for credit cards, issuing debit cards and enrolling customers in on-line banking services without the customers' consent.","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1762},{"d":"2016-08-31","di":"2016-08-31","dr":"2016-08-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","fine":2000000.0,"dk":"317520","al":"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.","res":"Order","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1763},{"d":"2016-08-26","di":"2016-08-26","dr":"2016-08-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"2014042962101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it made publicly available a report on its routing of non-directed orders in covered securities during the time period examined. The findings stated that these reports included incomplete information as to the identity of the venues to which the largest number of total non-directed orders were routed for execution and other venues to which five percent or more of non-directed orders were routed for execution.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $20,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1764},{"d":"2016-08-25","di":"2016-08-25","dr":"2016-08-25","k":"Regulatory Action","rg":"Other","reg":"Hawaii Department of Commerce and Consumer Affairs","san":"Cease and Desist","st":"Final","fine":19825.37,"dk":"SEU-2015-044","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Hawaii Department of Commerce and Consumer Affairs (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Hawaii representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Hawaii residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Hawaii residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $19,825.37. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1765},{"d":"2016-08-25","dr":"2016-08-25","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Customer remediation","st":"Final","fine":4500000.0,"dk":"2016-CFPB-0014","al":"The CFPB alleged that fnbo engaged in unfair billing and enrollment practices with respect to debt cancellation and credit monitoring products that resulted in violations of sections 1031 and 1036 of the Consumer financial protection act of 2010.","res":"Stipulation and Consent","sd":"Without admitting or denying the CFPB allegations, fnbo, pursuant to the order, agreed to pay a civil monetary penalty of $4,500,000 and make full reimbursements to eligible customers. Both the OCC and CFPB together have jointly ordered the repayment to customers which is estimated to total $27.75 million. Finally, fnbo agreed to the imposition of certain remedial measures in the areas of add-on products, service provider monitoring and unfair and deceptive acts and practices risk management.","sm":"Without admitting or denying the allegations as highlighted above in item 7, fnbo agreed to sanctions imposed as described above in item 12. No information Filed","ab":"First National Bank of","firms":[40258],"id":1766},{"d":"2016-08-24","di":"2016-08-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":40000.0,"dk":"2014042418001","al":"Without admitting or denying the findings, the firm consented to a censure and $40,000 fine for failing, during the period from January 1, 2014 through April 30, 2014, to accept or decline in the OTC reporting facility certain transactions within 20 minutes after execution.","res":"Acceptance, Waiver & Consent(AWC)","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1767},{"d":"2016-08-24","di":"2016-08-24","dr":"2016-08-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":2300000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17491","al":"The SEC alleged that WL ross failed to adequately disclose its fee allocation practices to certain private equity funds it advise (the \"WLR funds\") and their investors and that ambiguous language in its private equity fund limited partnership agreements resulted in certain WLR funds paying higher management fees bewteen 2001 and 2011.","res":"Settled","sd":"The order imposes a civil penalty of $2.3 million. The portion levied against WL ross is 100%. The penalty was paid on August 26, 2016","sm":"The SEC administrative order is final. In determining to accept the offer, the commission considered remedial acts promptly undertaken by WL ross and cooperation afforded the commission staff, including WL ross' self reporting of the transaction fee allocation issue to the ocie staff, WL ross' voluntary determination to revise its fee allocation methodology, and WL ross' voluntary reimbursement, with interest, of $11,873,571 in management fee credits resulting from its retroactive application of the revised allocation methodology to the inception of the WLR funds.","ab":"WL Ross & Co. LLC","firms":[105360],"id":1768},{"d":"2016-08-24","di":"2016-08-24","dr":"2016-08-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil penalty","st":"Final","fine":2300000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-17491","al":"The SEC alleged that WL ross failed to adequately disclose its fee allocation practices to certain private equity funds it advised (the \"WLR funds\") and their investors and that ambiguous language in its private equity fund limited partnership agreements resulted in certain WLR funds paying higher management fees bewteen 2001 and 2011.","res":"Settled","sd":"The order imposes a civil penalty of $2.3 million. The portion levied against WL ross is 100%. The penalty was paid on August 26, 2016","sm":"The SEC administrative order is final. In determining to accept the offer, the commission considered remedial acts promptly undertaken by WL ross and cooperation afforded the commission staff, including WL ross' self-reporting of the transaction fee allocation issue to the ocie staff, WL ross' voluntary determination to revise its fee allocation methodology, and WL ross' voluntary reimbursement, with interest, of $11,873,571 in management fee credits resulting from its retroactive application of the revised allocation methodology to the inception of the WLR funds.","ab":"WL Ross & Co. LLC","self":true,"firms":[107584,141854],"id":1769},{"d":"2016-08-23","di":"2016-08-23","dr":"2016-08-23","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":112500.0,"dk":"2013037434803","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and isc rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 23, 2016","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1770},{"d":"2016-08-23","di":"2016-08-23","dr":"2016-08-23","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Market Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"16-8893","al":"The market regulation department determined that J.P. Morgan Securities LLC (JPMS) violated rule 576 (\"identification of global terminal operators\") by failing to register 10 tag 50 ids in the exchange fee system which were required to be registered.","res":"Settled","sm":"In accordance with the summary notice, market regulation ordered JPMS to pay a fine to the CME group in the amount of $5,000. The fine was paid on August 25, 2016. The tag 50 ids have since been registered.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1771},{"d":"2016-08-22","di":"2016-08-22","dr":"2016-08-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":56250.0,"dk":"2013037434804","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and Nasdaq Stock Market rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 22, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1772},{"d":"2016-08-22","di":"2016-08-22","dr":"2016-08-22","k":"Regulatory Action","rg":"Other","reg":"Box Options Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":112500.0,"dk":"2013037434802","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and Box Options Exchange LLC rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 22, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1773},{"d":"2016-08-20","di":"2016-08-20","dr":"2016-08-20","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau (CFPB)","san":"Cease and Desist","os":"Compliance plan, remediation to borrowers, pay civil money penalties of $3,600,000 and provide a quarterly/annual tracking","st":"Final","fine":3600000.0,"dk":"2016-CFPB-0013","al":"Without admitting or denying the findings, Wells Fargo Bank, N.A. (\"WFBNA\") consented to the entry of an order that under certain scenarios and in certain timeframes its education financial services business (EFS)allocated partial payments, aggregated partial payments, and charged late fees in ways that were alleged to be unlawful.","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1774},{"d":"2016-08-19","di":"2016-08-19","dr":"2016-08-19","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":56250.0,"dk":"2013037434806","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and NYSE ARCA, Inc. rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 19, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1775},{"d":"2016-08-17","di":"2016-08-17","dr":"2016-08-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":6500.0,"dk":"2015047484601","al":"Without admitting or denying the findings, the firm consented to the sanction and to the entry of findings that it failed to report the correct trade execution time for transactions in trade reporting and compliance engine (TRACE)-eligible securitized products to TRACE and failed to show the correct execution time on brokerage order memoranda.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was fined $6,500.00","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1776},{"d":"2016-08-16","di":"2016-08-16","dr":"2016-08-16","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency","san":"Cease and Desist","os":"Civil money penalties and customer remediation","st":"Final","fine":3000000.0,"dk":"AA-EC-201S-71 AND AA-EC-201S-72","al":"The OCC alleged that fnbo engaged in unfair billing practices with regard to identity protection products that resulted in violations of section s of the federal trade commission act.","res":"Stipulation and Consent","sd":"Without admitting or denying the OCC allegations, fnbo agreed to cease and desist from violating section 5 of the FTC act and to pay a civil monetary penalty of $3,000,000 and make full reimbursements to eligible customers. Both the OCC and CFPB together have jointly ordered the repayment to customers which is estimated to total $27.75 million. Finally, fnbo agreed to the imposition of certain remedial measures in the areas of third-party vendor management and unfair and deceptive acts and practices risk management.","sm":"Without admitting or denying the allegations as highlighted above in item 7, fnbo agreed to sanctions imposed as described above in item 12.","ab":"First National Bank of","firms":[40258],"id":1777},{"d":"2016-08-16","di":"2016-08-16","dr":"2016-08-16","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","os":"Place limitations on the activities of steven Cohen.","st":"Final","dk":"CFTC DOCKET NO. SD 16-01","al":"On August 16, 2016, the CFTC issued an order (\"CFTC order\") accepting an offer of settlement from steven Cohen. The CFTC alleged that MR. Cohen is subject to statutory disqualification under section 8a(4) of the Commodity Exchange Act, as amended, due to the finding contained in the SEC's order (admin proceeding file no. 3-15950) of MR. Cohen's failure to supervise another person with a view to preventing violations of the Securities Exchange Act of 1934. Pursuant to the settlement, MR. Cohen neither admitted or denied any of the findings or conclusions in the CFTC order or the accompanying notice. The CFTC order restricts MR. Cohen from engaging in any activity requiring registration with the CFTC and/or acting as an officer or employee of any person registered or required to be registered with the CFTC through December 31, 2017, or through such later date as MR. Cohen's restriction under the SEC order is extended.","res":"Decision & Order of Offer of Settlement","sd":"See the response to question 7 above.","ab":"Cohen, Steven, Alan","firms":[283077],"id":1778},{"d":"2016-08-09","di":"2016-08-09","dr":"2016-08-09","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"RSRH-16-4375","al":"Alleged violation of CME rule 811 in which Citigroup Global Markets Inc. inaccurately reported to the exchange open interest positions during the period of June 1-30, 2016.","res":"Settled","sm":"The firm consented to a summary fine in the amount of $1,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1779},{"d":"2016-08-09","di":"2016-08-09","dr":"2016-08-09","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"RSRH-16-4375","al":"Alleged violation of CBT rule 811 in which Citigroup Global Markets Inc. inaccurately reported to the exchange open interest positions during the period of June 1-30, 2016.","res":"Settled","sm":"The firm consented to a summary fine in the amount of $1,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1780},{"d":"2016-08-09","di":"2016-08-09","dr":"2016-08-09","k":"Regulatory Action","rg":"State regulator","reg":"Mississippi Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease & desist; reimburse costs; restitution","st":"Final","fine":100000.0,"dk":"LS-12-0454","al":"The state of MS alleged the firm failed to reasonably supervise certain of its agents in the ridgeland, Mississippi branch so as to prevent and detect violations. In addition, they alleged the firm failed in some instances to enforce supervisory procedures to comply with the requirements to prevent and detect violations by certain of its agents in the ridgeland, Mississippi branch.","res":"Consent","sm":"On August 9, 2016, without admitting or denying the findings of fact or conclusions of law, the firm consented to the sanctions and to the entry of findings that it failed to reasonably supervise certain of its agents in the ridgeland, Mississippi branch so as to prevent and detect violations. In addition, the firm failed in some instances to enforce supervisory procedures to comply with the requirements to prevent and detect violations by certain of its agents in the ridgeland, Mississippi branch.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1781},{"d":"2016-08-08","di":"2016-08-08","dr":"2016-08-08","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"OFI-2016-001","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Louisiana Office of Financial Institutions (OFI) alleged that Citigroup Global Markets Inc. (CGMI) accepted client orders through sales assistants who were highly likely not registered in Louisiana, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Louisiana. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the ofi alleged that the acceptance of client orders in Louisiana through sales assistants that were highly likely not registered in Louisiana, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in Louisiana constituted bases for the assessment of an administrative fine pursuant to lsa-R.S. 51:710.1. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the ofi a sum in the amount of $35,000, Louisiana's allocated portion of the amount agreed to with nasaa. Finally, the ofi and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1782},{"d":"2016-08-05","di":"2016-08-05","dr":"2016-08-05","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":56250.0,"dk":"2013037434805","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and NYSE MKT rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on August 5, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1783},{"d":"2016-08-04","di":"2016-08-04","dr":"2016-08-04","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania, Department of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":135000.0,"dk":"160043 (SEC-CAO)","al":"The Commonwealth of Pennsylvania, Department of Banking and Securities (the \"department\"), alleged that Edward jones failed to reasonably supervise an agent in violation of section 305(a)(VII) of the Pennsylvania Securities Act of 1972 (the \"act\").","res":"Order","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1784},{"d":"2016-08-02","di":"2016-08-02","dr":"2016-08-02","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":36300000.0,"dk":"16-011-BH-C; 16-011-CMP-HC","al":"The Board of Governors of the Federal Reserve System (the \"Board of Governors\") has alleged that: (a) Goldman, Sachs & co. (\"GSCO\") and The Goldman Sachs Group, inc., (together with GSCO, the \"firm\") failed to monitor electronic mail for documents containing confidential supervisory information; (b) firm employees, including senior managers, had confidential supervisory information of the Board of Governors and other banking regulators in their possession without the authorization required by law; (c) a firm employee engaged in criminal theft of confidential supervisory information of the Board of Governors and other banking regulators, and disseminated such information to multiple employees within the firm; (d) the firm's personnel improperly used confidential supervisory information, including confidential supervisory information relating to institutions other than the firm, of the Board of Governors and other banking regulators in presentations to its clients and prospective clients in an effort to solicit business for the firm; and (e) the firm lacked adequate policies and procedures designed to detect or prevent the unauthorized dissemination and use of confidential supervisory information belonging to the Board of Governors and other banking regulators.","res":"Order","sm":"The firm and the Board of Governors entered into a consent order to cease and desist and assessment of civil money penalty on August 2, 2016 (the \"consent order\"), pursuant to which: (a) within 30 days of the consent order, the Board of directors of the firm shall appoint a committee comprised of members of senior management to monitor and coordinate compliance with the provisions of the consent order, which committee shall meet quarterly, keep detailed minutes of each meeting, and annually submit to the Board of Governors and the Board of directors of the firm written progress reports detailing the form and manner of all actions taken to secure compliance with the consent order and the results thereof; (b) within 90 days of the consent order, the firm shall: (I) submit to the Board of Governors a written plan, and timeline for implementation, to enhance the effectiveness of the internal controls and compliance functions regarding the identification, monitoring, and control of confidential supervisory information, which plan shall be reviewed for effectiveness by the firm's internal audit function; (II) submit to the Board of Governors a written plan, and timeline for implementation, for the training of all appropriate gsco personnel regarding the restrictions, controls and legal requirements governing the use of confidential supervisory information; and (III) certify to the Board of Governors that all documents containing confidential supervisory information of which the firm is aware or becomes aware that the firm obtained without appropriate regulatory authorization have been de- referenced from the firm's internal systems and rendered inaccessible by firm personnel, and to the extent such confidential supervisory information may be subsequently be restored or rendered accessible for any purpose, the firm shall notify the Board of Governors prior to such information being restored or accessible by firm personnel; (c) the firm shall not in the future directly or indirectly retain any individual as an officer, employee, agent, consultant, or contractor of the firm or of any affiliate of the firm who, based on the investigative record compiled by U.S. authorities, has done all of the following: (I) participated in the illegal conduct described in the consent order; (II) been subject to formal disciplinary action as a result of gsco's internal disciplinary review or performance review in connection with the conduct described in the consent order; and (III) has been separated from or has had his or her employment terminated by the firm; and (d) the firm paid a civil monetary penalty in the amount of $36,300,000 on August 3, 2016.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1785},{"d":"2016-07-29","di":"2016-07-29","dr":"2016-07-29","k":"Regulatory Action","rg":"Other","reg":"Chicago Baord of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"CBOT 149940BC","al":"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.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1786},{"d":"2016-07-27","di":"2016-07-27","dr":"2016-07-27","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":950000.0,"dk":"16-0003 CA","al":"On July 27, 2016, J.P. Morgan Securities LLC (\"JPMS\") and JPMorgan Chase Bank, N.A. (\"JPMCB\", together \"respondents\") entered into a consent agreement (\"agreement\") with the Indiana securities division (\"ISD\"). The respondents consented to the entry of the agreement that alleged that certain conduct of the respondents was outside the standards of honesty and ethics generally accepted in the securities trade and industry, in violation of 710 ind. Admin. Code§ 4­10­1(23) (2016). Specifically, the agreement alleged that, between 2008 and 2013, JPMS failed to disclose to Indiana investors that certain proprietary mutual funds purchased for chase strategic portfolio (\"CSP\") clients offered institutional shares that were less expensive than the institutional shares JPMS chose for CSP clients. In addition, the agreement alleged that, from February 2011 to January 2014, no account opening document or marketing materials disclosed to Indiana investment management account clients or Indiana J.P. Morgan investment portfolio clients that JPMCB preferred to invest client assets in proprietary mutual funds, and that between 2008 and January 2014, JPMCB did not disclose its preference for investing certain investment management account assets in certain proprietary hedge funds to Indiana clients. Lastly, the agreement alleged that, JPMCB did not disclose its preference for placement-agent-fee-paying third-party hedge fund managers in certain investment management accounts to Indiana clients until August 2015.","res":"Consent","sm":"Solely for the purpose of settling these proceedings, the respondents consented to the agreement, with no admissions as to liability. The allegations, dispositions, findings and sanctions of the agreement are described above in items 7 and 12.","ab":"JPMorgan Chase Bank, N.A.","firms":[79],"id":1787},{"d":"2016-07-27","di":"2016-07-27","dr":"2016-07-27","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Securities Division","san":"Cease and Desist","st":"Final","fine":28172.31,"dk":"2015-0464","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Maryland Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Maryland representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Maryland residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Maryland residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,172.31. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1788},{"d":"2016-07-27","di":"2016-07-27","dr":"2016-07-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":200000.0,"dk":"2014040147502","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm and a firm supervisor did not reasonably supervise a former registered representative's misuse of customer funds. The findings stated that the supervisor, who was the registered representative's direct supervisor, did not reasonably follow-up on red flags associated with a trade correction request submitted by the registered representative that should have alerted him to the registered representative's misuse of customer funds. The supervisor also did not follow certain of the firm's written supervisory procedures (WSPS) relating to trade corrections which, if followed, would have prevented the registered representative's misuse of customer funds. The findings also stated that in reviewing and approving the trade correction request, the supervisor did not follow some of the firm's WSPS. The firm's WSPS stated that customer losses caused by a registered representative's error would be borne by the firm or the registered representative. The WSPS further stated that supervisors were required to obtain and maintain documentation and verification of the reasons for, and details surrounding, the trade errors and correction. Contrary to these procedures, the supervisor approved the trade correction request when the resulting correction allocated the trade loss to the customer rather than the firm or the registered representative, and he did not reasonably document the reasons for, or details surrounding, the trade correction. After it became clear that the customer of the registered representative did not, in fact, agree to purchase the stock at above-market value, the firm reimbursed the customer for the loss. The findings also included that the firm did not establish and maintain a supervisory system, including WSPS, for correcting trade errors that was reasonably designed to ensure compliance with applicable securities laws, regulations and rules. In particular, the firm did not implement reasonable WSPS, guidance, or training to adequately describe the supervisory steps associated with reviewing, approving, and processing trade corrections. The firm's WSPS for handling trade corrections were vague and ambiguous and firm supervisors did not understand how to interpret or apply the procedures. FINRA found that the firm recognized, that its WSPS for correcting trade errors needed to be updated because they were vague and ambiguous. Nonetheless, the firm did not take any steps to enhance the WSPS or provide supervisors with training or guidance on the relevant WSPS until a year later. The firm did not complete its enhancement of its WSPS for trade corrections until early 2016.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $200,000, and undertakes to, within 30 days of approval of this AWC, provide a written certification to FINRA that the firm's systems, policies and procedures for correcting trade errors are reasonably designed to achieve compliance with applicable securities laws, regulations and rules.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1789},{"d":"2016-07-22","di":"2016-07-22","dr":"2016-07-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Louisiana","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":41040.17,"dk":"OFI2016004","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1790},{"d":"2016-07-20","di":"2016-07-20","dr":"2016-07-20","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Cease and Desist","st":"Final","fine":64363.95,"dk":"OFI-2016-003","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Louisiana Office of Financial Institutions (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Louisiana representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Louisiana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Louisiana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $64,363.95. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1791},{"d":"2016-07-19","di":"2016-07-19","dr":"2016-07-19","k":"Regulatory Action","rg":"Other","reg":"Hawaii Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"CASE NO. SEU-2015-029","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Hawaii Department of Commerce and Consumer Affairs (department) alleged that Citigroup Global Markets Inc. (CGMI) accepted client orders through sales assistants who were highly likely not registered in Hawaii, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Hawaii. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the department alleged that the acceptance of client orders in Hawaii through sales assistants that were highly likely not registered in Hawaii, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in Hawaii constituted bases for the assessment of an administrative fine pursuant to HRS §§ 485­18.7 and 485a­412(c) and (d)(9). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the department a sum in the amount of $35,000, Hawaii's allocated portion of the amount agreed to with nasaa. Finally, the department and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1792},{"d":"2016-07-18","di":"2016-07-18","dr":"2016-07-18","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Pennsylvania","san":"Other","os":"Administrative consent order and monetary fine","st":"Final","fine":125000.0,"dk":"160041","al":"The Commonwealth of Pennsylvania conducted an investigation of Janney Montgomery Scott LLC (\"Janney\") regarding a former financial advisor, who was terminated by the firm on July 27, 2010. It is alleged that Janney failed to reasonably supervise the financial advisor during the term of her employment, resulting in failure to detect and prevent a fraudulent scheme conducted by the former financial advisor.","res":"Order","sd":"The firm agreed to pay an administrative fine of $125,000 and $10,000 towards the cost of the investigation.","sm":"The Commonwealth of Pennsylvania, department of banking and securities, and Janney Montgomery Scott LLC entered into an administrative consent agreement and order, which was adopted by the Commonwealth through a final order filed on July 18, 2016. Based on the results of the investigation, which included the full cooperation of Janney, the firm consented to the findings, without admitting or denying the allegations, that the firm operated in violation of the Pennsylvania Securities Act of 1972, having failed to reasonably supervise the securities activities of the former financial advisor.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1793},{"d":"2016-07-18","di":"2016-07-18","dr":"2016-07-18","k":"Regulatory Action","rg":"State regulator","reg":"Montana Securities Department","san":"Cease and Desist","st":"Final","fine":11397.81,"dk":"SEC 2013-59","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Montana Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Montana representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Montana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Montana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $11,397.81 and investigative costs in the amount of $29,112.18. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1794},{"d":"2016-07-15","di":"2016-07-12","dr":"2016-07-15","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":25000.0,"dk":"2014042644601","al":"The business conduct committee (the \"committee\") of Nasdaq PHLX LLC (\"PHLX\") alleged that during the period between August 13, 2014 and August 15, 2014, Goldman, Sachs & co. (the \"firm\"): (I) effected transactions in an options position that resulted in one of the firm's customers exceeding the applicable position limit for three consecutive trading days, in alleged violation of PHLX rule 1001; and (II) failed to establish, maintain and enforce written supervisory procedures (\"WSPS\") and a system of supervision that was reasonably designed to detect and prevent violations of, and achieve compliance with, PHLX's position limit rule: specifically, the timing and review of the firm's position limit reports under its WSPS were not reasonably designed to timely detect certain position limit overages from the trade date, notify the firm's customers of such overages, or take corrective measures to reduce and prevent further overages, in alleged violation of PHLX rule 748(h).","res":"Decision","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine, a censure, and an undertaking to revise its WSPS, and entered into an offer of settlement, stipulation of facts and consent to sanctions with the committee which was accepted by the committee on July 15, 2016, and on August 1, 2016, the firm submitted a wire to PHLX in payment of the fine in the amount of $25,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1795},{"d":"2016-07-15","di":"2016-07-15","dr":"2016-07-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":12500.0,"dk":"2013037852901","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1796},{"d":"2016-07-14","dr":"2016-07-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq PHLX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":56250.0,"dk":"2013037434801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it: (1) failed to reconcile and accurately capture books and records data across multiple data systems and paper tickets for certain manual option orders (E.G., some combination of incorrect or missing data) in violation of Exchange Act rule 17A-3 which impacted thousands of options order tickets during the review period; (2) failed to store books and records in an easily accessible place as required by Exchange Act rule 17A-4; and (3) the firm's WSPS included supervisory reviews that were inadequately designed to ensure the accuracy of its manual options order tickets and the firm failed to maintain and enforce a system reasonably designed to supervise the operations of its business and ensure compliance with applicable federal securities laws and Nasdaq PHLX LLC rules pertaining to books and records for manual options orders.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent, final on July 14, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1797},{"d":"2016-07-12","di":"2016-07-12","dr":"2016-07-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil money penalty","st":"Final","fine":7000000.0,"dk":"3-17338","al":"Violation of section 17(a) of the Exchange Act and rules 17A-4(j) and 17A-25 thereunder in that Citigroup Global Markets Inc. (\"CGMI\") failed to furnish to the commission true and complete trade data in response to commission staff's electronic blue sheet (\"EBS\") requests between May 1999 and April 2014 due to an error in the computer code for CGMI's EBS response software.","res":"Order","sm":"The firm was ordered to cease and desist, censured, and ordered to pay a civil money penalty in the amount of $7,000,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1798},{"d":"2016-07-12","di":"2015-06-10","dr":"2016-07-12","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":75000.0,"dk":"15-0080/20150464504","al":"Alleged violation of exchange rules 3.6a and 4.2 in that Citigroup Global Markets Inc. failed to register certain associated persons as a proprietary trader on various dates between November 5, 2011 through August 3, 2015; failed to qualify certain associated persons as a proprietary trader principal on various dates from November 5, 2011 through August 21, 2015; failed to supervise from November 5, 2011 through August 3, 2015.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to a $75,000 fine and a censure.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1799},{"d":"2016-07-12","di":"2016-04-20","dr":"2016-07-12","k":"Regulatory Action","rg":"Other","reg":"California Department of Business Oversight","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":45000.0,"al":"On September 22, 2015, Beryl filed with California's department of business oversight (CA dbo) an initial form ADV, applying for an investment advisor certificate. In response to the commissioner of the CA dbo's inquiry about possible unlicensed investment adviser activities, Beryl provided additional information disclosing that, beginning in or about June 2013, Beryl had conducted business as an investment adviser in California to at least nine clients, without first applying for and securing from the commissioner a certificate, then in effect, authorizing Beryl to do so, in violation of California corporations code section 25230, subdivision (a). On July 12, 2016, Beryl entered into a stipulation agreement with the CA dbo and consented to desist and refrain from engaging in investment adviser activities unless and until certification has been made under the California corporate securities law of 1968 (CSL) or unless exempt. Beryl stipulated to undertake all appropriate steps designed to assure full compliance with the laws of California in connection with the licensing of Beryl's business as an investment adviser. Beryl agreed to pay the CA dbo an administrative penalty in the amount of $45,000.00 (administrative penalty) pursuant to California corporations code section 25532, subdivision (b).","res":"Stipulation and Consent","ab":"Beryl Capital Management, LLC","self":true,"firms":[269959],"id":1800},{"d":"2016-07-05","di":"2016-07-05","dr":"2016-07-05","k":"Regulatory Action","rg":"State regulator","reg":"Wyoming Secretary of State Compliance Division","san":"Cease and Desist","st":"Final","fine":12344.55,"dk":"15-03","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Wyoming Secretary of State Compliance Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Wyoming representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Wyoming residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Wyoming residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $12,344.55. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1801},{"d":"2016-06-30","di":"2016-06-30","dr":"2016-06-30","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Restitution","os":"Cease and desist, censure, fine, changes to policies and procedures, employee training.","st":"Final","fine":100000.0,"dk":"E-2015-0112","al":"The enforcement section alleged that during the time period of January 1, 2014 to June 30, 2016, LPL Financial LLC failed to supervise its agents when it failed to review those agents' misleading communications with the public in connection with the purchase and sale of an agents' book of business. The enforcement section also alleged that LPL Financial LLC failed to supervise its agent when such agent borrowed money from a client and lost that money in speculative trading for his own account.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1802},{"d":"2016-06-29","di":"2016-06-29","dr":"2016-06-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont, Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist order","st":"Final","fine":5950000.0,"dk":"16-026-S","al":"Violation of 9 Vermont Securities Act (VSA) 5412(d)(9)","res":"Order","sd":"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.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":1803},{"d":"2016-06-28","di":"2016-06-28","dr":"2016-06-28","k":"Regulatory Action","rg":"Other","reg":"Vermont Department of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"16-25-S","al":"The state of Vermont Department of Financial Regulation alleged that Wells fargo advisors, LLC failed to reasonably supervise a registered representative with regard to the use of investments in non-traditional ETFS; failed to establish and maintain an adequate supervisory system in connection with the sale of and investment in non-traditional ETFS; failed to follow written supervisory procedures with respect to the use of and investment in non-traditional ETFS; and allowed a registered representative to recommend unsuitable products to a customer, all in violation of 9 vsa section 5412(d)(9).","res":"Consent","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings. Therefore, the firm is censured and fined $300,000.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1804},{"d":"2016-06-23","di":"2016-06-23","dr":"2016-06-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":5000000.0,"dk":"2012032967901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it sold approximately $168 million of structured notes known as \"strategic return notes\" (SRNS) linked to a proprietary volatility index, without adequately disclosing certain fixed costs. The findings stated that the firm emphasized in offering materials that investors would be subject to a 2% sales commission and a 0.75% annual fee in connection with the SRNS. The firm also disclosed a third fixed, regularly occurring cost included in its proprietary volatility index known as the \"execution factor\" (distinct from \"holding\" or \"decay\" costs associated with daily calculation of the underlying index which are variable and depend on market conditions), but did not do so in the same manner as the sales commission and annual fee. As a result, the firm's disclosures in the offering materials of the fixed costs associated with the SRNS were materially misleading, were not fair and balanced and failed to provide a sound basis for evaluation of the SRNS by not adequately disclosing the execution factor. The findings also stated the firm failed to maintain supervisory procedures reasonably designed to ensure compliance with applicable disclosure standards in connection with the sale of the SRNS.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $5,000,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1805},{"d":"2016-06-23","di":"2016-06-23","dr":"2016-06-23","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":10000000.0,"dk":"3-17314","al":"SEC admin release 33-10103 / June 23, 2016: the Securities and Exchange Commission (\"commission\") deems it appropriate and in the public interest that cease-and-desist proceedings be, and hereby are, instituted pursuant to section 8a of the Securities Act of 1933 (\"Securities Act\") against Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\" or \"respondent\"). On the basis of this order and Merrill lynch's offer, the commission finds that these proceedings involve Merrill lynch's failure to adequately disclose certain fixed costs in a proprietary volatility index linked to structured notes known as strategic return notes (\"SRNS\") of a bank. Merrill lynch offered and sold approximately $150 million of these volatility notes to approximately 4,000 retail investor accounts in 2010 and 2011. The disclosures made it appear as if the volatility product had relatively low fixed costs. The offering materials emphasized that investors would be subject to a 2 percent sales commission and a 0.75 percent annual fee. The offering materials failed to adequately disclose a third fixed, regularly occurring cost included in its proprietary volatility index known as the \"execution factor\" (distinct from \"holding\" or \"decay\" costs associated with daily calculation of the underlying index which are variable and depend upon market conditions). As a result, the disclosures in the offering materials of the fixed costs associated with the SRNS were materially misleading. As an issuer of securities, the bank had a duty to disclose all material information necessary to make statements contained in the retail pricing supplements, in light of the circumstances under which they were made, not misleading. The bank delegated to Merrill lynch principal responsibility for drafting and reviewing the retail pricing supplements. Within Merrill lynch, primary responsibility for drafting and reviewing the retail pricing supplements was spread among different groups (as supplemented by outside counsel). Merrill lynch failed to have in place an effective policy, procedure or internal communication process to provide reasonable assurances that the individuals with primary responsibility for drafting, reviewing and approving the retail pricing supplements prepared disclosures for the bank regarding the execution factor that were not materially misleading in light of the disclosure of other fixed, regularly occurring costs. As a result of the negligent conduct, Merrill lynch violated section 17(a)(2) of the Securities Act which prohibits obtaining money or property by means of material misstatements and omissions in the offer or sale of securities.","res":"Order","sm":"In anticipation of the institution of these proceedings, Merrill lynch has submitted an OFFER of settlement (\"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 herein, except as to the commission's jurisdiction over it and the subject matter of these proceedings, which are admitted, Merrill lynch consents to the entry of this order instituting cease-and-desist proceedings pursuant to section 8a of the Securities Act of 1933, making findings and imposing a cease-and-desist order. Accordingly, pursuant to section 8a of the Securities Act, it is hereby ordered that: Merrill lynch cease and desist from committing or causing any violations and any future violations of section 17(a)(2) of the Securities Act. Merrill lynch shall, within ten (10) days of the entry of this order, pay a civil monetary penalty in the amount of $10 million to the Securities and Exchange Commission.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1806},{"d":"2016-06-23","di":"2016-06-23","dr":"2016-06-23","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; disgorgement; prejudgment interest","st":"Final","fine":358000000.0,"dk":"3-17312","al":"On June 23, 2016, the Securities and Exchange Commission (\"SEC\") issued an administrative order in which it found that Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill Lynch\") and Merrill Lynch professional clearing corp. (\"MLPRO\") (collectively, \"ML\") had willfully violated section 15(c)(3) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 15C3-3 thereunder and section 17(a)(1) of the Exchange Act and rules 17A-3(a)(10) and 17A-5(a) thereunder, and that Merrill Lynch willfully violated section 17(a)(1) of the Exchange Act and rules 17A-5(d)(3) (as it existed prior to amendments to rule 17A-5 in 2014), 17A-5(d)(2)(II), 17A-5(d)(3) and 17A-11(e) thereunder, and Exchange Act rule 21F-17. Specifically, the order found that (I) ML engaged in a series of complex trades that allowed it to use customer cash to finance firm inventory and (II) Merrill Lynch allowed certain of its clearing banks to hold liens on customer securities.","res":"Order","sm":"In determining to accept ML's offer, the SEC considered remedial acts promptly undertaken by ML and substantial cooperation afforded the SEC staff during the course of its investigation. In the order, (I) Merrill Lynch and mlpro were censured, (II) Merrill Lynch was ordered to cease and desist from committing or causing any violations and any future violations of sections 15(c)(3) and 17(a)(1) of the Exchange Act and rules 15C3-3, 17A-3(a)(10), 17A-5(a), 17A-5(d)(2)(II), 17A-5(d)(3), 17A-11(e) and 21F-17 thereunder, (III) mlpro was ordered to cease and desist from committing or causing any violations and any future violations of sections 15(c)(3) and 17(a)(1) of the Exchange Act and rules 15C3-3, 17A-3(a)(10) and 17A-5(a) thereunder, (IV) Merrill Lynch and mlpro were ordered to pay disgorgement of $50,000,000 and prejudgment interest in the amount of $7,000,000, and (v) Merrill Lynch was ordered to pay a civil monetary penalty of $358,000,000. No customers were harmed, and the issues related to ML's procedures and controls have been corrected. The penalty was paid on June 29, 2016.","ab":"Merrill Lynch","firms":[7691],"id":1807},{"d":"2016-06-22","di":"2016-06-22","dr":"2016-06-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":200000.0,"dk":"2011029749101","al":"FINRA alleged that between 2009 and 2010 MSSB failed to adequately supervise by following firm policies and procedures to detect and cause the reporting of potentially suspicious transactions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, Morgan Stanley Smith Barney (MSSB) entered into a letter of acceptance, waiver and consent to settle allegations that MSSB violated NASD conduct rule 3011(a) (for conduct on or before December 31, 2009) and FINRA rules 3310(a) (for conduct after January 1, 2010) relating to the asheville, North Carolina branch office's failure to adequately supervise the checking activities of a client to detect suspicious checking activity.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1808},{"d":"2016-06-20","di":"2016-06-20","dr":"2016-06-20","k":"Regulatory Action","rg":"Other","reg":"Commissioner of Securities, Department of Commerce and Consumer Affairs, Hawaii","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":47703.26,"dk":"SEU-2008-048","al":"Various state regulators, including the Commissioner of Securities, Department of Commerce and Consumer Affairs, Hawaii, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Commissioner of Securities, Department of Commerce and Consumer Affairs, Hawaii, alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Commissioner of Securities, Department of Commerce and Consumer Affairs, Hawaii, on June 20, 2016, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $47,703.26 to the Commissioner of Securities, Department of Commerce and Consumer Affairs, Hawaii, which amount was paid on June 28, 2016.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1809},{"d":"2016-06-17","di":"2016-05-18","dr":"2016-06-17","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2015-058","al":"The BCC subcommittee determined Wedbush may have violated exchange rule 6.15(a) in which it failed to report large trader positions in multiple instances January 2015 through April 2015 and September 2015 through October 2015. Also, Wedbush may have violated exchange rule 4.01 in which it failed to have an adequate process or procedure in place.","res":"Settled","sd":"Wedbush paid a fine of $20,000 and agreed to cease and desist from future violations of exchange rule 6.15(a)","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1810},{"d":"2016-06-10","di":"2016-06-10","dr":"2016-06-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":125000.0,"dk":"2014043628201","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1811},{"d":"2016-06-08","di":"2016-06-08","dr":"2016-06-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil penalty","st":"Final","fine":1000000.0,"dk":"3-17280","al":"The SEC found that Morgan Stanley Smith Barney (\"MSSB\") willfully violated rule 30(a) of regulation s­p (17 c. F. R. § 248.30(a)) (the \"safeguards rule\"). In particular, the SEC found that, prior to December 2014, although MSSB had adopted written policies and procedures relating to the protection of customer records and information, those policies and procedures were not reasonably designed to safeguard its customers' personally identifiable information as required by the safeguards rule and therefore failed to prevent a MSSB employee, who was subsequently terminated, from misappropriating customer account information.","res":"Order","sm":"In determining to accept the offer resulting in the order, the SEC considered the remedial efforts promptly undertaken by MSSB and MSSB's cooperation afforded to the SEC staff.","ab":"Morgan Stanley Smith Barney LLC","self":true,"firms":[149777],"id":1812},{"d":"2016-06-03","di":"2016-06-03","dr":"2016-06-03","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"CME 15-0242-BC","al":"CME Group alleged that dbag London branch executed an exchange for related position (\"EFRP\") transaction on June 30, 2015 in which the related position transaction was established and offset without the incurrence of market risk. The transaction was transitory in nature and therefore non-bona fide. As a result, CME alleged that dbag violated exchange rule 538.c.","res":"Decision","sm":"Without admitting or denying any rule violations, dbag London branch agreed to pay the fine of $15,000.00 which was paid on June 6, 2016.","ab":"Deutsche Bank AG London","firms":[300838],"id":1813},{"d":"2016-06-02","di":"2016-04-15","dr":"2016-06-02","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"16-0011/ 20150461188","al":"The business conduct committee (\"BCC\") of the Chicago Board Options Exchange (\"CBOE\") issued a statement of charges alleging J.P. Morgan Securities LLC (\"JPMS\") violated exchange rule 6.74a - automated improvement mechanism (\"AIM\"). The BCC alleges that during the period of June 1, 2014 through June 30, 2014, JPMS responded to approximately 2,152 AIM auctions and received executions on approximately 6,056 contracts, while it did not hold an appointment in the relevant options classes.","res":"Decision & Order of Offer of Settlement","sm":"This is a final action resolved by decision & order of offer of settlement dated June 06, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1814},{"d":"2016-06-02","di":"2015-09-09","dr":"2016-06-02","k":"Regulatory Action","rg":"Other","reg":"C2 Options Exchange, Incorporated (The \"Exchange\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":75000.0,"dk":"FILE NO. C2 15-0015","al":"The C2 options exchange, incorporated (C2) alleged that the firm failed to register its financial and operations principal as a financial/operations principal with C2, failed to register certain associated persons as proprietary trader principals (TP) with C2, failed to register the minimum number of TPS with C2, failed to register certain associated persons as proprietary traders with C2 and failed to register its chief compliance officer as a proprietary trader compliance officer with C2 in violation of C2 rule 3.4. The firm submitted a letter of consent, without admitting or denying that a violation of C2 rules was committed.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying that a violation of the C2 rules was committed, the firm consented to the imposition of the following sanctions: (1) a censure, and (2) a fine in the amount of $75,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1815},{"d":"2016-06-02","di":"2016-06-02","dr":"2016-06-02","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":33000.0,"dk":"FILE NO. 15-0091","al":"The Chicago Board Options Exchange, Incorporated (CBOE) alleged that the firm failed to register certain associated persons as proprietary traders with CBOE, failed to register an associated person as a proprietary trader principal with CBOE and failed to register its chief compliance officer as a proprietary trader compliance officer with CBOE in violation of CBOE rule 3.6a. The firm submitted a letter of consent, without admitting or denying that a violation of CBOE rules was committed.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying that a violation of the CBOE rules was committed, the firm consented to the imposition of the following sanctions: (1) a censure, and (2) a fine in the amount of $33,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1816},{"d":"2016-06-01","di":"2016-06-01","dr":"2016-06-01","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"CME 15-0242-BC","al":"Execution of an exchange for realted position (\"EFRP\") transaction in which the related position was transitory in nature and therefore non-bona fide.","res":"Settled","sd":"A $15,000 fine was paid by the adviser on June 6, 2016. No portion was waived.","sm":"On June 1, 2016, a panel of the CME business conduct committee found that on June 30, 2015, the adviser violated exchange rule 538.c by executing an exchange for related position (\"EFRP\") transaction in which the related position transaction was established and offset without the incurrence of market risk. An offer of settlement was approved by a panel of the CME business conduct committee on June 1, 2016, in which the adviser neither admitted nor denied the rule violation on which the penalty was based. On June 6, 2016, the adviser paid in full a fine of $15,000 in connection with the settlement. No information Filed","ab":"Pointstate Capital LP","self":true,"firms":[161110],"id":1817},{"d":"2016-05-27","di":"2016-05-27","dr":"2016-05-27","k":"Regulatory Action","rg":"CME Group","reg":"CME Group Market Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"16-8828-CBOT","al":"The market regulation department determined that J.P. Morgan Securities LLC (JPMS) violated rule 536.f by having >10% data entry errors for trade dates of November 17, 2015 through January 8, 2016 (23 data entry errors or 13.29%) triggering an automatic fine of $5,000.","res":"Settled","sm":"Without admitting or denying the findings, JPMS consented to a fine of $5,000 which was paid on 10, 2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1818},{"d":"2016-05-26","di":"2016-05-26","dr":"2016-05-26","k":"Regulatory Action","rg":"State regulator","reg":"Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cost of investigation","st":"Final","fine":5000.0,"dk":"SEC-2015-00060","al":"Alleged failure to enforce written policies and procedures, failing to exercise diligent supervision over the activities of its agents, and recommending a purchase of a security without reasonable grounds.","res":"Settled","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1819},{"d":"2016-05-25","di":"2016-05-25","dr":"2016-05-25","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"CFE 15-0023","al":"JPMS LLC recently agreed to settle a CBOE Futures Exchange action for $20,000 without admitting/denying findings that the firm had submitted the wrong CBOE account type code in numerous orders to the exchange for 2+ years.","res":"Consent","sm":"This is a final action resolved by letter of consent, approved on 5/25/2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1820},{"d":"2016-05-25","di":"2016-05-25","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil monetary penalty, undertakings","st":"Final","fine":250000000.0,"dk":"16-16","al":"Citibank, N.A. submitted an offer of settlement, which the Commodity Futures Trading Commission (\"CFTC\") accepted. The CFTC issued an order which Citibank, N.A. consented to without admitting or denying the order's findings. Citibank, N.A. agreed to pay a penalty of $250,000,000 and to implement and improve its internal controls and procedures in a manner reasonably designed to ensure the integrity of the fixing of any interest-rate swap benchmark. The order alleges that from 2007 through January 2012, Citibank, by and through certain of its traders, on multiple occasions attempted to manipulate the U.S. dollar isdafix.","res":"Order","sm":"Ust t t t e space p o ded) Citibank, N.A., without admitting or denying the findings or conclusions therein, consented to an order by the CFTC instituting proceedings pursuant to sections 6(c), 6(d) and 9(a)(2) of the Commodity Exchange Act, 7 U.S.C. Sections 9, 13b, 13(a)(2) (2006), and for conduct occurring on or after August 15, 2011, sections 6(c)(1), 6(c)(1)(a), 6(c)(3), 6(d) and 9(a)(2) of the Commodity Exchange Act, 7 U.S.C. Sections 9(1), 9(1)(a), 9(3), 13b, 13(a)(2) (2012) and regulations 180.1(a) and 180.2, 17 C.F.R. Sections 180.1(a), 180.2 (2015), making findings and imposing remedial sanctions. The order requires Citibank, N.A. to pay a civil monetary penalty of $250,000,000, cease and desist from violating sections 6(c)(1), 6(c)(1)(a), 6(c)(3), 6(d) and 9(a)(2) of the Commodity Exchange Act, 7 U.S.C. Sections 9(1), 9(1)(a), 9(3), 13b, 13(a)(2) (2012) and regulations 180.1(a) and 180.2, 17 C.F.R. Sections 180.1(a), 180.2 (2015), and to implement and improve its internal controls and procedures in a manner reasonably designed to ensure the integrity of the fixing of any interest-rate swap benchmark.","ab":"Citibank, N.A.","firms":[7059],"id":1821},{"d":"2016-05-25","di":"2016-05-25","dr":"2016-05-25","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Cease and Desist","os":"Civil monetary penalty, undertakings","st":"Final","fine":175000000.0,"dk":"16-17","al":"Citibank, N.A., Citibank Japan LTD. and Citigroup Global Markets Japan inc. submitted an offer of settlement, which the Commodity Futures Trading Commission (\"CFTC\") accepted. The CFTC issued an order which the firms consented to without admitting or denying the order's findings. The firms agreed to pay a penalty of $175,000,000 and to enhance the integrity and reliability of their benchmark interest rate submissions. The order alleges that certain of the firms' employees: (1) from February 2010 through August 2010, on multiple occasions, attempted to manipulate the London interbank offered rate (\"LIBOR\") for yen; (2) from April ( ) ( ) 2010 through June 2010, at times attempted to manipulate the euroyen tokyo interbank offered rate (\"euroyen tibor\"), and, on a few occasions, falsely reported market information with respect to euroyen tibor; and (3) from spring 2008 through summer 2010, at times falsely reported market information with respect to U.S. dollar LIBOR.","res":"Order","sm":"Citibank N.A., Citibank Japan LTD. and Citigroup Global Markets Japan inc., without admitting or denying the findings or conclusions therein, consented to an order by the CFTC instituting proceedings pursuant to sections 6(c), 6(d) and 9(a)(2) of the Commodity Exchange Act, 7 U.S.C. Sections 9, 13b and 13(a)(2) (2006), making findings and imposing remedial sanctions. The order requires the firms to pay a civil monetary penalty of $175,000,000, cease and desist from violating sections 6(c), 6(d) and 9(a)(2) of the Commodity Exchange Act, 7 U.S.C. Sections 9, 13b and 13(a)(2) (2012), and to enhance the integrity and reliability of their benchmark interest rate submission(s), presently and in the future, and to identify, construct and promote effective methodologies and processes of setting benchmark interest rates, in coordination with efforts by benchmark publishers.","ab":"Citibank, N.A.","firms":[7059],"id":1822},{"d":"2016-05-24","di":"2011-03-31","dr":"2016-05-24","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptrollerof the Currency (\"OCC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000000.0,"dk":"2016-56 AMENDS 2011-051, 2013-132, 2015-067, AND AA-EC-11-19 TO TERMINATE. 2016-055 (AA-EC-2016-30) ORDER FOR CIVIL PENALTY","al":"Wells Fargo Bank, N.A. failed to comply with certain provisions of prior OCC consent orders relating to certain residential mortgage servicing practices from prior consent orders. # 2016-055 (AA-EC-2016-30) orders Wells Fargo Bank, N.A. pay a $ 70,000,000. Civil money penalty.","res":"Stipulation and Consent","ab":"Wells Fargo Bank, N. A.; Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1823},{"d":"2016-05-24","di":"2016-05-24","dr":"2016-05-24","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange (\"NYMEX\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"NYMEX 15-0213-BC-2","al":"Execution of exchange for related position (\"EFRP\") transactions in which the related positions were transitory in nature and therefore non-bona fide.","res":"Settled","sd":"A $35,000 fine was paid by the adviser on June 1, 2016. No portion was waived.","sm":"On May 24, 2016, a panel of the NYMEX business conduct committee found that on January 5, 2015 and March 3, 2015, the adviser violated New York Mercantile Exchange (\"NYMEX\") rule 538.c by executing several exchange for related position (\"EFRP\") transactions in various energy products in which the related position for each transaction was offset to avoid material risk. An offer of settlement was approved by a panel of the NYMEX business conduct committee on May 24, 2016, in which the adviser neither admitted nor denied the rule violations on which the penalty was based. On June 1, 2016, the adviser paid in full a fine of $35,000 in connection with the settlement.","ab":"Pointstate Capital LP","self":true,"firms":[161110],"id":1824},{"d":"2016-05-20","di":"2016-05-20","dr":"2016-05-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":50000.0,"dk":"2013035981901","al":"Alleged violation of FINRA rules 2360(b)(3), 2360(b)(5), 2010, and 3110, as well as NASD rule 3010, in that Citigroup Global Markets Inc.: (a) exceeded the relevant position limit in certain securities between July 2013 and February 19, 2013; (b) failed to report and failed to correctly report certain conventional options positions to the large options positions report at certain times between January 28, 2013 and January 2015; and (c) failed to maintain an adequate system of supervision to comply with the reporting of positions to the lopr system between January 2010 and June 2015.an adequate system of supervision for the period between January 2010 and June 2015.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm agreed to a censure and a fine of $50,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1825},{"d":"2016-05-18","di":"2016-05-18","dr":"2016-05-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"2013039539801","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) during the period of January 30, 2009 through December 31, 2011, Goldman, Sachs & co. (the \"firm\"), acting as a program dealer in auction rate securities (\"ARS\"), submitted inaccurate information in certain respects regarding the result of an auction in certain instances to the MSRB's SHORT-term obligation rate transparency (\"SHORT\") system: specifically, that the firm erroneously reported rate types for the ARS indicating that the interest rates were set by auction rather than the maximum interest rates, in alleged violation of MSRB rule G-34; and (II) 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 MSRB rules, relating to MSRB rule g- 34 concerning SHORT reporting of rate types, in alleged violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on May 18, 2016, and on May 31, 2016, the firm submitted a wire in payment of a fine in the amount of $50,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1826},{"d":"2016-05-18","di":"2016-05-18","dr":"2016-05-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":8000000.0,"dk":"2014043592001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, and its amlco, failed to establish and implement policies and procedures to reasonably detect and cause the reporting of suspicious transactions. The findings stated that as the firm's amlco, the representative was responsible for ensuring that the firm's AML program was adequately tailored to the firm's business and for appropriately monitoring, detecting and reporting suspicious activity. Despite the separate AML departments and programs, the firm as a clearing firm, its amlco, and the firm for which the firm served as clearing firm created a system under which this firm heavily relied upon its clearing firm to provide certain systems and tools as part of the firm's AML program. The firm failed to commit adequate resources to the firm's AML programs. The firm's staffing of its AML departments was inadequate in light of the extensive responsibilities assigned to the few individuals, including the labor-intensive manual reviews, particularly in light of the firm's growth. The findings also stated that the firm failed to establish and implement AML procedures and systems reasonably expected to detect suspicious activity. The firm failed to establish reasonable written procedures for certain aspects of the firm's AML programs. The firm failed to establish reasonable AML systems tailored to its business. The AML procedures that were in place required the firm to review accounts for potential suspicious activity. The firm, however, failed to develop and implement surveillance reports tailored to detect certain types of potentially suspicious transactions. For example, the firm had no written procedures requiring review of, or surveillance reports monitoring for, the following high-risk activities: transfers of funds to unrelated accounts without any apparent business purpose; journaling securities and cash between unrelated accounts for no apparent business purpose, particularly internal transfers of cash from customer accounts to employee or employee-related accounts; and movement of funds, by wire transfer or otherwise, from multiple accounts to the same third party account. The firm's surveillance reports failed to reasonably monitor for suspicious activity. The findings also included that the firm failed to reasonably investigate red flags. As a result of the firm's AML procedures, the firm had gaps in its surveillance of activity for AML red flags. Even when the exception reports or other surveillance identified red flags, the firm failed to reasonably investigate many instances in order to determine whether a sar should be filed. Also, although the firm AML analysts identified some red flags and opened investigations, the investigations were deficient. FINRA found that the firm failed to reasonably enforce its due diligence procedures for certain correspondent accounts of certain foreign financial institutions (FFIS). Moreover, the firm also had no reliable periodic review process in place to ensure that the activity in the FFIS' accounts was consistent with representations made by FFIS at the time of account opening. This failure resulted in the firm performing no periodic risk reviews of a portuguese ffi account, even though the ffi was assigned a high-risk rating by the firm. FINRA also found that the firm failed to establish, maintain, and enforce a supervisory system reasonably designed to achieve compliance with section 5 of the Securities Act through incomplete risk reviews, due diligence failures, and failures to implement existing procedures relevant to low priced","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $8,000,000 and required to conduct a comprehensive review of the adequacy of its AML and supervisory policies, systems, procedures, and training. At the conclusion of the review, which shall be no more than 180 days after the date of the notice of acceptance of this AWC, the firm shall certify that its procedures are reasonably designed to achieve compliance with FINRA rule 3310. The certification shall be provided in a written letter to FINRA. The letter shall be accompanied by a written report, at a minimum, stating (I) the adequacy of the firm's policies, systems, procedures and training relating to AML and supervision; (II) a description of the review performed and the conclusions reached; and (III) recommendations for modifications and additions to the firm's policies, systems, procedures and training. The $8,000,000 fine was paid on 5/26/16.","ab":"Raymond James Financial","firms":[705],"id":1827},{"d":"2016-05-18","di":"2014-06-04","dr":"2016-05-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":1000000.0,"dk":"2012034934301","al":"The firm was named a respondent in a FINRA complaint alleging that it failed to provide trade data requested by the SEC and FINRA, commonly known as \"blue sheets,\" for more than 160,000 trades that it executed for correspondent firms, and failed to properly submit blue sheets requested by the SEC and FINRA for more than 5.6 million trades. The firm knew or should have known that its blue sheet submissions to the SEC were inaccurate and incomplete. The complaint alleges that these failures were due in part to the firm's lack of an adequate audit system providing for accountability of its blue sheet submissions and its lack of a supervisory system and procedures for supervision reasonably designed to achieve compliance with applicable securities laws and regulations and with applicable FINRA and NASD rules for electronic blue sheet reporting requirements. The firm knew or should have known that its audit system did not provide for accountability of its blue sheet submissions. As a result, the firm willfully violated section 17(a) of the Securities Exchange Act of 1934 and rules 17A-4(f)(3)(v), 17A-4(j) and 17A-25 thereunder, and FINRA rule 2010.","res":"Decision","sd":"The firm was fined $1,000,000 and ordered to pay costs of $9,085.21.","sm":"Extended hearing panel decision rendered August 27, 2015 wherein the firm was fined in the aggregate $1,000,000 and ordered to pay costs in the amount of $9,085.21. On September 21, 2015, the firm appealed the decision to the nac. On May 18, 2016, the firm withdrew its appeal of the extended hearing panel decision. Accordingly, the matter is now final.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1828},{"d":"2016-05-18","di":"2016-05-18","dr":"2016-05-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":17000000.0,"dk":"2014043592001","al":"Without admitting or denying the findings, Raymond james and associates (herein, \"the firm\") consented to the sanctions and to the entry of findings that it failed to establish and implement policies and procedures to reasonably detect and cause the reporting of suspicious transactions. The findings stated that as the firm's amlco, the representative was responsible for ensuring that the firm's AML program was adequately tailored to the firm's business and for appropriately monitoring, detecting and reporting suspicious activity. Despite the separate AML departments and programs, the firm as a clearing firm, its amlco, and Raymond James Financial services, inc. for which the firm served as clearing firm created a system under which this firm heavily relied upon its clearing firm to provide certain systems and tools as part of the firm's AML program. The firm failed to commit adequate resources to the firm's AML programs. The firm's staffing of its AML departments was inadequate in light of the extensive responsibilities assigned to the few individuals, including the labor-intensive manual reviews, particularly in light of the firm's growth. The findings also stated that the firm failed to establish reasonable written procedures for certain aspects of the firm's AML programs. The firm failed to establish reasonable AML systems tailored to its business. The AML procedures that were in place required the firm to review accounts for potential suspicious activity. The firm, however, failed to develop and implement surveillance reports tailored to detect detain types of potentially suspicious transactions. For example, the firm had no written procedures requiring review of, or surveillance reports monitoring for, the following high-risk activities: transfers of funds to unrelated accounts without any apparent business purpose; journaling securities and cash between unrelated accounts for no apparent business purpose, particularly internal transfers of cash from customer accounts to employee or employee-related accounts; and movement of funds, by wire transfer or otherwise, from multiple accounts to the same third party account. The firm's surveillance reports failed to reasonably monitor for suspicious activity. The finds also included that the firm failed to reasonably investigate red flags. As a result from the firm's AML procedures, the firm had gaps in its surveillance of activity for AML red flags, the firm failed to reasonably investigate many instances in order to determine whether a sar should be filed. Also, although the firm AML analysts identified some red flags and opened investigations, the investigations were deficient. FINRA found that the firm failed to reasonably enforce its due diligence procedures for certain correspondent accounts of certain foreign financial institutions (FFIS). Moreover, the firm also had no reliable periodic review process in place to ensure that the activity in the FFIS' accounts was consistent with representations made by FFIS at the time of account opening. This failure resulted in the firm performing no periodic risk reviews of a portuguese ffi account, even though the ffi was assigned a high-risk rating by the firm. FINRA also found that the firm failed to establish, maintain, and enforce a supervisory system reasonably designed to achieve compliance with section 5 of the Securities Act through the incomplete risk reviews, due diligence failures, and failures to implement existing procedures relevant to low priced securities.","res":"Acceptance, Waiver & Consent(AWC)","sd":"A censure; a fine in the amount of $8,000,000 for Raymond James & associates; a fine in the amount of $9,000,000 for Raymond James Financial services; and","sm":"Rja & RJFS were censured, fined, and required to conduct a comprehensive review of the adequacy of each of its AML and supervisory policies, systems, procedures, and training. At the conclusion of the review, which shall be no more than 180 days after the date of the notice of acceptance of the AWC, rja/RJFS shall certify that the procedures are reasonably designed to achieve compliance with FINRA rule 3310. The certification shall be provided in a written letter to FINRA. The letter shall be accompanied by a written report, at a minimum stating (I) the adequacy of rja/RJFS' policies, systems, procedures, and training relating to AML and supervision; (II) a description of the review performed and the conclusions reached; and (III) recommendations for modifications and additions to the firm's policies, systems, procedures and training.","ab":"Raymond James &; Raymond James Financial","firms":[110653,174904],"id":1829},{"d":"2016-05-18","di":"2016-05-18","dr":"2016-05-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":17000000.0,"dk":"2014043592001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, and its amlco, failed to establish and implement policies and procedures to reasonably detect and cause the reporting of suspicious transactions. The findings stated that as the firm's amlco, the representative was responsible for ensuring that the firm's AML program was adequately tailored to the firm's business and for appropriately monitoring, detecting and reporting suspicious activity. Despite the separate AML departments and programs, the firm as a clearing firm, its amlco, and the firm for which the firm served as clearing firm created a system under which this firm heavily relied upon its clearing firm to provide certain systems and tools as part of the firm's AML program. The firm failed to commit adequate resources to the firm's AML programs. The firm's staffing of its AML departments was inadequate in light of the extensive responsibilities assigned to the few individuals, including the labor-intensive manual reviews, particularly in light of the firm's growth. The findings also stated that the firm failed to establish and implement AML procedures and systems reasonably expected to detect suspicious activity. The firm failed to establish reasonable written procedures for certain aspects of the firm's AML programs. The firm failed to establish reasonable AML systems tailored to its business. The AML procedures that were in place required the firm to review accounts for potential suspicious activity. The firm, however, failed to develop and implement surveillance reports tailored to detect certain types of potentially suspicious transactions. For example, the firm had no written procedures requiring review of, or surveillance reports monitoring for, the following high-risk activities: transfers of funds to unrelated accounts without any apparent business purpose; journaling securities and cash between unrelated accounts for no apparent business purpose, particularly internal transfers of cash from customer accounts to employee or employee-related accounts; and movement of funds, by wire transfer or otherwise, from multiple accounts to the same third party account. The firm's surveillance reports failed to reasonably monitor for suspicious activity. The findings also included that the firm failed to reasonably investigate red flags. As a result of the firm's AML procedures, the firm had gaps in its surveillance of activity for AML red flags. Even when the exception reports or other surveillance identified red flags, the firm failed to reasonably investigate many instances in order to determine whether a sar should be filed. Also, although the firm AML analysts identified some red flags and opened investigations, the investigations were deficient. FINRA found that the firm failed to reasonably enforce its due diligence procedures for certain correspondent accounts of certain foreign financial institutions (FFIS). Moreover, the firm also had no reliable periodic review process in place to ensure that the activity in the FFIS' accounts was consistent with representations made by FFIS at the time of account opening. This failure resulted in the firm performing no periodic risk reviews of a portuguese ffi account, even though the ffi was assigned a high-risk rating by the firm. FINRA also found that the firm failed to establish, maintain, and enforce a supervisory system reasonably designed to achieve compliance with section 5 of the Securities Act through incomplete risk reviews, due diligence failures, and failures to implement existing procedures relevant to low priced","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firms were censured, fined $8,000,000 (RJA) and $9,000,000 (RJFS) and required to conduct a comprehensive review of the adequacy of its AML and supervisory policies, systems, procedures, and training. At the conclusion of the review, which shall be no more than 180 days after the date of the notice of acceptance of this AWC, the firm shall certify that its procedures are reasonably designed to achieve compliance with FINRA rule 3310. The certification shall be provided in a written letter to FINRA. The letter shall be accompanied by a written report, at a minimum, stating (I) the adequacy of the firm's policies, systems, procedures and training relating to AML and supervision; (II) a description of the review performed and the conclusions reached; and (III) recommendations for modifications and additions to the firm's policies, systems, procedures and training. The $17,000,000 fine was paid on 5/26/16.","ab":"Raymond James &","firms":[149018],"id":1830},{"d":"2016-05-12","di":"2016-05-12","dr":"2016-05-12","k":"Regulatory Action","rg":"Other","reg":"Capital Market Authority of the Kingdom of Saudi Arabia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2665.32,"dk":"375/10/2015","al":"In a letter dated May 12, 2016 to Goldman Sachs Saudi arabia (\"GSSA\") from the kingdom of saudi arabia capital market authority (the \"cma\"), the cma informed GSSA of a cma decision alleging that there was only one individual associated with GSSA registered with the cma under investment fund management and client portfolio management activities, in alleged violation of cma circular no. t/1/6/9/15, dated June 17, 2015.","res":"Decision","sm":"Gssa agreed to the payment of a financial penalty to the cma in the amount of 10,000 saudi arabian riyals (SAR), which was paid by submission of a wire on May 23, 2016. The cma's decision stipulated the need for gssa to discuss the matter of the violation at the next meeting of the board of directors of gssa.","ab":"Goldman Sachs Saudi","firms":[361],"id":1831},{"d":"2016-05-11","di":"2016-05-11","dr":"2016-05-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":900000.0,"dk":"2014041823201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it did not adequately supervise the content and dissemination of firm-wide \"flash\" emails through which its research analysts alerted other firm personnel to news and insights concerning companies and industries covered by the firm's research department. The findings stated that the firm also failed to establish, maintain, and enforce adequate written supervisory procedures concerning securities trading in connection with these flash emails. These failures collectively created the risk that flash emails could potentially include material nonpublic information that might be misused by sales and trading personnel. Although the flash email program was intended to convey only publicly-available information, the firm did not have adequate policies and procedures to supervise the content of the flash emails, and in practice flash emails sometimes conveyed more than that. The flash emails were not subject to the level of systematic supervisory review and approval applied to published research, either before or after they were circulated, unless an issuer mentioned in the email was on a firm restricted list. Moreover, flash emails did not contain the disclosures required by SEC regulations and FINRA rules for published research. The findings also stated that in at least one instance, the content from an unapproved, draft research report was cut and pasted into a flash email. The findings also included that although flash emails were marked for internal use only, the firm's personnel sometimes forwarded them to firm customers or cut and pasted the text of a flash email into a separate communication sent to a firm customer. The findings also included that when the firm published a research report containing a ratings change, firm policy prohibited employees from trading the securities of the affected issuer in the direction of the new rating during the two business days following publication of the report. However, the firm did not systematically monitor for trading that occurred shortly before the publication of research reports containing rating, estimate, or price target changes or during the period between the time a flash email was distributed and the publication of a subsequent research report containing such changes. FINRA found that the firm failed to establish, maintain, and enforce adequate systems and procedures to supervise flash emails and related trading. FINRA also found that the firm failed to establish, maintain, and enforce policies and procedures reasonably designed to restrict or limit the information flow between research department personnel and trading department personnel so as to prevent trading department personnel from using material, non-public analyst research for the benefit of the firm, its employees, and its customers.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, fined $900,000 and undertakes within 60 days of the date of the notice of acceptance of this AWC, the firm shall certify to FINRA in a submission signed by an officer of the firm that it has ceased distributing flash emails. Furthermore, the firm undertakes within 90 days of the date of notice of acceptance of this AWC, submit to FINRA a written plan of how it will conduct a comprehensive review of the adequacy and implementation of its policies and procedures (written and otherwise) and training in the research area.","sm":"within the space provided).","ab":"Stephens Inc.","self":true,"firms":[3496],"id":1832},{"d":"2016-05-06","di":"2016-04-05","dr":"2016-05-06","k":"Regulatory Action","rg":"Other","reg":"BAFIN - Federal Financial Supervisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":55690.0,"dk":"WA 17-WP 3120-2010/0024 WA 17-WP 3120-2012/0105 TO -/0110 WA 17-WP 3120-2012/0189 WA 17-WP 3120-2013/0117 TO -/0122","al":"The federal financial supervisory authority of Germany (\"BAFIN\") alleged that Jupiter Asset Management Limited (\"jam UK\") did not have sufficient procedures in place to ensure compliance with german law regarding notification of BAFIN of significant shareholders in german securities","res":"Decision & Order of Offer of Settlement","sd":"None","sm":"The federal financial supervisory authority of Germany (\"BAFIN\") alleged that jam UK did not have sufficient procedures in place to ensure compliance with german law regarding notification of BAFIN of significant shareholders in german securities. Jam UK paid the administrative fine on May 6TH 2016.","ab":"Jupiter Asset Management Limited","self":true,"firms":[306863],"id":1833},{"d":"2016-05-04","di":"2016-05-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"2014043005601","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1834},{"d":"2016-05-03","di":"2016-05-03","dr":"2016-05-03","k":"Regulatory Action","rg":"Other","reg":"Oklahoma Department of Securities","san":"Cease and Desist","st":"Final","fine":21245.14,"dk":"16-017","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Oklahoma Department of Securities (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Oklahoma representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Oklahoma residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Oklahoma residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $21,245.14. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1835},{"d":"2016-04-29","di":"2016-04-29","dr":"2016-04-29","k":"Regulatory Action","rg":"Other","reg":"Oregon Division of Financial Regulation","san":"Cease and Desist","st":"Final","fine":24642.2,"dk":"S-15-0126","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Oregon Division of Financial Regulation (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Oregon representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Oregon residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Oregon residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $24,642.20. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1836},{"d":"2016-04-26","di":"2016-04-26","dr":"2016-04-26","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Cease and Desist","st":"Final","fine":19347.74,"dk":"S-15-0038","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Arkansas Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Arkansas representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Arkansas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Arkansas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $19,347.74. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1837},{"d":"2016-04-22","di":"2016-04-22","dr":"2016-04-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine","st":"Final","fine":250000.0,"dk":"2013035265401","al":"The Financial Industry Regulatory Authority (FINRA) alleged that in 2011, 2012 and 2013, J.P. Morgan Clearing Corp. (JPMCC) failed to send annual privacy notices on its own behalf to certain account holders of other broker-dealers for which it provides clearing and custody services. FINRA also alleged that JPMCC had inadequate controls to ensure that such privacy notices were sent. The alleged conduct violated NASD conduct rule 3010(a) and (b) and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent dated April 22, 2016.","ab":"J.P. Morgan Clearing Corp.","firms":[79],"id":1838},{"d":"2016-04-22","di":"2016-04-22","dr":"2016-04-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine","st":"Final","fine":775000.0,"dk":"2013035265401","al":"The Financial Industry Regulatory Authority (FINRA) alleged various operational systems, supervisory and recordkeeping deficiencies that occurred at various times during the period December 2006 through September 2014. The alleged deficiencies include the failure to send letters to certain customer accounts confirming changes in investment objectives within 30 days of the change; the failure to collect and review certain outside brokerage statements associated with employee accounts; the failure to send letters to certain customers providing a copy of their account record within 30 days of account opening; the failure to make, deliver and preserve transaction confirmations for certain account holders; and the failure to preserve copies of letters sent to certain customers who updated their investor profiles, but instead preserved some electronic information in its systems for each such letter so that the letter could be regenerated if a copy was later requested, however, the system did not preserve the name of the supervisory manager who appeared in the signature block of the original letter. The alleged deficiencies violated Exchange Act § 17(a); Exchange Act rules 10b­10, 17a­3; and 17a­4; NASD code of conduct rules 2110, 2230, 3110(a), 3010(a) and 3010(b); and FINRA rules 2010, 2232, and 4511.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This is a final action resolved by letter of acceptance, waiver and consent dated 4/22/2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1839},{"d":"2016-04-22","di":"2016-04-22","dr":"2016-04-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","os":"Fine, undertaking","st":"Final","fine":2250000.0,"dk":"2012031642902","al":"Alleged violation of Nasdaq rules 4755, 2110, 4511a, and 3010, rule 200(g) of Regulation SHO, and SEC rule 17A-3 in that Citigroup Global Markets Inc. failed to properly mark certain sale orders as short sales, between June 1, 2012 and June 1, 2013, entered certain order into the Nasdaq market center that filed to correctly indicate that the orders were short sales, improperly marked short sale orders were also incorrectly recorded as long sale orders in the firm's books and records, and 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 Nasdaq rules, concerning short sale order marking pertaining to one of its order handling systems between April 1, 2009 and June 30, 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a $2,250,000 fine, an undertaking to revise the firm's written supervisory procedures and an undertaking to provide a written report to FINRA regarding the firm's supervision of short order marking.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1840},{"d":"2016-04-21","di":"2016-04-21","dr":"2016-04-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":55000.0,"dk":"2012031642901","al":"Alleged violation of FINRA rules 6182, 4511, 2010, SEC rule 17A-3, and NASD rule 3010 in that Citigroup Global Markets Inc. reported certain long sale executions to the FINRA/Nasdaq trade reporting facility as short as the result of a system issue, recorded certain long sale executions on its books and records as short sales, and failed to provide documentary evidence that on the trade dates reviewed in the trading and market making surveillance examination it performed the supervisory reviews set forth in its written supervisory procedures between April 2009 and June 2013.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a $55,000 fine.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1841},{"d":"2016-04-20","di":"2016-04-20","dr":"2016-04-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":12500.0,"dk":"2014042109401","al":"FINRA alleged violations of improperly reporting certain OATS reports to the order audit trail system with a reporting exception code of m that were required to match a related trade report.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured and fined $12,500.00.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1842},{"d":"2016-04-15","di":"2016-04-15","dr":"2016-04-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","dk":"2015045594601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to customers. The findings stated that the firm failed to apply the waivers to mutual fund purchases made by certain retirement plan and charitable organization customers (eligible customers) that were eligible to purchase class a shares in certain mutual funds without a front-end sales charge, and instead sold them class a shares with a front-end sales charge or class b or class c shares with back-end sales charges and higher ongoing fees and expenses. The findings also stated that these sales disadvantaged eligible customers by causing such customers to pay higher fees than they were actually required to pay. The findings also included that the firm relied on its financial advisors to determine the applicability of sales charge waivers, but failed to maintain adequate written policies or procedures to assist financial advisors in making this determination. FINRA found that the firm failed to adequately notify and train its financial advisors regarding the availability of mutual fund sales charge waivers for eligible customers. The firm failed to adopt adequate controls to detect instances in which they did not provide sales charge waivers to eligible customers in connection with their mutual fund purchases. As a result of the failure of the firm to apply available sales charge waivers, the firm estimates that eligible customers were overcharged by approximately $1.8 million for mutual fund purchases made since July 1, 2009.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured, and will provide remediation to eligible customers who qualified for, but did not receive, the applicable mutual fund sales charge waivers by agreeing to pay restitution, plus interest, to eligible customers in the amount of $2.1 million.","sm":"In resolving this matter, FINRA has recognized the extraordinary cooperation of the firm for having: (1) initiated, prior to detection or intervention by a regulator, an investigation to identify whether eligible customers received sales charge waivers during the relevant period; (2) promptly established a plan of remediation for eligible customers who did not receive appropriate sales charge waivers; (3) promptly self-reported to FINRA; (4) agreed to promptly take action and remedial steps to correct the violative conduct; and (5) agreed to employ subsequent corrective measures, prior to detection or intervention by a regulator, to revise its procedures to avoid recurrence of the misconduct.","ab":"Robert W. Baird & Co. Incorporated","self":true,"firms":[8158],"id":1843},{"d":"2016-04-14","di":"2016-04-14","dr":"2016-04-14","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"16-8824","al":"Alleged violation of rule 576 in that Citigroup Global Markets Inc. failed to maintain accurate and current information in the exchange fee system for trade dates October 1, 2015 through December 31, 2015.","res":"Settled","sm":"The firm consented to a $10,000 summary fine.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1844},{"d":"2016-04-14","di":"2015-09-28","dr":"2016-04-14","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Authority of Norway","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":12000.0,"dk":"15/6983","al":"In March 2016, the Financial Supervisory Authority of Norway (\"finanstilsynet\") sent a letter to Dalton Investments LLC (\"Dalton\"),notifying it of the finanstilsynet's decision to impose a charge of 100,000 nok (approximately $12,000 usd) for violating the notification requirement under norwegian law. Norwegian law requires that a notification begiven to the finanstilsynet if a person's proportion of shares of a portfolio company falls below 10%. On July 7, 2015, a sale by Dalton, on behalf of its clients/funds, resulted in its ownership of a portfolio company decreasing from 10.14% to 9.998% on an aggregated basis. Dalton filed the report on July 10, 2015, which thefinanstilsynet did not deem as \"immediate\" under norwegian law. Dalton paid the penalty in due course.","res":"Order","sd":"See above.","sm":"SEE ABOVE. No Information Filed","ab":"Dalton Investments LLC","firms":[308609],"id":1845},{"d":"2016-04-11","di":"2016-04-11","dr":"2016-04-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":750000.0,"dk":"2013036354001","al":"FINRA alleged that, prior to performing its end of the week customer reserve calculations, the firm substituted loans secured by customer-owned securities with loans secured by firm-owned collateral, potentially reducing the amount the firm was required to deposit into its special reserve bank account. These substitutions were based on administrative convenience and, at all relevant times, the firm had sufficient capital to properly fund the reserve account had the loan substitutions not occurred, assuming that any additional deposits were even necessary. FINRA also alleged that, based on its improper treatment of various cash and securities balances in the accounts of a newly-acquired introducing broker-dealer, the firm incorrectly calculated its proprietary accounts of introducing brokers and dealers reserve and customer reserve deposit requirements causing several hindsight deficiencies in 2013 as well as the filing of inaccurate focus reports, and the maintenance of inaccurate books and records. As a result of these violations, FINRA alleged that the firm did not establish and maintain reasonable supervisory systems and procedures designed to detect and prevent these violations.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm fully cooperated with FINRA's inquiry and resolved this matter without admitting or denying the findings. In addition, the firm undertook significant remediation efforts to enhance its training and controls for complying with sea rule 15c 3-3, rule 17A-3(a)(11) and rule 17A-5. The firm retained an outside consultant who conducted an extensive review of the firm's relevant processes and controls. Consistent with the consultant's recommendations, the firm revised certain written supervisory procedures for regulatory reporting, developed new processes to improve communication between its regulatory reporting department and other departments within the firm responsible for producing and providing key regulatory information, and developed enhanced training for firm personnel involved in the regulatory reporting process.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1846},{"d":"2016-04-11","di":"2015-11-11","dr":"2016-04-11","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"15-0093/20150459684","al":"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.","res":"Decision & Order of Offer of Settlement","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1847},{"d":"2016-04-08","di":"2012-10-09","dr":"2016-04-08","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Civil penalties","st":"Final","fine":1200000000.0,"al":"The complaint alleges that Wells Fargo Bank, N.A. engaged in misconduct in connection with its participation in the federal housing administration (FHA) direct endorsement lender program and that, as a result of false certifications, FHA has paid hundreds of millions of dollars in insurance claims on thousands of mortgages that defaulted.","res":"Settled","sd":"Monetary fine of 1,200,000,000.00 100% leveled against the affiliate.","ab":"Wells Fargo Bank, NA","firms":[11025,19616],"id":1848},{"d":"2016-04-05","di":"2016-04-05","dr":"2016-04-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"2014040037901","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that for the period September 1, 2013 through December 31, 2013, Goldman, Sachs & co. (the \"firm\") failed to accept or decline in the FINRA/Nasdaq trade reporting facility (FNTRF) certain transactions in reportable securities within twenty minutes after execution, in alleged violation of FINRA rule 7230a(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on April 5, 2016, and on April 29, 2016, the firm submitted a wire in payment of a fine in the amount of $20,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1849},{"d":"2016-04-05","di":"2016-04-05","dr":"2016-04-05","k":"Regulatory Action","rg":"Other","reg":"Bloomberg SEF","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1250.0,"dk":"N/A","al":"Alleged violation of BSEF rule 516 in that Citibank, N.A. failed to notify and seek approval from BSEF prior to entering into offsetting and corrective trades.","res":"Consent","sm":"BSEF imposed a fine in the amount of $1,250","ab":"Citibank, N.A.","firms":[7059],"id":1850},{"d":"2016-04-05","di":"2016-04-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine, undertaking","st":"Final","fine":35000.0,"dk":"2013038061201","al":"Alleged violation of SEC rule 611(a), FINRA rule 2010, and NASD rule 3010 in that Citigroup Global Markets Inc. failed to access protected quotes in certain transactions to the disadvantage of its customers and the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable rules and laws from June 1, 2012 through August 26, 2014.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a fine of $35,000, and an undertaking to revise the firm's procedures.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1851},{"d":"2016-04-05","di":"2016-04-05","dr":"2016-04-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":115000.0,"dk":"2013038371401","al":"FINRA alleged violations of FINRA and SEC rules resulting from inaccurate capacity disclosures for certain trades related to errors (representing less than 0.1 % of the firms ATS volume) and corresponding supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$115,000 and undertaking to resolve certain policies and procedures.","sm":"Without admitting or denying the findings , the firm consented to the entry of FINRA's findings and sanctions. The findings stated that the orders related to this matter involved less than 0.1% of the firms ATS volume. The findings also stated that there is no evidence that the firms orders received any preferential treatment or trading advantage over any other order in the system.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":1852},{"d":"2016-04-04","di":"2016-04-04","dr":"2016-04-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":260000.0,"dk":"2013035825001","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) for trade dates August 15 and 16, 2013, Goldman, Sachs & co. (the \"firm\") failed to submit, or inaccurately submitted, certain information to the order audit trail system (OATS), in alleged violation of FINRA rule 7450; (II) during the period from May 17, 2011 through February 28, 2014, the firm reported certain short sale transactions to the FINRA trade reporting facility (\"FTRF\") without the required short sale modifier, in alleged violation of FINRA rule 6182; and (III) the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to FINRA rule 6182 concerning the reporting of correct short sale modifiers to the FTRF, in alleged violation of FINRA rule 2010 and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on April 4, 2016, and on April 29, 2016, the firm submitted a wire in payment of a fine in the amount of $260,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1853},{"d":"2016-04-04","di":"2016-04-04","dr":"2016-04-04","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2014-153","al":"Alleged violation of exchange rule 4.02(g)(2) in that Citigroup Global Markets Inc. failed to use the exchange's crossing order functionality in certain instances on trade date December 11, 2014.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to a summary fine in the amount of $5,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1854},{"d":"2016-04-04","di":"2016-04-04","dr":"2016-04-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":225000.0,"dk":"2014042542901","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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).","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1855},{"d":"2016-03-31","di":"2016-03-31","dr":"2016-03-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"2014041197401","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1856},{"d":"2016-03-30","di":"2016-03-30","dr":"2016-03-30","k":"Regulatory Action","rg":"State regulator","reg":"South Carolina Securities Commission","san":"Cease and Desist","st":"Final","fine":80000.0,"dk":"15037","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the South Carolina Securities Commission (securities commission) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its South Carolina representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the securities commission alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to South Carolina residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to South Carolina residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the securities commission a civil penalty in the amount of $80,000. Finally, the securities commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1857},{"d":"2016-03-29","di":"2016-03-03","dr":"2016-03-29","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":275000.0,"dk":"2013035466001","al":"Without admitting or denying the findings, the firm consented to the sanctions and entry of findings that, on certain occasions during the period of January 1, 2010 through June 1, 2011, the firm violated: NYSE rule 92(a) by entering an order to buy or sell an NYSE-listed security for an account in which the firm had an interest (a \"proprietary order\") while knowingly in possession of a customer order that could be executed at the same price, that traded along with, or ahead of, the customer order without the customer's consent; section 11(a) of the Exchange Act and NYSE rule 90(a) by causing firm-associated floor brokers to effect proprietary transactions on the NYSE floor without yielding priority, parity and precedence to non-proprietary orders; NYSE rule 410(b) by allowing proprietary orders to be transmitted to the NYSE floor without the required \"g\" notation that would enable such orders to be handled pursuant to section 11(a)(1)(g) of the Exchange Act; NYSE rule 2010 by failing to cross certain customer orders described above; section 10B-10(a)(2) of the Exchange Act by failing to provide written disclosures to customers concerning the firm's correct capacity and, when acting as principal in a non-market making capacity, failing to provide complete and accurate written disclosures to customers about the difference between the customer's price and the firm's contemporaneous price; and NYSE rule 342 by failing to reasonably supervise and implement adequate controls reasonably designed to achieve compliance with NYSE rules 90, 92, 410(b), 2010 and section 11(a) of the Exchange Act with respect to the transmission and execution of certain agency and proprietary transactions effected on the NYSE floor.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1858},{"d":"2016-03-24","di":"2016-03-24","dr":"2016-03-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":25000.0,"dk":"2014041851101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it 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 rule.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1859},{"d":"2016-03-24","di":"2016-03-24","dr":"2016-03-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure;restitution;interest","st":"Final","fine":565000.0,"dk":"2009020201201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in transactions, the firm purchased municipal securities for its own account FROM a customer and/or sold municipal securities for its own account to a customer at an aggregate price (including any mark-down or mark-up) that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer, or municipal securities dealer is entitled to a profit, and the total dollar amount of the transaction. The findings stated that in corporate bond transactions for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to BUY or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. In corporate bond transactions, the firm sold (BOUGHT) corporate bonds to (FROM) customers and failed to sell (BUY) such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each bond at the time of the transaction, the expense involved and that the firm was entitled to a profit.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $565,000 and ordered to pay customers restitution of $95,530.93, plus interest. The firm has paid remediation to relevant customers in the amount of $90,841.10.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1860},{"d":"2016-03-23","di":"2016-03-01","dr":"2016-03-23","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"2012-070","al":"During the review period, Wedbush reported (I) approximately 118,785 instances to the large options positions report (\"LOPR\") without the tax id or tax id type. (II) approximately 51,385 instances to the LOPR with the \"account address city\" field incorrectly populated with \"no city\"; (III) approximately 62,482 instances with the \"account street address\" field incorrectly populated with \"street not found\" and (IV) 188 instances for one account with the incorrect \"account name\" field. Also during the review period, Wedbush also failed to report the correct effective date to the LOPR for an unknown number of positions; a sample reviewed by staff during the period between January 19, 2010 & March 28, 2013 revealed that Wedbush had reported approximately 3,144 positions without the correct effective date as a result of errors related to the firms third party vendors processing of certain trades. During the review period between January 19 & June 7, 2012, Wedbush also failed to report to LOPR approximately 100,2326 instances that were connected to the firms joint back office account. The conduct described above violated ise rule 415(a). During the review period, Wedbush failed to have adequate supervisory systems and controls in place, including a separate system of follow-up and review and written policies & procedures, reasonably designed to achieve compliance with the exchanges options positions reporting requirements. The conduct above violated ise rule 401.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Wedbush fined $90,000","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1861},{"d":"2016-03-17","di":"2016-03-17","dr":"2016-03-17","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc. (Ifus)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"2015-106","al":"Ifus has concluded that J.P. Morgan Securities LLC (JPMS) may have violated ICE rule 6.10 by failing to ensure the the proper cti code was affixed to orders.","res":"Settled","sm":"This is a final action resolved by settlement approved by ifus on 3/17/2016.","ab":"J.P. Morgan Securities LLC","self":true,"firms":[79],"id":1862},{"d":"2016-03-17","di":"2016-03-17","dr":"2016-03-17","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"2015-106","al":"ICE Futures U.S., Inc. (\"IFUS\") market regulation department issued a summary fine, dated March 17, 2016, to Goldman, Sachs & co. (the \"firm\"), stating that the firm may have violated IFUS rule 6.10 by failing to ensure that the proper customer type indicator (CTI) code was affixed to certain orders entered between may and August 2015.","res":"Decision","sm":"The summary fine, in the amount of $2,000, was paid by submission of a wire on March 31, 2016.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1863},{"d":"2016-03-17","di":"2016-03-17","dr":"2016-03-17","k":"Regulatory Action","rg":"Other","reg":"Eurex Deutschland","san":"Reprimand","st":"Final","dk":"2016/06","al":"The firm exceeded the order to trade ratio mentioned in section 17b of the Eurex Deutschland and Eurex zurich exchange rules by 0.0955 as per September 30, 2015.","res":"Decision","sm":"The firm was reprimanded and no monetary fine was imposed. The firm was required to bear the cost of the proceeding (approximately US$2,263.25). In determining to impose the lowest form of sanction, the sanctions committee took into account the fact that the firm took prompt corrective action and implemented controls to prevent similar incidents in the future. The committee also noted that there was no financial loss to other market participants nor any loss in trust for the firm and that the firm did not gain any financial advantage.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1864},{"d":"2016-03-17","di":"2016-03-17","dr":"2016-03-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":41520.17,"dk":"14-078","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1865},{"d":"2016-03-17","di":"2016-03-17","dr":"2016-03-17","k":"Regulatory Action","rg":"Other","reg":"New York Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":18112.0,"dk":"STATE OF NY STIPULATION NO. 2016-0045-S","al":"Alleged violations of various provisions of New York insurance laws.","res":"Stipulation and Consent","sd":"On March 17, 2016, TIAA entered into a stipulation with the New York Department of Financial Services (\"NYDFS\") to, among other things, findings by NYDFS that TIAA violated various provisions of New York insurance law. The stipulation cited violations of NYDFS regulation 60 and regulation 152 related to replacement and recordkeeping requirements. TIAA paid a civil penalty in the amount of $18,112. The stipulation covered the exam period 01/2005 through 12/2008. NYDFS has assessed the remediation plan during the subsequent examination in 2013 with no findings or violations identified related to replacement, illustration, disclosure and recordkeeping requirements.","sm":"This matter does not involve Nuveen Fund Advisors, LLC or Nuveen, LLC.","ab":"Teachers Insurance and","firms":[104626,107168,155584],"id":1866},{"d":"2016-03-15","di":"2016-03-15","dr":"2016-03-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":155000.0,"dk":"2013037678901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to transmit reportable order events (ROES) to the order audit trail system (OATS) under its various market participant identifiers (MPIDS). The findings stated that the firm failed to report to the FINRA/Nasdaq trade reporting facility by 8:00 P.M. Eastern time transactions that required a .x modifier. The findings also stated that the firm failed to provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and FINRA rules concerning OATS and trade reporting.","res":"Acceptance, Waiver & Consent(AWC)","sm":"P p ) in determining to resolve this matter in the manner set forth herein, and in determining the appropriate monetary sanction, FINRA gave consideration that the firm self-reported to FINRA in July 2013 the failure to submit to OATS the roes involved in this matter. The firm further undertook steps to remediate the issues, and subsequently submitted to OATS the roes it failed to submit during the period between March 2012 and May 2013.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1867},{"d":"2016-03-15","dr":"2016-03-15","k":"Regulatory Action","rg":"Other","reg":"Refer to Advisory Affiliate's DRP.","san":"Other","os":"Refer to Advisory Affiliate's DRP.","st":"Final","res":"Decision","sm":"Refer to Advisory Affiliate's DRP.","ab":"Pacific Alliance","firms":[161814],"id":1868},{"d":"2016-03-14","di":"2016-03-14","dr":"2016-03-14","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Cease and Desist","st":"Final","fine":32522.13,"dk":"16-008","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Ohio Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Ohio representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Ohio residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Ohio residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $32,522.13. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1869},{"d":"2016-03-11","di":"2016-03-11","dr":"2016-03-11","k":"Regulatory Action","rg":"Other","reg":"U.S. Virgin Islands Division of Banking and Insurance","san":"Cease and Desist","st":"Final","fine":10013.22,"dk":"6","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the U.S. Virgin Islands Division of Banking and Insurance (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its U.S. virgin islands representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to U.S. virgin islands residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to U.S. virgin islands residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $10,013.22. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1870},{"d":"2016-03-08","di":"2016-03-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":500000.0,"dk":"2013035599201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it caused certain newly-recruited registered representatives from other brokerage firms to disclose customer nonpublic personal information to it in violation of Regulation S-P under the Securities Exchange Act of 1934. The findings stated that the firm used the nonpublic personal information provided to pre-populate new account forms with certain customer information. The firm, however, failed to make any determination as to whether the recruits, or the current broker-dealers with which the recruits were associated, had obtained the customers' consent to provide the firm with the customers' nonpublic personal information or provided customers with notice of, and an opportunity to opt-out of, the disclosure. The findings also stated that the firm failed to establish and maintain reasonable supervisory systems, including WSPS and training, to ensure compliance with Regulation S-P under the Securities Exchange Act of 1934. The firm failed to prevent the improper solicitation of nonpublic personal information from recruits, failed to adequately train and educate its staff on what constituted nonpublic personal information and the appropriate circumstances in which such information could be shared, and with respect to registered representatives who were transitioning from the firm to another broker-dealer. It was unable to demonstrate that its WSPS were systematically followed and enforced.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $500,000.00, and required to review and revise, as necessary, its policies, procedures, and internal controls. Within 45 business days of the issuance of the notice of acceptance of this AWC, the chief executive officer and chief compliance officer at the firm shall certify in writing to FINRA that, with respect to the areas described in the AWC, (1) the firm has engaged in the review described above; and (II) as of the date of this certification, the firm has established and implemented policies, procedures and internal controls reasonably designed to achieve compliance with Regulation S-P under the Securities Exchange Act of 1934.","ab":"Raymond James &; Raymond James Financial","firms":[705,149018],"id":1871},{"d":"2016-03-08","di":"2015-04-15","dr":"2016-03-08","k":"Regulatory Action","rg":"Other","reg":"Finansinspektionen, Sweden's Financial Supervisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"11712-15","al":"On April 15, 2015, Finansinspektionen, Sweden's Financial Supervisory Authority, imposed a penalty of sek 300,000 (approximately usd 35,659 at date of payment) against Franklin Templeton Investments Corp. (\"FTIC\") in connection with FTIC's inadvertent failure to timely report changes in major shareholdings of a canadian issuer held by funds and accounts advised by FTIC. The change was reported on a timely basis to canadian securities regulators, but after the reporting deadline in sweden, where the canadian issuer has a dual listing. FTIC appealed the penalty unsuccessfully and the penalty became final on March 8, 2016.","res":"Decision","sm":"fit within the space provided). PLEASE SEE RESPONSE TO QUESTION 12.B. ABOVE.","ab":"Franklin Templeton Investments Corp.","self":true,"firms":[111364],"id":1872},{"d":"2016-03-04","di":"2016-03-04","dr":"2016-03-04","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Securities Division","san":"Cease and Desist","st":"Final","fine":33714.11,"dk":"15002","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Tennessee Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Tennessee representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Tennessee residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Tennessee residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $33,714.11. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1873},{"d":"2016-03-04","di":"2016-03-04","dr":"2016-03-04","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":60000.0,"dk":"DECISION -CBOT 14-9808-BC","al":"CME Group alleged Deutsche Bank AG (\"Dbag\") violated legacy CBOT rules 534 (wash trades prohibited), 538.a (nature of an efrp) and 538.b (related positions). These transactions occurred on June 4, 2013 and August 29, 2013.","res":"Decision","sm":"Without admitting or denying any rule violations, dbag agreed to pay the fine of $60,000.00 which was paid on March 16, 2016.","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":1874},{"d":"2016-03-02","di":"2016-03-02","dr":"2016-03-02","k":"Regulatory Action","rg":"State regulator","reg":"Wisconsin Division of Securities","san":"Cease and Desist","st":"Final","fine":25928.7,"dk":"S-233431(LX)","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Wisconsin Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Wisconsin representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Wisconsin residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Wisconsin residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $25,928.70. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1875},{"d":"2016-03-01","di":"2016-03-01","dr":"2016-03-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"2013039474902","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1876},{"d":"2016-02-29","di":"2016-02-29","dr":"2016-02-29","k":"Regulatory Action","rg":"Other","reg":"Kentucky Department of Financial Institutions","san":"Cease and Desist","st":"Final","fine":22841.84,"dk":"2016-AH-0010","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Kentucky Department of Financial Institutions (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Kentucky representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Kentucky residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Kentucky residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $22,841.84. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1877},{"d":"2016-02-26","di":"2016-02-26","dr":"2016-02-26","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Kansas Securities Commissioner","san":"Cease and Desist","st":"Final","fine":16182.86,"dk":"16E002/2016-6358","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Office of the Kansas Securities Commissioner (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Kansas representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Kansas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Kansas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $16,182.86. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1878},{"d":"2016-02-25","di":"2016-02-25","dr":"2016-02-25","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":337500.0,"dk":"2010024386602","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it served as the clearing firm for a correspondent broker-dealer (the client broker-dealer) that was engaged in the trading of various exchange-traded funds (ETFS). The findings stated that the firm's client broker-dealer engaged in a systemic, recurring and cyclical pattern of 'naked' redemption and short sale trading activity in ETFS that resulted in substantial, repeated failures to deliver the ETFS by the firm within the continuous net settlement system (CNS). The firm allocated the fails to deliver associated with the foregoing redemption and trading activity to the client broker-dealer, which, upon receiving buy-in notices, the client broker-dealer typically took action to close out the fail by submitting an order to create units in the ETFS on t+6, even though its redemption and short sale activities that resulted in the fails to deliver did not qualify as bona fide market making under rule 204 of Regulation SHO. In addition, the client broker-dealer would typically re-establish the fail position by redeeming shares of the ETF through the firm, or executing sales of the ETF that cleared through the firm the next trading day. The extent and magnitude of the client broker-dealer's naked redemption/short selling in the subject ETFS was significant. The client broker-dealer submitted at least 255 naked redemption orders through the firm in 11 of the 14 ETFS included in the review, totaling 295,950,000 shares for which the client broker-dealer was not long the requisite number of shares of the ETF and otherwise did not have the full legal authority and legal and beneficial right to tender those shares at the time the client broker-dealer submitted its redemption orders. The client broker-dealer's chronic fails to deliver in ETF shares resulting from its above naked redemption/trading strategy also constituted a significant factor in the 14 ETFS under review being classified as threshold securities under Regulation SHO for sustained timeframes. The findings also stated that the firm failed to ascertain whether the client broker-dealer beneficially owned sufficient ETF shares to cover its redemption requests. In fact, the firm was aware, or should have been aware, that the client broker-dealer routinely was placing ETF redemption orders with the firm when it was insufficiently long the ETF shares, resulting in repeated fails to deliver consistent with the client broker-dealer's strategy to maintain a short position in ETFS. In addition, the firm failed to adequately follow up on the client broker-dealer's repeated fails to deliver that resulted from its cyclical, repetitive pattern of naked redemption orders and short sales of ETFS in the secondary market to identify and take steps to address the misconduct. The findings also included that the firm failed to establish, implement and enforce reasonable supervisory procedures, including written supervisory procedures, during the review period specific to compliance with rule 204 of Regulation SHO, or specific to the firm's activities as an authorized participant in certain ETFS, to reasonably ensure those activities complied with applicable securities laws, rules and regulations. As a result of its conduct, the firm violated Nasdaq rules 2110 and 3010, and violated Nasdaq rule 2110 by facilitating its client broker-dealer's violations of rule 204 of Regulation SHO.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $337,500 shall be paid to Nasdaq and undertakes to revise its written supervisory procedures.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1879},{"d":"2016-02-19","di":"2016-02-19","dr":"2016-02-19","k":"Regulatory Action","rg":"Other","reg":"Washington Insurance Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"15-0242","al":"LPL consented to the entry of a consent order with the insurance commissioner of the state of Washington, after its investigation into the conduct of a non-resident insurance producer after receiving a complaint from an insured alleging that he misrepresented the benefits and suitability of an annuity. More than one of the insurance producers' violations were known or should have been known by one or more individuals acting on behalf of LPL, and LPL neither reported the violations nor took corrective action. The insurance commissioner levied a fine in the amount of $2,000.00.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1880},{"d":"2016-02-18","di":"2016-02-18","dr":"2016-02-18","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Other","os":"Order","st":"Final","fine":95000.0,"dk":"IC16-CAF-02","al":"In May 2015, the staff of the Texas State Securities Board initiated an investigation into LPL's financial statement reviews for agents registered with the Texas securities commissioner. In certain instances, during the relevant periods of January 2011 through September 2011 and June 2014 through December 2014, the financial statement reviews were not conducted in accordance with respondent's written supervisory procedures.","res":"Order","sm":"LPL has undertaken a number of enhancements to its policies and procedures relating to financial statement reviews. The enhancements included, among other things, manager escalation meetings, as well as creating an escalation review committee, additional quality control reviews, centralization of review documentation, and a requirement for dba owners to keep at least the most recent six months of all dba statements and check copies on file. In addition, pursuant to the undertakings, LPL will be implementing further enhancements to its procedures, focused primarily on creating monetary thresholds that define escalation criteria and the requirement, in certain circumstances, to obtain additional supporting documentation from the advisor. LPL rendered substantial cooperation in the staff's investigation.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1881},{"d":"2016-02-12","di":"2016-02-12","dr":"2016-02-12","k":"Regulatory Action","rg":"Other","reg":"Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"15-11252","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Maine Office of Securities office (the \"office\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Maine, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Maine. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the office alleged that the acceptance of client orders in Maine through sales assistants that were highly likely not registered in Maine, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in Maine constituted bases for the assessment of an administrative fine pursuant to 32 M.R.S. § 16412(3) (2014). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the office a sum in the amount of $35,000, Maine's allocated portion of the amount agreed to with nasaa. Finally, the office and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1882},{"d":"2016-02-11","di":"2016-02-11","dr":"2016-02-11","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Attorney General of the State of Illinois","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":22500000.0,"al":"The Illinois attorney general's office (\"ILAG\") alleged that Morgan Stanley violated Illinois law in connection with the marketing, sale, and issuance of certain residential mortgage-backed securities between 2002 and 2008.","res":"Settled","sd":"Morgan Stanley made payment of $22,500,000 by wire transfer on 2/24/2016.","sm":"Action status and (OR) disposition and include relevant terms, conditions and dates: on February 11, 2016, Morgan Stanley entered into an agreement (the \"ilag settlement agreement\") with the Illinois attorney general to pay $22.5 million to resolve certain potential claims related to Morgan Stanley's marketing, sale and issuance of certain residential mortgage-backed securities. The ilag settlement agreement was made in conjunction with an agreement between Morgan Stanley and certain members of the president's RMBS working group of the financial fraud enforcement task force. This settlement does not result in any finding of violations of law, and constitutes a final deposition of the potential claims referenced above.","ab":"Morgan Stanley","firms":[104859,105922,110353,126896,134366,158959,309263],"id":1883},{"d":"2016-02-11","di":"2016-02-11","dr":"2016-02-11","k":"Regulatory Action","rg":"State regulator","reg":"Attorney General of the State of New York","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000000.0,"al":"The New York Attorney general's office (\"NYAG\") alleged that Morgan Stanley violated New York law in connection with the marketing, sale, and issuance of certain residential mortgage-backed securities between 2006 and 2007.","res":"Settled","sd":"Morgan Stanley made payment of $150,000,000 by wire transfer on 2/24/2016.","sm":"Action status and (OR) disposition and include relevant terms, conditions and dates: on February 11, 2016, Morgan Stanley entered into an agreement (the \"nyag settlement agreement\") with the New York Attorney general to pay $150 million to resolve certain potential claims related to Morgan Stanley's marketing, sale and issuance of certain residential-mortgage backed securities. Morgan Stanley also agreed to provide $400 million of consumer relief, andthe requirement of an independent monitor to oversee Morgan Stanley's provision of the consumer relief. The nyag settlement agreement was made in conjunction with an agreement between Morgan Stanley and certain members of the president's RMBS working group of the financial fraud enforcement task force. This settlement does not result in any finding of violations of law, and constitutes a final deposition of the potential claims referenced above.","ab":"Morgan Stanley","firms":[104859,105922,110353,126896,134366,158959,309263],"id":1884},{"d":"2016-02-10","di":"2016-02-05","dr":"2016-02-10","k":"Regulatory Action","rg":"State regulator","reg":"Ontario Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":8000000.0,"al":"Ci Investments inc. self-reported a matter to the Ontario Securities Commission staff in connection with the failure to record interest within certain funds in a timely manner.","res":"Settled","sd":"The Ontario Securities Commission entered an order approving a no contest settlement agreement between Ci Investments inc. and the staff of the Ontario Securities Commission relating to the failure to record interest for certain mutual funds.","sm":"Under this settlement agreement, Ci Investments inc. agreed to make a voluntary payment of c$8,000,000 towards the OSC's mandate of protecting investors, c$50,000 towards costs to the OSC investigation, and compensation to reimburse current and former clients affected which is equal to the full amount of the unrecorded interest, in the respective proportions to which they are entitled.","ab":"Ci Investments, Inc.","firms":[156752],"id":1885},{"d":"2016-02-09","di":"2016-02-09","dr":"2016-02-09","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Cease and Desist","st":"Final","fine":18267.52,"dk":"CO-2016-0002","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Alabama Securities Commission (commission) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Alabama representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the commission alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Alabama residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Alabama residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the commission a civil penalty in the amount of $18,267.52, of which $8,267.52 represents partial reimbursement for the commission's cost for investigating this matter. Finally, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1886},{"d":"2016-02-09","di":"2016-02-09","dr":"2016-02-09","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Securities Department","san":"Cease and Desist","st":"Final","fine":11012.5,"dk":"N/A","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the North Dakota Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its North Dakota representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to North Dakota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to North Dakota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $11,012.50, North Dakota's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1887},{"d":"2016-02-09","di":"2016-02-09","dr":"2016-02-09","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Other","os":"Monetary fine","st":"Final","fine":42500.0,"dk":"NYMEX 15-0167-BC","al":"It was alleged that, on May 22, 2015, the Steadfast funds held a short position in natural gas futures which was in excess of the standard expiration month position limit under New York Mercantile Exchange rule 562.","res":"Settled","sd":"Steadfast Capital Management LP (\"Steadfast\") paid a fine in the amount of $42,500 promptly following settlement of this action.","sm":"It was alleged that, on May 22, 2015, the Steadfast funds held a short position in natural gas futures which was in excess of the standard expiration month position limit under NYMEX rule 562 (the \"violation\"). The position limit went into effect at the close of business on May 21, 2015. Despite the fact that the NYMEX division of market regulation had, on multiple occasions in the preceding two days, notified the broker carrying Steadfast's position of the May 21, 2015 effective date and the funds' excess holdings, Steadfast was not notified by its carrying broker of such overage until the morning of May 22, 2015. Upon receiving notification of the overage, the funds promptly liquidated the position. On February 9, 2016, a panel of the NYMEX business conduct committee accepted Steadfast's offer of settlement with respect to the alleged violation, pursuant to which Steadfast agreed to pay a fine in the amount of $42,500, while neither admitting nor denying any rule violation. Steadfast Capital Management LP paid this amount promptly following settlement of this action. The funds were not assessed any fine or other penalties. No information Filed","ab":"Steadfast Capital Management LP","self":true,"firms":[157124],"id":1888},{"d":"2016-02-08","di":"2015-11-30","dr":"2016-02-08","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":5000.0,"dk":"15-0097/20150475130","al":"Alleged violation of exchange rule 4.1 in that Citigroup Global Markets Inc. failed to maintain separate logon id's for trading permit holders for which cgmi provided CBSX access and accessed CBSX through a connectivity provider with a logon id that was not unique and separate from the connectivity provider's logon id.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the allegations, the firm consented to a $5,000 fine and a censure","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1889},{"d":"2016-02-03","di":"2016-02-03","dr":"2016-02-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":235000.0,"dk":"2014042543901","al":"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) that resulted in customers paying excessive sales charges of approximately $458,747. The findings stated that the firm has paid restitution to all affected customers. 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. The firm relied primarily on its registered representatives to ensure that customers received appropriate uit sales charge discounts despite the fact that the firm did not effectively inform and train representatives and their supervisors to identify and apply such sales charge discounts.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $235,000, and ordered to pay $458,747.07 in restitution to affected customers.","sm":"Within the space provided). Due to the growth of Stephens' private client group and, as a result, the increase in the firm's uit business, the firm undertook a review of its uit trading procedures. Based upon the review, in late February 2014 it was determined that the execution of uits should be moved from the fixed income trading DESK to the private client group trading DESK (\"DESK\"). In addition to the move, new procedures were developed which include, but are not limited to, additional front-end account reviews, post execution reviews, thirty-day look back reviews and a rollover template which must be completed by the financial consultant and provided to the DESK for review prior to the execution of a rollover transaction.","ab":"Stephens Inc.","self":true,"firms":[3496],"id":1890},{"d":"2016-02-03","di":"2015-12-07","dr":"2016-02-03","k":"Regulatory Action","rg":"Other","reg":"Finnish Financial Supervisory Advisory Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":32514.0,"al":"Pursuant to the requirements in finland to disclose net short positions in Finnish issuers, Carlson Capital UK LLP (\"Carlson UK\"), the UK based sub-advisor of Carlson Capital L.P., sent a public notification of a net short position in the issued share capital of a finland-listed company on January 31, 2014. Thereafter, Carlson UK closed/covered the entire net short position in the issued share capital of the company on February 7, 2014. Inadvertently, and due to an administrative oversight in the calendaring of the reporting to the Finnish Financial Supervisory Advisory Authority (\"fin-FSA\"), on February 8, 2014, Carlson UK did not report that it had in fact closed out its entire net short position in the company the prior trading day.","res":"Settled","sd":"Carlson UK paid an administrative fine in the amount of 30,000 euro and settled the matter in February 2016.","sm":"Pursuant to the requirements in finland to disclose net short positions in Finnish issuers, Carlson UK sent a public notification of a net short position in the issued share capital of a finland-listed company on January 31, 2014. Thereafter, Carlson UK closed/covered the entire net short position in the issued share capital of the company on February 7, 2014. Inadvertently, and due to an administrative oversight in the calendaring of the reporting to the fin-FSA, on February 8, 2014, Carlson UK did not report that it had in fact closed out its entire net short position in the company the prior trading day. As a result, Carlson UK paid an administrative penalty in the amount of 30,000 euro and settled the matter in February 2016. No information Filed","ab":"Carlson Capital UK LLP","firms":[118156],"id":1891},{"d":"2016-02-02","di":"2016-02-02","dr":"2016-02-02","k":"Regulatory Action","rg":"Other","reg":"The Securities and Futures Commission of Hong Kong","san":"Censure","st":"Final","dk":"6209/2014","al":"The Securities and Futures Commission of Hong Kong (\"SFC\") censured Goldman Sachs (Asia) L.L.C. (\"GS ASIA\") in respect to GS ASIA's failure, while acting as a financial advisor in relation to a voluntary general securities offering of an issuer, to (I) disclose its dealings in the relevant securities between November 8, 2013 and January 6, 2014, (II) seek, during the offer period, the SFC's consent prior to dealing in principal trades in the relevant securities of the issuer which fell outside the scope of dealings covered by the exempt principal trading and exempt fund manager status granted to certain Goldman Sachs entities and, (III) comply with certain requirements in relation to research reports on the issuer, in breach of rules 22, 21.5, note 4 to rule 8.1 and 10 of the code on takeovers and mergers.","res":"Settled","sm":"The SFC issued a public censure of GS asia dated February 2, 2016 (the \"censure\"). In deciding the censure, the SFC took into account Goldman Sachs' cooperation and self-reporting of the breaches.","ab":"Goldman Sachs (Asia) L.L.C.","firms":[361],"id":1892},{"d":"2016-02-02","di":"2016-02-02","dr":"2016-02-02","k":"Regulatory Action","rg":"SEC","reg":"SEC","st":"Final","fine":500000.0,"dk":"3-17090","al":"Respondent 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 respondent's underwriting of certain municipal securities offerings. Respondent, 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 respondent offering and selling municipal securities on the basis of materially misleading disclosure documents. The violations were self-reported by respondent to the commission pursuant to the division of enforcement's (the \"division\") municipalities continuing disclosure cooperation (MCDC) initiative.","res":"Order","sd":"The respondent shall cease and desist from committing or causing any violations and any future violations of section 17(a) (2)of the Securities Act, pay a civil money penalty in the amount of $500,000 and comply with the undertakings enumerated in the offer of settlement.","sm":"Without admitting or denying the violations, the firm consented to the entry of an SEC order instituting administrative 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 (the \"order\"). The order stems from the firm's self-reporting of certain activities related to continuing disclosure obligations specified in rules 15C2-12 under the Securities Exchange Act whereby the firm must 1) cease and desist from committing or causing any future violations of section 17(a)(2) of the Securities Act, 2) pay a civil money penalty in the amount of $500,000, and 3) comply with certain undertakings, including retention of an independent consultant to conduct a review of the firm's policies and procedures as they relate to municipal securities underwriting due diligence.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1893},{"d":"2016-02-02","di":"2016-02-02","dr":"2016-02-02","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Commission","san":"Cease and Desist","os":"Monetary fine of $440,000.00","st":"Final","fine":440000.0,"dk":"3-17096","al":"The Securities and Exchange Commission (SEC) alleged Wells Fargo Bank, N.A. municipal products group (wfbna MPG) 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 wfbna MPG offering and selling municipal securities on the basis of materially misleading disclosure documents. The SEC alleges wfbna MPG violated section 17(a)(2) of the Securities Act of 1933.","res":"Consent","sm":"Without admitting or denying the findings or violations of securities laws or rules, Wells Fargo Bank, N.A. municipal products group agrees to the offer of settlement and this order.","ab":"Wells Fargo Bank, N.A.,","firms":[11025,19616],"id":1894},{"d":"2016-01-29","dr":"2016-01-29","k":"Regulatory Action","rg":"Other","reg":"California Department of Business Oversight","san":"Cease and Desist","st":"Final","fine":140220.11,"dk":"N/A","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the California Department of Business Oversight (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its California representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to California residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to California residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $140,220.11, California's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1895},{"d":"2016-01-21","dr":"2016-01-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":200000.0,"dk":"2015045548001","al":"FINRA alleged that Edward jones violated certain municipal securities rulemaking board rules in connection with short positions in certain municipal securities.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1896},{"d":"2016-01-15","di":"2016-01-15","dr":"2016-01-15","k":"Regulatory Action","rg":"State regulator","reg":"Washington Department of Financial Institutions Securities Division","san":"Cease and Desist","st":"Final","fine":65766.07,"dk":"S-15-1795-15-C001","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Washington Department of Financial Institutions Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Washington representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Washington residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Washington residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $65,766.07, Washington's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1897},{"d":"2016-01-14","di":"2016-01-14","dr":"2016-01-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":15000000.0,"dk":"3-17053","al":"The U.S. Securities and Exchange Commission (the \"SEC\") alleged that Goldman, Sachs & co. (the \"firm\") violated Regulation SHO under the Securities Exchange Act of 1934 (\"Exchange Act\") by improperly relying on the firm's automated locate function in the order management system without having confirmed the availability of the securities to be located. In addition, the SEC alleged that firm employees did not provide sufficient and accurate information with respect to these locates in the firm's locate log, which must reflect the basis upon which the firm provided the locates. The SEC alleged that the firm willfully violated rule 203(b)(1) of Regulation SHO and section 17(a) of the Exchange Act.","res":"Order","sm":"Without admitting or denying the violations, the firm consented to the entry by the SEC of an order instituting administrative and cease-and-desist proceedings, pursuant to sections 15(b) and 21c of the Exchange Act, making findings, and imposing remedial sanctions and a cease-and-desist order (release no. 34-76899, jan. 14, 2016). Pursuant to the order, the firm must cease and desist from committing or causing any violations and any future violations of rule 203(b)(1) of Regulation SHO, and any violations and any future violations of section 17(a) of the Exchange Act and rule 203(b)(1)(III) thereunder relating to short sale locate records. Also pursuant to the order, the firm was censured and paid a civil money penalty in the amount of $15,000,000 on January 20, 2016. The SEC stated that, in determining to accept the firm's offer of settlement, it considered certain remedial acts taken by the firm.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1898},{"d":"2016-01-13","di":"2016-01-13","k":"Civil Judicial Action","san":"Disgorgement","os":"Money damages","st":"Pending","al":"The milan public prosecutor alleged that Deutsche Bank AG/Deutsche Bank AG London branch (\"DB AG\") failed to provide adequate management and supervision under italian legislative decree 231 (non-criminal liability) in connection with allegedly unlawful repo transactions between DB AG and banca monte dei paschi di siena (\"BMPS\") and its subsidiary santorini. The transactions were allegedly intended to hide BMPS losses by allowing BMPS to account for the trades as a financing on an accrual basis, and permitted some BMPS senior management to disseminate false information to the market through the publication of press releases quoting financial data emerging from certain BMPS financial statements.","ab":"Deutsche Bank","firms":[300838],"id":1899},{"d":"2016-01-08","di":"2016-01-08","dr":"2016-01-08","k":"Regulatory Action","rg":"State regulator","reg":"Georgia Securities Division","san":"Cease and Desist","st":"Final","fine":28021.63,"dk":"ENSC-160589","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Georgia Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Georgia representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Georgia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Georgia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,021.63, Georgia's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1900},{"d":"2016-01-08","di":"2013-07-19","dr":"2016-01-08","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"Place limitations on the activities of steven Cohen","st":"Final","dk":"ADMIN PROCEEDING FILE NO. 3-15382","al":"Steven a. Cohen was alleged to have failed to reasonably supervise an employee of CR intrinsic investors, LLC who was alleged to have engaged in trading in securities on the basis of material nonpublic information.","res":"Decision & Order of Offer of Settlement","sd":"See the above response.","sm":"On July 19, 2013, the SEC instituted an administrative proceeding against steven a. Cohen pursuant to section 203(f) of the Investment Advisers Act of 1940 alleging that MR. Cohen failed to reasonably supervise an employee of CR intrinsic investors, LLC (\"CR intrinsic\"). The SEC previously settled civil claims against CR intrinsic related to such employee's trading. On January 8, 2016, the SEC issued an order accepting an offer of settlement from MR. Cohen. Pursuant to the settlement, MR. Cohen neither admitted nor denied the findings of the SEC in the order. The order requires any investment adviser, family office, broker or dealer owned or controlled by MR. Cohen to, for a limited period of time, retain an independent consultant and adopt such consultant's recommendations and submit to on-site SEC examinations. Further, the order prohibits MR. Cohen from being associated in a supervisory capacity with any investment adviser, broker or dealer until December 31, 2017, subject to an extension if the SEC brings a new action against MR. Cohen or a related entity or an employee supervised by him.","ab":"Cohen, Steven, Alan","firms":[283077],"id":1901},{"d":"2016-01-05","di":"2016-01-05","dr":"2016-01-05","k":"Regulatory Action","rg":"Other","reg":"Iowa Insurance Division","san":"Cease and Desist","st":"Final","fine":16638.57,"dk":"88827","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Iowa Insurance Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Iowa representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Iowa residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Iowa residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $16,638.57, Iowa's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1902},{"d":"2015-12-30","di":"2015-12-30","dr":"2015-12-30","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Division of Securities","san":"Cease and Desist","st":"Final","fine":40183.94,"dk":"2016-L-09","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Colorado Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Colorado representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Colorado residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Colorado residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $40,183.94, Colorado's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1903},{"d":"2015-12-30","di":"2015-12-30","dr":"2015-12-30","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Cease and Desist","st":"Final","fine":50555.39,"dk":"62466-S","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the state of Florida Office of Financial Regulation (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Florida representatives regarding the sale of non-traded reits.","res":"Stipulation and Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Florida residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Florida residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $50,555.39, Florida's allocated portion of the amount agreed to with nasaa. Finally, the office and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1904},{"d":"2015-12-29","di":"2015-12-29","dr":"2015-12-29","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Cease and Desist","st":"Final","fine":16736.07,"dk":"N/A","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Nebraska Department of Banking & Finance (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Nebraska representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Nebraska residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Nebraska residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $16,736.07, Nebraska's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1905},{"d":"2015-12-21","di":"2015-12-21","dr":"2015-12-21","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Cease and Desist","st":"Final","fine":17738.18,"dk":"2015-7-10","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Idaho Department of Finance (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Idaho representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Idaho residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Idaho residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $17,738.18, Idaho's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1906},{"d":"2015-12-21","di":"2015-12-21","dr":"2015-12-21","k":"Regulatory Action","rg":"Other","reg":"Michigan Department of Licensing and Regulatory Affairs","san":"Cease and Desist","st":"Final","fine":38133.8,"dk":"327800","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Michigan Department of Licensing and Regulatory Affairs (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Michigan representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Michigan residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Michigan residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $38,133.80, Michigan's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1907},{"d":"2015-12-18","di":"2015-12-18","dr":"2015-12-18","k":"Regulatory Action","rg":"OCC","reg":"U.S.A., Department of the Treasury, Comptroller of the Currency (OCC)","san":"Cease and Desist","st":"Final","dk":"AA-EC-2015-79","al":"7.the OCC found that Wells Fargo Bank, N.A. (\"WFBNA\") failed to make acceptable substantial progress toward correcting previously identified BSA/AML problems relating to due diligence practices and customer risk assessment in the wholesale banking group resulting in a violation of 12 usc 1818(s); and critical internal control deficiencies in the wholesale banking group's BSA/AML compliance program resulted in an internal control pillar violation (12 CFR 21.21(d)(1)).","res":"Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":1908},{"d":"2015-12-16","di":"2015-12-16","dr":"2015-12-16","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Cease and Desist","st":"Final","fine":41209.74,"dk":"39265","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Minnesota Department of Commerce (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Minnesota representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Minnesota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Minnesota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $41,209.74, Minnesota's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1909},{"d":"2015-12-16","di":"2015-12-16","dr":"2015-12-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":1250000.0,"dk":"AWC NO. 2013038772501","al":"The Financial Industry Regulatory Authority (FINRA) alleged that from January 2009 through October 28, 2013, Merrill Lynch, Pierce, Fenner & Smith Incorporated (Merrill lynch) did not conduct adequate background checks on approximately 4,500 non- registered associated persons, after its acquisition by bank of america corporation and the resulting organizational changes. Of that total, approximately 3,145 were fingerprinted, but were screened under the standards applicable to banks and not to broker-dealers; approximately 1,115 were not fingerprinted; and approximately 240 were not fingerprinted until after they joined Merrill lynch. As a result, FINRA alleged individuals were not properly screened for statutory disqualifications under the Securities Exchange Act of 1934 (Exchange Act) (and one person subject to an Exchange Act statutory disqualification actually associated with Merrill lynch); Merrill lynch did not have adequate records and Merrill lynch did not adequately supervise the fingerprinting process. FINRA alleged violations of section 17(f) of the Exchange Act and rule 17F-2 thereunder; section 17(a) of the Exchange Act and rules 17A-3(a)(12)(I)(g) and 17A-3(a)(13) thereunder; article III, section 3(b) of the FINRA by-laws; NASD rule 3010 and FINRA rules 4511 and 2010. Merrill lynch accepted and consented to the entry of an AWC, without admitting or denying the findings.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In connection with the AWC, Merrill lynch agreed to an undertaking to review its systems and procedures regarding the identification, fingerprinting, and screening of non-registered associated persons to ensure that current systems and procedures are reasonably designed to achieve compliance with all securities laws and regulations, including section 17(a) of the Exchange Act and rule 17A-3 thereunder, section 17(f) of the Exchange Act and rule 17F-2 thereunder, FINRA by-laws article III, section 3(b), and FINRA rule 4511.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1910},{"d":"2015-12-15","di":"2015-04-06","dr":"2015-12-15","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Bureau of Securities Regulation","san":"Other","os":"N/a","st":"Final","fine":750000.0,"dk":"C-2013-000005","al":"The State of New Hampshire Bureau of Securities Regulation commenced an adjudicative proceeding based on allegations of inadequate supervision of non-traded REIT sales.","res":"Consent","sm":"Without admitting or denying the facts or allegations, LPL consented to the findings that LPL failed to implement an adequate supervisory system and enforce its written procedures regarding the sale of non-traded reits to New Hampshire residents.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1911},{"d":"2015-12-14","di":"2015-12-14","dr":"2015-12-14","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2015-030","al":"ICE Futures U.S., Inc. (\"IFUS\") market regulation department issued a summary fine, dated December 14, 2015, to Goldman, Sachs & co. (the \"firm\"), stating that the firm may have violated IFUS rule 4.02(g)(2) in one instance on December 12, 2014 by failing to utilize IFUS's crossing order functionality.","res":"Decision","sm":"The summary fine, in the amount of $5,000, was paid by submission of a wire on December 24, 2015.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1912},{"d":"2015-12-08","di":"2015-12-08","dr":"2015-12-08","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Other","os":"Reparation payment","st":"Final","fine":20350.02,"dk":"442.2-164/194","al":"The federal department of finance (\"FDF\") of the Swiss confederation alleged that The Goldman Sachs Group, inc. (\"GS group\") published twice an incomplete notification regarding the firm's holdings in certain securities in the period between December 12, 2013 and February 12, 2014, and published delayed notification of the firm's qualified shareholding in certain securities exceeding the notification threshold in the period between August 19, 2014 and August 8, 2015, each in alleged infringement of article 41 of the Swiss federal act on stock exchanges and securities trading (\"SESTA\").","res":"Consent","sm":"Without admitting any intentional infringement of sesta articles or wrongdoing, GS group entered into a settlement agreement with FDF on December 8, 2015, and consented to a payment to the Swiss confederation in the amount of CHF20,000, which amount was paid on December 18, 2015.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1913},{"d":"2015-12-07","di":"2015-12-07","dr":"2015-12-07","k":"Regulatory Action","rg":"Other","reg":"Illinois Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Institute and maintain specific policies and procedures.","st":"Final","fine":26450.0,"dk":"66915","al":"The Illinois Department of Insurance conducted a market exam, the report of which identified certain areas where nylic was not in compliance with Illinois insurance regulations. Nylic and the il dept of insurance entered into a stipulation and consent order under which nylic will pay a civil penalty and institute policies and procedures to comply with appropriate regulations.","res":"Stipulation and Consent","sd":"The civil forfeiture levied against nylic (eagle's controlling affiliate) was in the amount of $26,450 and a check was issued, payable to the director of insurance, for this amount on 12/16/2015.","sm":"Nylic paid $26,450 to the director of insurance on 12/16/2015.","ab":"New York Life Insurance","firms":[173355],"id":1914},{"d":"2015-12-03","di":"2015-12-03","dr":"2015-12-03","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Cease and Desist","st":"Final","fine":18293.16,"dk":"SD-15-0064","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Utah Division of Securities (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Utah representatives regarding the sale of non- traded reits.","res":"Stipulation and Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Utah residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Utah residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $18,293.16, Utah's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1915},{"d":"2015-12-03","di":"2015-12-03","dr":"2015-12-03","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Cease and Desist","st":"Final","fine":38522.75,"dk":"AP-15-42","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Missouri Securities Division (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Missouri representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Missouri residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Missouri residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $38,522.75, Missouri's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1916},{"d":"2015-12-03","di":"2015-12-03","dr":"2015-12-03","k":"Regulatory Action","rg":"Other","reg":"Alaska Division of Banking and Securities","san":"Cease and Desist","st":"Final","fine":10570.45,"dk":"15-1804-S","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Alaska division of banking and of securities (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Alaska representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Alaska residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Alaska residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $10,570.45, Alaska's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1917},{"d":"2015-12-01","di":"2014-08-21","dr":"2015-12-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":100002.0,"dk":"2009020634401","al":"The firm was named a respondent in a FINRA complaint alleging that it failed to have a supervisory system reasonably designed to achieve compliance with the securities laws and FINRA rules, and NASD rule 3010(b), by failing to establish, maintain and enforce written procedures to supervise the types of business in which it engaged. The complaint alleges that despite numerous red flags that should have alerted the firm to the types of potential manipulation by its market access customers, the firm's written supervisory procedures (WSPS) continued to lack reasonable or any procedures and reviews for various types of price manipulation, including layering, spoofing, pre-arranged trading, auto-execution, excessive order entry and marking-the-close, and contained fundamental flaws with respect to established reviews. The firm failed to establish, maintain and enforce WSPS reasonably designed to supervise the types of business in which it was engaged and to supervise the activities of registered representatives, registered principals and other associated persons that were reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules, including SEC rule 15C3-5. The complaint also alleges that the firm failed to establish, maintain and enforce adequate anti-money laundering (AML) policies and procedures and failed to reasonably monitor, detect, and cause the reporting of potentially suspicious activity by its market access customers. The firm failed to develop and implement AML policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations promulgated thereunder. Although the firm had AML policies and procedures in place, they were not tailored to its market access business and therefore could not reasonably be expected to detect and cause the reporting of suspicious transactions. The firm missed or otherwise failed to investigate numerous red flags of suspicious activity related to its market access business and clients. This failure was at least partly the result of the firm's failure to adopt clear lines of responsibility for AML compliance regarding the market access business. The complaint further alleges that the firm failed to establish, document and maintain a system of risk management controls and supervisory procedures reasonably designed to systematically manage the regulatory and other risks of providing market access. The firm failed to appropriately control the risks associated with providing its customers with market access so as not to jeopardize the firm's and other market participants' financial condition and the integrity of the trading on the securities markets. The firm also failed to ensure that it had adequate risk management controls to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time. The firm failed to reasonably allocate, by written contract, after a thorough due diligence review, control over specific regulatory risk management controls and supervisory procedures to a broker-dealer customer. The firm failed to adequately review the performance of broker-dealers to whom it has allocated certain regulatory responsibilities. The firm knowingly and deliberately created a disincentive for its employees to conduct rigorous and effective monitoring and curtail potential violative activity and profited handsomely from its abject failure to reasonably monitor and detect thousands of instances of","res":"Decision & Order of Offer of Settlement","sd":"The firm is fined $100,002, in this proceeding.","sm":"Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that the firm failed to establish, document and maintain a system of risk management controls and supervisory procedures reasonably designed to systematically manage the regulatory and other risks of providing market access. As a result, the firm willfully violated section 15(c)(3) of the Securities Exchange Act of 1934 and rule 15C3-5.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1918},{"d":"2015-12-01","di":"2015-04-10","dr":"2015-12-01","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Other","os":"Other","st":"Final","fine":566666.0,"dk":"2011026311802","al":"The firm was named a respondent in a FINRA complaint alleging that its supervisory systems and procedures governing market access were deficient in numerous ways. The complaint alleges that despite numerous red flags that should have alerted the firm to the types of potential manipulation by its market access customers, its WSPS continued to lack reasonable or any procedures and reviews for various types of price manipulation, including layering, spoofing, pre-arranged trading, auto- execution manipulation, excessive order entry and marking-the-close, and contained fundamental flaws with respect to established reviews. The firm failed to establish, maintain and enforce WSPS reasonably designed to supervise the types of business in which it was engaged and to supervise the activities of registered representatives, registered principals and other associated persons that were reasonably designed to achieve compliance with applicable securities laws, regulations and Nasdaq rules, including rule 15C3-5. The complaint also alleges that the firm failed to appropriately control the risks associated with providing its customers with market access so as not to jeopardize the firm's and other market participants' financial condition and the integrity of the trading on the securities markets, as required by SEC rule 15C3-5. The firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of providing market access, as required by rule 15C3-5(b). The firm failed to ensure, as required by rule 15C3-5(c), that it had in place appropriate regulatory risk management controls and supervisory procedures. The firm failed to ensure that it had adequate risk management controls to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time. It failed to ensure that its regulatory risk management controls and supervisory procedures were under its direct and exclusive control, as required by rule 15C3-5(d). It failed to reasonably allocate, by written contract, after a thorough due diligence review, control over specific regulatory risk management controls and supervisory procedures to a broker-dealer customer. The firm failed to adequately review the performance of broker-dealers to whom it has allocated certain regulatory responsibilities. The firm failed to establish, document and maintain a system for regularly reviewing the effectiveness of the risk management controls and supervisory procedures as required by rule 15C3-5(e). Thus, as detailed, the firm willfully violated section 15(c)(3) of the Exchange Act of 1934, and rule 15C3-5 thereunder. The complaint further alleges that the firm established a compensation system rife with potential conflicts of interest. The firm thereby knowingly and deliberately created a disincentive for its employees to conduct rigorous and effective monitoring and curtail potential violative activity. Moreover, despite its receipt of numerous regulatory inquiries as well as exchange-generated reports identifying hundreds of wash trades on a daily basis, the firm took no steps to curtail wash trades. Through such knowing and deliberate conduct, it enabled artificially elevated, distorted and misleading trading volumes of multiple securities across multiple exchanges. The firm handsomely profited from its abject failure to reasonably monitor and detect thousands of instances of potential","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured and fined a total of $566,666 in connection with this proceeding","sm":"Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that as required by SEC rule 15C3-5(d)the firm failed to reasonably allocate, by written contract, after a thorough due diligence review, control over specific regulatory risk management controls and supervisory procedures to a broker-dealer customer. The firm failed to establish, document and maintain a system for regularly reviewing the effectiveness of the risk management controls and supervisory procedures as required by SEC rule 15C3-5(e). As a result, the firm willfully violated section 15(c)(3) of the Securities Exchange Act of 1934, and SEC rule 15C3-5 thereunder, and violated Nasdaq rule 2110 and Nasdaq rule 2010a.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1919},{"d":"2015-12-01","di":"2015-10-01","dr":"2015-12-01","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Other","st":"Final","fine":566666.0,"dk":"2011026311803","al":"The department of market regulation of the Financial Industry Regulatory Authority (FINRA), on behalf of NYSE regulation, inc., alleges: the firm committed egregious and systemic supervisory violations in its business of providing market access to broker- dealers and non-registered market participants (market access customers) to multiple market centers, including the NYSE ARCA marketplace. Without dedicating sufficient resources to ensure appropriate regulatory risk management controls and supervisory systems and procedures, Wedbush enabled its market access customers to flood the exchanges with thousands of potentially manipulative wash trades, and other potentially manipulative trading activity, such as layering and spoofing. Wedbush reaped millions of dollars from its market access business, but failed to devote sufficient resources, including qualified and adequately trained compliance personnel, surveillance systems and controls, to detect and prevent potential manipulative activity by its market access customers. The firm failed to establish, maintain, and enforce supervisory systems and procedures that were reasonably designed to achieve compliance with securities laws, rules and regulations, including NYSE ARCA equities rules addressing the monitoring, detection, and prevention of suspicious and potentially manipulative trading. The firm also failed to establish, document and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory and other risks of having and providing market access and failed to have reasonable procedures to ensure that all authorized traders of its market access customers comply with all NYSE ARCA equities rules. The firm created incentives that rewarded compliance personnel with monthly compensation based on market access customers' trading volume, for which they had responsibility to oversee, and failed to monitor and detect thousands of instances of potentially manipulative trading by recidivist customers, despite repeated red flags. The firm failed to use due diligence to learn essential facts relative to market access customer accounts and failed to periodically review market access customer accounts for irregularities. The firm also failed to take reasonable steps to avoid submission by its market access customers of orders that resulted in locked and crossed markets and failed to reasonably supervise activity by its market access customers with respect to locked and crossed markets, order protection rules and compliance with NYSE ARCA equities rule 7.37(e)(2) and regulation NMS rule 611(c). As a result of its conduct, the firm willfully violated section 15(c)(3) of the Securities Exchange Act of 1934 and market access rule 15C3-5 and regulation NMS rule 611(c) and violated NYSE ARCA equities rules 6.1(b), 6.18, 6.18(a)-(c), 6.2, 7.30(b), 7.37(e)(2), 9.2(a), 9.2(b), 9.2(b)(4) and 2010.","res":"Decision & Order of Offer of Settlement","sd":"Censure and fine of $566,666","sm":"A hearing officer at FINRA considered an offer of settlement and consent entered into between FINRA's department of market regulation on behalf of NYSE regulation, inc. and Wedbush Securities, inc. the offer of settlement and consent was submitted for the purpose of settling this disciplinary proceeding without adjudication of any issues of law or fact and without admitting or denying any allegations or findings referenced in the offer. The offer was submitted in conjunction with the settlements of three other disciplinary actions FINRA brought against Wedbush on behalf of FINRA and two other self- regulatory organizations, which disciplinary actions include substantially the same allegations and charges as those in the complaint in this action. The firm is censured and fined $566,666. The firm settled the related FINRA and exchange complaints for a total fine of $1,800,000, which is allocated as follows: $566,666 each to NYSE ARCA, bats exchange, inc., and Nasdaq, and $100,002 to FINRA. In setting the fine amount, the parties took into consideration that the firm paid $2.44 million to the Securities and Exchange Commission and agreed to hire an independent consultant in settlement of similar claims.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1920},{"d":"2015-12-01","di":"2015-10-01","dr":"2015-12-01","k":"Regulatory Action","rg":"Other","reg":"Bats Z-Exchange, Inc.","san":"Other","st":"Final","fine":566666.0,"dk":"2011026311804","al":"The department of market regulation of the Financial Industry Regulatory Authority (\"FINRA\"), on behalf of Bats exchange, inc. (\"Bats\", \"BZX\", or the \"exchange\"), alleges: the firm committed egregious and systemic supervisory violations in its business of providing direct market access and sponsored access (together \"market access\") to broker-dealers and non-registered market participants (\"market access customers\") to multiple market centers, including BZX. Without dedicating sufficient resources to ensure appropriate regulatory risk management controls and supervisory systems and procedures, Wedbush enabled its market access customers to flood the exchanges with thousands of potentially manipulative wash trades, and other potentially manipulative trading activity, such as layering and spoofing. Wedbush reaped millions of dollars from its market access business, but failed to devote sufficient resources, including qualified and adequately trained compliance personnel, surveillance systems and controls, to detect and prevent potential manipulative activity by its market access customers. The firm failed to establish, maintain, and enforce supervisory systems and procedures that were reasonably designed to achieve compliance with securities laws, rules and regulations, including BZX rules, addressing the monitoring, detection, and prevention of suspicious and potentially manipulative trading. The firm also failed to establish, document and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory and other risks of having and providing market access. The firm created incentives that rewarded compliance personnel with monthly compensation based on market access customers' trading volume, for which they had responsibility to oversee, and failed to monitor and detect thousands of instances of potentially manipulative trading by recidivist customers, despite repeated red flags. As a result of its conduct, the firm willfully violated section 15(c)(3) of the Securities Exchange Act of 1934 and rule 15C3-5 thereunder and violated BZX rules 3.1, 5.1 and 5.4.","res":"Decision & Order of Offer of Settlement","sd":"Censure and fine of $566,666","sm":"An offer of settlement and consent entered into between FINRA's department of market regulation on behalf of Bats Z-Exchange and Wedbush Securities, inc. the offer of settlement and consent was submitted for the purpose of settling this disciplinary proceeding without adjudication of any issues of law or fact and without admitting or denying any allegations or findings referenced in the offer. The offer was submitted in conjunction with the settlements of three other disciplinary actions FINRA brought against Wedbush on behalf of FINRA and two other self-regulatory organizations, which disciplinary actions include substantially the same allegations and charges as those in the complaint in this action. The firm is censured and fined $566,666. The firm settled the related FINRA and exchange complaints for a total fine of $1,800,000, which is allocated as follows: $566,666 each to NYSE ARCA, Bats exchange, inc., and Nasdaq, and $100,002 to FINRA. In setting the fine amount, the parties took into consideration that the firm paid $2.44 million to the Securities and Exchange Commission and agreed to hire an independent consultant in settlement of similar claims.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1921},{"d":"2015-12-01","di":"2015-12-01","dr":"2015-12-01","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Cease and Desist","st":"Final","fine":110855.07,"dk":"IC15-CDO-04","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Texas State Securities Board (the \"board\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Texas representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the board alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Texas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Texas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the board a civil penalty in the amount of $110,855.07 Texas' allocated portion of the amount agreed to with nasaa. Finally, the board and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1922},{"d":"2015-11-30","di":"2015-11-30","dr":"2015-11-30","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Department of Banking and Securities","san":"Cease and Desist","st":"Final","fine":26110.92,"dk":"150046","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Pennsylvania Department of Banking and Securities (the \"department\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Pennsylvania representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Pennsylvania residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Pennsylvania residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $26,110.92, Pennsylvania's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1923},{"d":"2015-11-30","di":"2015-11-30","dr":"2015-11-30","k":"Regulatory Action","rg":"State regulator","reg":"South Dakota Division of Securities","san":"Cease and Desist","st":"Final","fine":12500.7,"dk":"2816","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the South Dakota Division of Securities (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its South Dakota representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to South Dakota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to South Dakota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $12,500.70, South Dakota's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1924},{"d":"2015-11-24","di":"2015-11-24","dr":"2015-11-24","k":"Regulatory Action","rg":"State regulator","reg":"Mississippi Securities Division","san":"Cease and Desist","st":"Final","fine":19253.45,"dk":"LS-15-1497","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Mississippi Securities Division (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Mississippi representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Mississippi residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Mississippi residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $19,253.45, Mississippi's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1925},{"d":"2015-11-24","di":"2015-11-24","dr":"2015-11-24","k":"Regulatory Action","rg":"State regulator","reg":"New Mexico Securities Division","san":"Cease and Desist","st":"Final","fine":11528.48,"dk":"15-09-0049","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the New Mexico Securities Division (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its New Mexico representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to New Mexico residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to New Mexico residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $11,528.48, New Mexico's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1926},{"d":"2015-11-24","di":"2015-11-24","dr":"2015-11-24","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Cease and Desist","st":"Final","fine":19041.63,"dk":"15-0022 CA","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), the Indiana Securities Division (the \"division\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Indiana representatives regarding the sale of non- traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Indiana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Indiana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $19,041.63, Indiana's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1927},{"d":"2015-11-23","di":"2015-08-12","dr":"2015-11-23","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority of Germany","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1218475.35,"dk":"WA 17-WP 3120-2012/0035 - 3121-2014/0027","al":"The Federal Financial Supervisory Authority of Germany (bundesanstalt fÜr finanzdienstleistungsaufsicht ­ \"BAFIN\") alleged certain breaches by Goldman Sachs international (\"GSI\") of the ownership threshold notification requirements of sections 21, 25 and 25a of the german securities trading act (wertpapierhandelsgesetz - \"WPHG\").","res":"Decision","sm":"BAFIN imposed a monetary penalty on gsi of 1,107,503.50 euros in the aggregate, representing an administrative fine of 1,100,000 euros and procedural expenses of 7,503.50 euros, which amount was paid on December 18, 2015.","ab":"Goldman Sachs","firms":[361],"id":1928},{"d":"2015-11-23","di":"2015-11-23","dr":"2015-11-23","k":"Regulatory Action","rg":"Other","reg":"The Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico","san":"Cease and Desist","st":"Final","fine":10125.11,"dk":"N/A","al":"In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (\"NASAA\"), The Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico (the \"ocfi\") alleged that LPL Financial LLC (\"LPL\") failed to implement an adequate supervisory system and enforce its procedures to supervise its Puerto Rico representatives regarding the sale of non-traded reits.","res":"Consent","sm":"This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the \"relevant period\") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the ocfi alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Puerto Rico residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Puerto Rico residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the ocfi a civil penalty in the amount of $10,125.11, Puerto Rico's allocated portion of the amount agreed to with nasaa. Finally, the ocfi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1929},{"d":"2015-11-09","di":"2015-11-05","dr":"2015-11-09","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":41850.0,"dk":"2015-0092-S","al":"The applicant entered into a stipulation with the New York State Department of Financial Services consenting to a civil penalty for violations of New York state insurance regulations that were not the result of any conscious company policy to evade such regulations. The violations arose under 1) regulation no. 33, by deviating from an acceptable means policy reserves and liabilities method of allocation of net investment income on guaranteed investment contracts; and 2) regulation no. 60, by failing to furnish the insurer whose coverage was being replaced with certain required materials and by not ensuring that certain materials were presented to the applicant prior to signing the application.","res":"Stipulation and Consent","sd":"Civil penalty of $41,850 paid in November 2015","sm":"The applicant entered into a stipulation with New York State Department of Financial Services which included a civil penalty of $41,850.","ab":"Mutual of America Life Insurance Company","self":true,"firms":[15356],"id":1930},{"d":"2015-11-04","di":"2015-11-04","dr":"2015-11-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"NONE","al":"LPL consented to the allegations that it violated Ohio statute 3905.22 by failing to timely report a regulatory action taken by the state of New Hampshire dated April 6, 2015.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1931},{"d":"2015-11-03","di":"2015-11-03","dr":"2015-11-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s), censure, disgorgement","st":"Final","fine":10241471.0,"dk":"SEC ADMIN. PROCEEDING FILE NO. 3-16938","al":"These proceedings concern the alleged failure by Fenway Partners, LLC, its principals and a former senior executive to disclose conflicts of interest to a private equity fund client, as well as alleged material omissions to investors in the fund about payments to affiliates. The complete allegations are set forth in the SEC's order instituting proceedings dated November 3, 2015, release no. 4253.","res":"Order","sd":"The order instituting proceedings provides that Fenway Partners, LLC, and respondents peter lamm, william gregory smart, and a former executive of Fenway Partners will pay total disgorgement of $8,716,471.10, consisting of $7,892,000 of disgorgement and $824,471.10 of prejudgment interest, on a joint and several basis. The respondents, except for MR. Wiacek, were also censured pursuant to the terms of the order. Respondents shall also pay a total of $1,525,000 of civil money penalties, which shall be made as follows: $1,000,000 by Fenway Partners, LLC; $150,000 by lamm; $150,000 by smart; $150,000 by the former executive; and $75,000 by respondent walter Wiacek. These amounts were deposited into a distribution fund for the benefit of limited partners on November 24, 2015 and November 25, 2015 and distributed to such limited partners on or before January 26, 2016.","sm":"The SEC filed an order instituting administrative and cease-and-desist proceedings pursuant to sections 203(e), 203(f) and 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease and desist order (the \"order\") on November 3, 2015, to which Fenway Partners, peter lamm, william gregory smart, walter Wiacek, and a former executive of Fenway Partners consented. The monetary sanctions have been described above and are set forth fully in the SEC's release no. 4253. No additional proceedings are anticipated at this time. No information Filed","ab":"Wiacek, Walter, John","firms":[160630],"id":1932},{"d":"2015-10-28","di":"2015-10-28","dr":"2015-10-28","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":50000000.0,"al":"The New York State Department of Financial Services (the \"DFS\") has alleged that: (a) a former associate of Goldman, Sachs & co. (together with The Goldman Sachs Group, inc., \"Goldman Sachs\") engaged in the theft of DFS confidential supervisory information, and that a former Goldman Sachs managing director improperly received this information without reporting it; and (b) Goldman Sachs failed: (I) to effectively supervise the associate to prevent this theft from occurring; (II) to implement and maintain adequate policies and procedures relating to post-employment restrictions for former government employees; and (III) to implement and maintain sufficient policies and procedures to ensure compliance with New York state banking law section 36(10) (\"section 36(10)\"), specifically with respect to Goldman Sachs' unauthorized possession and distribution of DFS confidential supervisory information.","res":"Order","sm":"Goldman Sachs and the DFS entered into a consent order under New York state banking law sections 39 and 44 on October 28, 2015 (the \"consent order\"), pursuant to which Goldman Sachs: (a) voluntarily will not accept any new engagements that would require the DFS to authorize the disclosure of confidential supervisory information under section 36(10) to Goldman Sachs during the three-year period following the date of the consent order; (b) agreed to implement reforms to its policies and procedures that are reasonably designed to prevent the improper use of confidential supervisory information under section 36(10), including: (I) policies and procedures reasonably designed to ensure the protection and proper handling of confidential supervisory information under section 36(10); (II) confirming that, to the best of Goldman Sachs' knowledge, as of the date of the consent order, Goldman Sachs had not accepted any engagements that would require the DFS to authorize the disclosure of confidential supervisory information under section 36(10); (III) policies and procedures reasonably designed to ensure that Goldman Sachs is aware of applicable post-employment restrictions for former government employees hired after the date of the consent order who have left the government within the past five years and that Goldman Sachs has taken steps necessary to address compliance with those restrictions; (IV) processes to monitor the assignment of such former government employees to prevent violations of post-employment restrictions and protect confidential supervisory information under section 36(10); and (v) processes to monitor the use of email to address the misuse of confidential material under section 36(10); and (c) paid a civil monetary penalty in the amount of $50 million on November 9, 2015.","ab":"The Goldman Sachs Group,","firms":[361,283221,286067],"id":1933},{"d":"2015-10-27","di":"2015-10-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","dk":"2015045368001","al":"Without admitting or denying the findings, the firm consented to the entry of findings that certain retirement plan and charitable organization customers eligible to purchase certain mutual funds at a discount were not issued applicable discounts. The findings further stated that the firm failed to maintain policies and procedures designed to ensure such discounts were offered as appropriate.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and agreed to pay approximately $1,030,235, in restitution plus interest to eligible customers.","sm":"In May 2015, the firm self-reported that some eligible customers had not received available sales charge waivers. As a result, the firm estimates that eligible customers were overcharged by approximately $1,030,235 for mutual fund purchases made between July 1, 2009 and June 24, 2015. As part of this settlement, the firm agrees to pay restitution plus interest. The firm will also ensure that retirement and charitable account mutual fund fee waivers are appropriately applied to all future transactions. In resolving this matter, FINRA has recognized the extraordinary cooperation of the firm for having: (1) initiated, prior to detection or intervention by a regulator, an investigation to identify whether eligible customers received sales charge waivers during the relevant period; (2) promptly established a plan of remediation for eligible customers who did not receive appropriate sales charge waivers; (3) promptly self-reported to FINRA; (4) promptly taken action and remedial steps to correct the violative conduct; and (5) employed subsequent corrective measures, prior to detection or intervention by a regulator, to revise its procedures to avoid recurrence of the misconduct.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1934},{"d":"2015-10-27","di":"2015-10-27","dr":"2015-10-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","dk":"2015045163601","al":"The firm self-reported to FINRA that it failed to apply the waivers to mutual fund purchases made by eligible customers and instead sold them 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. These sales disadvantaged eligible customers by causing such customers to pay higher fees than they were actually required to pay. The firm failed to establish and maintain a supervisory system and procedures reasonably designed to ensure that eligible customers who purchased mutual fund shares received the benefit of applicable sales charge waivers. The firm failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In October 2014, the firm began a review to determine whether it had provided available sales charge waivers to eligible customers. Based on this review, in April 2015, the firm self-reported to FINRA that eligible customers had not received available sales charge waivers.","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1935},{"d":"2015-10-26","di":"2015-10-26","dr":"2015-10-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","dk":"2015045354201","al":"On October 26, 2015, FINRA alleged Edward jones violated certain federal securities laws or rules by not ensuring applicable sales charge waivers were received for mutual fund purchases in certain retirement plan and charitable organization accounts. On May 5, 2015, FINRA's enforcement division advised Edward jones that it was investigating this issue. Prior to being advised of the investigation, Edward jones had commenced a review of this issue and self-reported to FINRA.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1936},{"d":"2015-10-26","di":"2011-10-04","dr":"2015-10-26","k":"Civil Judicial Action","san":"Injunction","os":"There were no sanctions ordered or relief granted.","st":"Final","al":"The lawsuit alleges that The Bank of New York Mellon (the \"bank\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by the bank. The registrant is not a defendant to this action.","res":"Settled","sd":"There were no sanctions ordered or relief granted.","ab":"The Bank of New York Mellon Corporation","firms":[111208],"id":1937},{"d":"2015-10-26","di":"2011-06-01","dr":"2015-10-26","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"There were no sanctions ordered or relief granted.","st":"Final","al":"This is a putative class action alleging that BNY mellon improperly charged and reported prices for standing instruction foreign exchange transactions executed in connection with custody services provided by BNY mellon. Plaintiff asserts breach of fiduciary duty, breach of contract, and unjust enrichment claims. The registrant is not a defendant to this action.","res":"Settled","sd":"There were no sanctions ordered or relief granted.","ab":"The Bank of New York Mellon Corporation","firms":[111208],"id":1938},{"d":"2015-10-26","di":"2012-03-12","dr":"2015-10-26","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"There were no sanctions ordered or relief granted","st":"Final","al":"This lawsuit alleges that The Bank of New York Mellon Corporation (\"BNY mellon\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by BNY mellon. Plaintiffs assert claims for breach of contract, fraud, violation of the Ohio deceptive trade practices act and unjust enrichment. The registrant is not a defendant to this action.","res":"Settled","sd":"There were no sanctions ordered or relief granted","ab":"The Bank of New York Mellon Corporation","firms":[111208],"id":1939},{"d":"2015-10-19","di":"2015-10-06","dr":"2015-10-19","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"2015-404B-039","al":"ICE Clear Credit, LLC (\"ICC\") alleged that during the month of September 2015, Goldman, Sachs & co. (the \"firm\") failed to submit one (1) index end of day price in accordance with ICC rules and procedures, in alleged violation of ICC rule 404(b).","res":"Consent","sm":"Icc made a summary assessment against the firm in the amount of $1,000, which amount is direct debited in the next icc monthly clearing fee invoice.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1940},{"d":"2015-10-19","di":"2015-10-06","dr":"2015-10-19","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7000.0,"dk":"2015-404B-038","al":"ICE Clear Credit, LLC (\"ICC\") alleged that during the month of September 2015, Goldman Sachs international (\"GSI\") failed to submit seven (7) index end of day prices in accordance with ICC rules and procedures, in alleged violation of ICC rule 404(b).","res":"Consent","sm":"Icc made a summary assessment against gsi in the amount of $7,000, which amount is direct debited in the next icc monthly clearing fee invoice.","ab":"Goldman Sachs","firms":[361],"id":1941},{"d":"2015-10-19","di":"2015-10-19","dr":"2015-10-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":225000.0,"dk":"2014041839401","al":"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) resulting in customers paying excessive sales charges of approximately $320,917. The findings stated that the firm has paid restitution to all affected customers. The findings also stated that the firm failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to ensure that customers received sales charge discounts on all eligible uit purchases. The firm relied primarily on its registered representatives to ensure that customers received sales charge discounts on all eligible uit rollover and exchange purchases, despite the fact that the firm did not effectively train representatives and their supervisors to identify and apply such sales charge discounts.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $225,000, and paid restitution of $357,521.04 to customers.","sm":"Upon discovering this issue, Commonwealth proactively revised the applicable supervisory systems and procedures for uit rollover and exchange purchases and reimbursed all affected customers for the discounts, plus interest.","ab":"Commonwealth Equity Services, LLC","self":true,"firms":[8032],"id":1942},{"d":"2015-10-14","di":"2015-07-21","dr":"2015-10-14","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement of $184,747.10, prejudgment interest of $2,331.51, and a civil money penalty in the amount of $91,669.95 (for a total","st":"Final","fine":91669.95,"dk":"FILE NO. 3-16895","al":"It appeared that Sabby Management, LLC (\"Sabby\") engaged in prohibited trading whenit sold shares during a restricted period and purchased shares in an offering by collabrx, inc. (ticker: CLRX), which offering priced on February 25, 2015.","res":"Decision & Order of Offer of Settlement","sm":"On two occasions between December 2014 and February 2015, Sabby bought (on behalf of private fund clients) offering shares from an underwriter or broker or dealer participating in a follow-on public offering after having sold short the same security during the restricted period set forth in rule 105 of Regulation M under the Securities Exchange Act of 1934. The subject transactions resulted in profits of $184,747.10 for Sabby's private fund clients. Sabby did not use the shares purchased to cover the shares sold short during the relevant restricted periods, but the SEC nevertheless alleged and found that the foregoing activity violated rule 105. The SEC ordered Sabby (I) to cease and desist from any future violations of rule 105, (II) disgorge the profits (including interest) earned by Sabby's private fund clients as a result of the transactions, and (III) to pay a civil monetary penalty $91,669.95. When issuing its order, the SEC acknowledged the remedial acts promptly undertaken by Sabby and the cooperation afforded by Sabby to the SEC in resolving this matter. No information Filed","ab":"Sabby Management, LLC","self":true,"firms":[162659],"id":1943},{"d":"2015-10-12","di":"2015-10-12","dr":"2015-10-12","k":"Regulatory Action","rg":"Other","reg":"De Nederlandsche Bank N.V.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27172.0,"dk":"N/A","al":"On October 12, 2015, De Nederlandsche Bank N.V. (\"DNB\") imposed a 25,000 euro administrative fine on Wilshire Associates europe B.V. (\"Wilshire europe\") for violating article 3:72, paragraph one, of the financial supervision act for failure to submit within the required time period its quarterly report for investment firms for the second quarter of 2015. Wilshire europe did not violate any other provisions of the financial supervision act in connection with this decision.","res":"Decision","sd":"Pursuant to the decision, DNB imposed an administrative fine of 25,000 euros to be paid within six weeks of the resolution date. No portion of the penalty was waived. The administrative fine was paid on November 6, 2015.","sm":"The decision was final and no further action was taken by DNB upon payment of the administrative fine by Wilshire europe.","ab":"Wilshire Associates","firms":[6210],"id":1944},{"d":"2015-10-01","di":"2015-10-01","dr":"2015-10-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":56202.19,"dk":"I14-083","al":"Without admitting or denying the findings of fact and conclusions of law, LPL entered into a consent order with the office of the secretary of state securities division after a multiple-jurisdiction investigation into LPL's sales transactions of non-traded reits, a form of alternative investments. During the time period beginning January 1, 2008 through December 31, 2013, LPL offered multiple non-traded reits through its branch offices in Nevada that were sold in excess of the REIT's prospectus standards, various state concentrations limits, or its own alternative investment guidelines. LPL failed to implement an adequate supervisory system that was reasonably designed to achieve compliance with nac 90.321. LPL also failed to enforce its written procedures to supervise the activities of its registered representatives in violation of nac 90.321.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1945},{"d":"2015-09-30","di":"2015-09-30","dr":"2015-09-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":100000.0,"dk":"3-16867","al":"On September 30, 2015, the Securities and Exchange Commission (\"SEC\") alleged that certain security firms, including Edward jones, violated section 17(a)(2) of the Securities Act of 1933 (\"Securities Act\") as it relates to certain statements of municipal issuers regarding compliance with previous continuing disclosure obligations in official statements. Edward jones self- reported the aforementioned violations to the SEC pursuant to its municipalities continuing disclosure cooperation (MCDC) initiative. Edward jones is one of fifty-eight firms participating in the MCDC initiative.","res":"Order","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1946},{"d":"2015-09-30","di":"2015-09-30","dr":"2015-09-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":220000.0,"dk":"3-16858","al":"SEC admin releases 33-9946; 34-76043; September 30, 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 Northland Securities, Inc. (\"respondent\"). Respondent 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 respondent's underwriting of certain municipal securities offerings. Respondent, 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 respondent offering and selling municipal securities on the basis of materially misleading disclosure documents. The violations were self-reported by respondent to the commission pursuant to the division of enforcement's (the \"division\") municipalities continuing disclosure cooperation (MCDC) initiative.","res":"Order","sd":"The respondent shall cease and desist from committing or causing any violations and any future violations of section 17(a) (2)of the Securities Act, pay a civil money penalty in the amount of $220,000 and comply with the undertakings enumerated in the offer of settlement.","sm":"In anticipation of the institution of these proceedings, respondent 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 it and the subject matter of these proceedings, which are admitted, respondent consents to 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 respondent's offer. Accordingly, it is hereby ordered that respondent 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 $220,000 to the Securities and Exchange Commission; and retain an independent consultant to conduct a review of respondent's policies and procedures as they relate to municipal securities underwriting due diligence.","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":1947},{"d":"2015-09-28","di":"2010-02-18","dr":"2015-09-28","k":"Regulatory Action","rg":"Other","reg":"Comision Nacional Del Mercado de Valores","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":18471600.0,"al":"Not complying with the regulations pertaining to commissions, costs and revenues of the funds afected in relation to certain rebates.","res":"Decision","sd":"$18,471,600","sm":"On August 2, 2011 by order entered by the ministry of economy and taxes, a fine was imposed on Santander asset mangement, sgic SA in the amount of $18,471,6000 due to an alleged infringment of article 80.n of act no. 35/2003, dated November 4, 2003, relating to the imcome, fees and costs regime of two investment funds during the years 2003 to 2007. The fine relates to an issue brought by the \"comite consultivo de la Comision Nacional Del Mercado de Valores\" (spain's stocks and investment product reulator consultation committee) alleging that the non-compliance of the obligation has a \"generic character\" and its interpretation \"could have got enough clarity only recently.\" On October 18, 2011, sam filed an appeal against the order in the courts of audiencia general. The fine was temporarily held on December 1, 2011 until the process had ended. On December 14, 2012, audiencia general rejected the appeal. On January 18, 2013, sam filed its intention to appeal to the spanish Supreme Court. On March, 2013, sam filed an appeal to the spanish Supreme Court. Final decision was issued by he Supreme Court on September 2015. Payment of the fine was made in February 2016.","ab":"Santander Asset Management SA Sgiic","self":true,"firms":[143883],"id":1948},{"d":"2015-09-24","di":"2011-10-04","dr":"2015-09-24","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Disgorgement, monetary damages, restraining order, injunction, restitution","st":"Final","fine":167500000.0,"al":"The lawsuit alleges that The Bank of New York Mellon (\"BNY mellon\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by BNY mellon. The registrant is not a defendant to this action.","res":"Settled","sd":"Details indicated above.","ab":"The Bank of New York Mellon","firms":[231],"id":1949},{"d":"2015-09-24","di":"2011-10-04","dr":"2015-09-24","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"The bank agreed to make a number of factual statements in connection with the settlement with the U.S. attorney's office for the southern","st":"Final","fine":167500000.0,"al":"The lawsuit alleges that the Bank of New York Mellon (\"the bank\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by the bank. The registrant is not a defendant to this action.","res":"Settled","sd":"Details indicated above.","ab":"Bank of New York Mellon","firms":[231],"id":1950},{"d":"2015-09-22","di":"2015-09-22","dr":"2015-09-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":20000.0,"dk":"2013035824401","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it transmitted to OATS reports that contained inaccurate, incomplete, or improperly formatted data. The findings stated that specifically, the firm submitted reports with inaccurate \"LVS qty\", failed to submit route reports, submitted an order execution report for an agency routed order, submitted an inaccurate order receipt time, failed to submit order information, and failed to submit the appropriate account type code. The findings also stated that the firm failed to properly memorialize OATS order information on the memoranda of brokerage orders. Specifically, the firm failed to memorialize immediate or cancel, or intermarket sweep order special handling codes, the peg special handling code, and the customer instructions regarding displaying the limit order on the order ticket. The findings also included that the firm failed to provide written notification disclosing relevant information to its customers. Specifically, the firm failed to disclose that the transactions were executed at average prices, that transaction details were available upon request, its capacity in the transactions, and that it charged commissions or commission equivalents. FINRA found that the firm's supervisory system failed to provide for supervision reasonably designed to achieve compliance with respect to SEC rule 204. Specifically, the firm's written supervisory procedures (WSPS) did not include the identification of the person responsible for supervision, the supervisory steps and reviews to be taken by the appropriate supervisor, the frequency of the supervisory reviews, and how the supervisory reviews should be documented.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Censure and fine of $20,000","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1951},{"d":"2015-09-22","di":"2015-09-22","dr":"2015-09-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Delaware Investor Protection Unit","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":200000.0,"dk":"13-5-1","al":"Without admitting or denying the conclusions of law, LPL entered into a consent order with the Delaware investor protection unit after their investigation into LPL's use of leveraged and inverse leveraged exchange-traded funds (ETFS). LPL offered leveraged ETFS to certain retail clients in Delaware that were unsuitable, and/or without adequate disclosure of the specialized risks of leveraged ETFS, which constitutes a dishonest or unethical practice. LPL failed to ensure that its financial advisors understood and explained the unique risks, failed to enforce its warning and fine system with regard to its leveraged ETFS concentration limits, and failed to adequately monitor and ensure the monitoring of client holding periods, all of which constitute a failure to supervise.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1952},{"d":"2015-09-21","dr":"2015-09-21","k":"Regulatory Action","rg":"Other","reg":"Bats Z-Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2010024913201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that during the period between January 19, 2010 and February 28, 2011, the firm failed to report numerous reportable options positions because the firm had failed to properly aggregate and report positions to the options clearing corporation (OCC) large options positions report (LOPR) for approximately 39 accounts related to five acting in concert (AIC) groups that acted in concert. This conduct violated chapter xviii, section 18.10 of the BZX exchange rules. During the period between January 19, 2010 and February 28, 2011, the firm failed to have an adequate supervisory system in place to ensure the accuracy and completeness of the reporting of its options positions, including in-concert reporting, to the LOPR. This conduct violated chapter xviii, rule 18.2(a) (1) of the BZX exchange rules. During the period between January 19, 2010 and the present, the firm has failed to have adequate written supervisory procedures (WSPS) regarding in-concert reporting to the LOPR and to ensure the accuracy and completeness of its daily LOPR submissions. Specifically, the firm's WSPS fail to reflect: (I) the step(s) that the firm's designated person responsible to ensure compliance with applicable rules should take to ensure compliance therewith; (II) how often such person(s) should take such step(s); and (III) how such steps are documented. This conduct violated chapter v, rules 5.1, 5.3, and 5.4 of the BZX exchange rules.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Censured, fine of $20,000 and undertaking to revise the WSP's","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":1953},{"d":"2015-09-17","di":"2015-09-17","dr":"2015-09-17","k":"Regulatory Action","rg":"State regulator","reg":"South Dakota Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"N/A","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the South Dakota Division of Securities (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in South Dakota, that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in South Dakota. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in South Dakota through sales assistants that were highly likely not registered in South Dakota, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in South Dakota constituted bases for the assessment of an administrative fine pursuant to SDCL 47-31b- 604(d). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, South Dakota's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1954},{"d":"2015-09-15","di":"2015-09-15","dr":"2015-09-15","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1800000.0,"dk":"15-2854E","al":"Without admitting or denying the findings of fact and conclusions of law, LPL entered into an assurance of discontinuance with the Commonwealth of Massachusetts, after an investigation into LPL's use of leveraged and inverse leveraged exchange-traded funds (ETFS). LPL offered leveraged ETFS to certain retail clients in Massachusetts without monitoring or systematically reviewing the length of time its clients held leveraged ETFS. LPL provided insufficient training materials that, in parts, suggested that leveraged ETFS were appropriate for conservative accounts, and in some instances recommended buying and holding, without reminding financial advisors of the specific risks associated with holding leveraged ETFS. LPL failed to identify and examine potential issues concerning the suitability of leveraged ETF exposure for those of LPL's financial advisors who caused clients to hold leveraged ETFS for extended periods of time. Moreover, LPL did not consistently adhere to its policy of imposing fines on LPL Financial advisors who exceeded this concentration limit, sometimes issuing multiple warnings unaccompanied by any sanctions.","res":"Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1955},{"d":"2015-09-14","di":"2015-09-14","dr":"2015-09-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"2013039305901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that, during the relevant review period, it failed to implement policies and procedures that reasonably avoid displaying, or engaging in a pattern or practice of displaying, locking or crossing quotations in any over-the-counter (OTC) equity security. The findings stated that, during the relevant review period, 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 FINRA rules, concerning FINRA rule 6437.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $17,500 and required to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1956},{"d":"2015-09-11","di":"2015-09-11","dr":"2015-09-11","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Virginia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"SEC-2014-00035","al":"The division alleges that wfa committed multiple violations of (I) rule 21 vac 5-20-260 b by failing to exercise diligent supervision over securities activities of its agent; (II) rule 21 vac 5-20-260 d (2) by failing to monitor and conduct frequent examinations of all customer accounts to detect and prevent irregularities or abuses; and (III)rule 21 vac 5-20-260 d by failing to enforce its written policies and procedures.","res":"Order","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1957},{"d":"2015-09-09","di":"2015-09-09","dr":"2015-09-09","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"CASE NO. AP-15-23","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Missouri Securities Division (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Missouri and that CGMI failed to monitor the registration status of these sales assistants to ensure that these persons were registered in Missouri. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Missouri through sales assistants that were highly likely not registered in Missouri and the failure to monitor the registration status of these sales assistants to ensure that these persons were registered in Missouri constituted bases for the assessment of an administrative fine pursuant to sections 409.4-412(c) and 409.6-604, rsmo. (Cum. Supp. 2013). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Missouri's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1958},{"d":"2015-09-04","di":"2015-09-04","dr":"2015-09-04","k":"Regulatory Action","rg":"Other","reg":"Superintendencia Del Mercado de Valores, Peru in Regards to Access Seaf Safi, a Relying Adviser of Seaf","san":"Revocation","st":"Final","dk":"090-2015-SMV/02","al":"Access Seaf Safi was not in compliance with reporting requirements to the Superintendencia del mercado de valores. There was a site visit by the Superintendencia del mercado de valores on September 1, 2015, but Access Seaf Safi's office was closed and there was no way to Access a representative of Access Seaf Safi. Access Seaf Safi did not submit an annual audit report for 2014. Access Seaf Safi did not submit / has not responded regarding the requirement to complete anti-money laundering and anti- terrorism reports. Access Seaf Safi does not have adequate physical infrastructure or technology to perform its duties. Access Seaf Safi has not remedied its financial deficit in accordance with article 130 of the regulations for investment funds and their management companies.","res":"Consent","sd":"N/a","sm":"In responding to item 11.D.5, it should be noted that in early 2012 the shareholders of fondo latam peru (\"the fund\") denied Access Seaf Safi, a relying advisor of seaf, its right to retain certain exit proceeds thereby leaving the fund with insufficient liquidity to pay its liabilities. The fund's significant liability is an account payable of over usd 1.1 million due to Access Seaf Safi, that remains unpaid. In Q1, 2015 after significant financial support from seaf to Access Seaf Safi, the funds' shareholders put the fund into liquidation and appointed a third party liquidator. As a result, Access Seaf Safi no longer needed to retain its registration and its registration was subsequently cancelled by the peruvian financial regulator (the SMV). No information Filed","ab":"Access Seaf Safi","firms":[161539],"id":1959},{"d":"2015-08-31","di":"2015-08-31","dr":"2015-08-31","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"CAUSE NO. 15-0013 CA","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Indiana Securities Division (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Indiana, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Indiana. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Indiana through sales assistants that were highly likely not registered in Indiana, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Indiana constituted bases for the assessment of an administrative fine pursuant to ind. Code § 23­19­4­12(c) and (d)(9). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Indiana's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1960},{"d":"2015-08-28","di":"2015-08-28","dr":"2015-08-28","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":80000.0,"dk":"2013039452701","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1961},{"d":"2015-08-27","dr":"2015-08-27","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"ORDER NO. SD-15-0041","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Utah Division of Securities (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Utah, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Utah. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Stipulation and Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Utah through sales assistants that were highly likely not registered in Utah, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Utah constituted bases for the assessment of an administrative fine pursuant to section 61-1-6(1)(a)(IV) of the Utah uniform Securities Act. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Utah's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1962},{"d":"2015-08-19","di":"2015-08-19","dr":"2015-08-19","k":"Regulatory Action","rg":"Other","reg":"United States Securities & Exchange Commission","san":"Cease and Desist","os":"Other sanctions included (1) a censure, (2) payment of a civil monetary penalty of $15,000,000 by Citigroup Global Markets Inc. and","st":"Final","fine":15000000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-16764","al":"On August 19, 2015, Citigroup Global Markets Inc. (\"CGMI\") consented to the entry of an order bearing administrative file number 3-16764 (the \"order\") by the U.S. Securities and Exchange Commission (the \"SEC\") finding that CGMI violated section 15(g) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and section 206(4) of the Investment Advisers Act of 1940 (\"Advisers Act\") and rule 204-7 thereunder. CGMI consented to the entry of the order without admitting or denying the SEC's findings. The SEC's findings included that certain of CGMI's technological errors caused CGMI's surveillance for trading in violation of legal requirements and firm policies to be inadequate. These technological errors included: (1) CGMI's inadvertent exclusion of certain trades from a data feed used in CGMI's surveillance for trading against the loan watch list, which began in 2002 and was discovered and repaired in 2009; (2) CGMI's omission of certain data from the reports used to monitor compliance with the restricted trading list, which began in spring of 2009 and was resolved in March 2012; and (3) CGMI's inadvertent routing of transactions on behalf of advisory clients to an affiliated market maker, automated trading desk financial services LLC, which occurred from approximately October 2007 through February 2010.","res":"Order","sm":"Pursuant to the order entered August 19, 2015, cgmi was censured and ordered to cease and desist from committing or causing any violations of section 15(g) of the Exchange Act and section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. Cgmi agreed to pay a civil monetary penalty in the amount of $15 million and payment was made on August 25, 2015. Cgmi also agreed to comply with certain undertakings, including, among other things: (a) retaining a consultant, or continuing to retain its current consultant, to conduct a review of cgmi's current surveillance program, including its implementation and enforcement of trade surveillance policies and procedures, its surveillance report development, process of applications, change management processes and procedures, and its use of the loan watch list and RTL; (b) retaining a consultant, or continuing to retain its current consultant, to conduct a review of cgmi's policies and procedures concerning the handling and routing of advisory orders; (c) the consultant(s) preparing a written report that evaluates the areas reviewed and provides recommendations about how cgmi should modify or supplement its trade surveillance policies and procedures and advisory account order handling and routing policies and procedures and the implementation and enforcement of such procedures; (d) taking all necessary and appropriate steps to adopt the consultant(s) recommendations; and (e) certifying, in writing, compliance with the undertakings.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1963},{"d":"2015-08-18","dr":"2015-08-18","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Censure","os":"Fine, undertaking","st":"Final","fine":2850000.0,"dk":"2013035466101","al":"Alleged violation of sections 11(a)1 and 17(a)3 of the Securities Exchange Act of 1934 and NYSE rules 90(a), 410(b), 132(a), 440, and 342 in that Citigroup Global Markets Inc. caused floor brokers associated with the firm to improperly effect certain transactions for its own account on the floor of the exchange without qualifying for an exemption and allowed the above referenced proprietary orders to be transmitted to the NYSE floor without being identified in a manner that would enable the orders to be handled pursuant to the requirements of the Exchange Act from July 2007 through October 2014, submitted inaccurate ati codes for comparison and/or settlement with respect to transactions effected on the exchange on certain occasions between September 2007 and April 2013, certain of the firm's records of orders were inaccurate between July 2007 and April 2013, and failed to establish and maintain appropriate procedures of supervision and control between July 2007 and October 2014.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to a censure, a fine of $2,850,000 and an undertaking to retain an independent consultant to conduct a comprehensive review of the adequacy of the firm's policies, system and procedures and training.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1964},{"d":"2015-08-18","di":"2015-08-18","dr":"2015-08-18","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"ORDER NO. IC15-CAF-01","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Texas State Securities Board (the \"board\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Texas, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Texas. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the board alleged that the acceptance of client orders in Texas through sales assistants that were highly likely not registered in Texas, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Texas constituted bases for the assessment of an administrative fine pursuant to section 23-1.a(3) of the Texas Securities Act. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the board a sum in the amount of $35,000, Texas' allocated portion of the amount agreed to with nasaa. Finally, the board and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1965},{"d":"2015-08-18","di":"2015-08-18","dr":"2015-08-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalties, disgorgement and prejudgment interest","st":"Final","fine":14800000.0,"dk":"SEC RELEASE NO. 34-75720; ACCOUNTING & AUDIT ENFORCEMENT RELEASE NO. 3679; ADMIN PROCEEDING FILE NO. 3-16762","al":"The SEC staff alleged violations of the U.S. foreign corrupt practices act in connection with the provision of a limited number of internships to relatives of sovereign wealth fund officials.","res":"Order","sd":"Disgorgement of $8,300,000, prejudgment interest of $1,500,000 and a civil money penalty in the amount of $5,000,000, for a total payment of $14,800,000. BNY mellon effected payment on August 24, 2015.","sm":"In January 2011, the enforcement division of the U.S. Securities and Exchange Commission (the \"SEC staff\") informed several financial institutions, including The Bank of New York Mellon Corporation (\"BNY mellon\"), that it had commenced an inquiry into certain of their business practices and relationships with sovereign wealth fund clients. In the third quarter of 2014, the SEC staff issued wells notices to certain current and former employees of BNY mellon, informing them that the SEC staff had made a preliminary determination to recommend enforcement action against them for alleged violations of the U.S. foreign corrupt practices act in connection with the provision of a limited number of internships to relatives of sovereign wealth fund officials. BNY mellon received a similar wells notice in the fourth quarter of 2014. On January 23, 2015, BNY mellon received an additional subpoena from the SEC expanding the scope of the SEC's inquiry into the provision of internships and employment opportunities offered to officials and relatives of officials at government- related entities. On August 18, 2015, the SEC announced that it had entered into an administrative settlement on a neither-admit-nor-deny basis with BNY mellon in which BNY mellon agreed to pay $14.8 million to resolve this inquiry. In addition, the SEC has indicated that it is no longer pursuing any current or former BNY mellon employees in connection with this matter.","ab":"The Bank of New York; The Bank of New York Mellon Corporation","firms":[111208,145995],"id":1966},{"d":"2015-08-17","di":"2015-08-17","dr":"2015-08-17","k":"Regulatory Action","rg":"Other","reg":"Oregon Department of Business and Consumer Services; Division of Financial Regulation","san":"Cease and Desist","os":"Civil and administrative penalty(IES)/fine(s)","st":"Final","fine":5000.0,"al":"Failure to timely amend section 14 of CRD Form U-4 to update financial disclosures.","res":"Consent","ab":"Mccabe, Trudy, L","firms":[7059],"id":1967},{"d":"2015-08-17","di":"2015-08-17","dr":"2015-08-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Censure","os":"Disgorgement and prejudgment interest","st":"Final","dk":"3-16757","al":"Alleged violations of sections 17(a)(2) and 17(a)(3) of the Securities Act against Citigroup Global Markets Inc. (CGMI) and Citigroup Alternative Investments LLC (CAI), section 206(2) against CGMI, and sections 206(4) of the Advisers Act, rule 206(4)-7 promulgated thereunder, and rule 206(4)-8 promulgated thereunder against CAI in that the firms' financial advisers and the fund manager misrepresented two alternative investment products' risks and performance to clients from 2002 through 2008.","res":"Order","sd":"Cease and desist, censure, disgorgement of $139,950,239 and prejudgment interest of $39,612,089","sm":"Without admitting or denying the findings, the firms consented to an order to cease and desist, a censure, disgorgement of $139,950,239 and prejudgment interest of $39,612,089.","ab":"Citigroup Alternative; Citigroup Alternative Investments LLC","self":true,"firms":[7059,119537],"id":1968},{"d":"2015-08-14","di":"2015-08-14","dr":"2015-08-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":30000.0,"dk":"2011030674103","al":"Alleged violation of NASD rules 3010(b) and 2110 and FINRA rule 2010 in that Citigroup Global Markets Inc. permitted certain quarterly dividend checks received from an issuer and payable to a third party, to be deposited into the personal brokerage account of a registered reprentative without obtaining a letter of authorization from the third party payee between April 9, 2007 and April 6, 2009.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and a fine of $30,000.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1969},{"d":"2015-08-13","di":"2015-08-13","dr":"2015-08-13","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"N/a","st":"Final","fine":15000000.0,"dk":"3-16751","al":"On August 13, 2015, the Securities and Exchange Commission (\"SEC\") alleged that Edward jones violated sections 17(a)(2) and (3) of the Securities Act of 1933 (\"Securities Act\"), sections 15b(c)(1) and 15(b)(4)(e) of the Securities Exchange Act of 1934 (\"Exchange Act\"), and municipal securities rulemaking board (\"MSRB\") rules G-17, G-11(b) and (d), G-27 and G-30(a) in connection with improper practices involving municipal securities. In entering into the settlement, the SEC considered remedial acts undertaken by Edward jones related to this matter.","res":"Order","sm":"Refer to part II, item 12(c.) Of this regulatory action disclosure reporting page for a discussion of the monetary sanctions agreed to as part of the settlement. The settlement provides for the following schedule with respect to disgorgement: (1) Edward jones shall be responsible for administering the disgorgement; (2) within 60 days of August 13, 2015 (the \"order date\"), Edward jones shall submit to the Securities and Exchange Commission staff (\"SEC staff\"), for its review and approval, a proposed calculation for the disbursement of the disgorgement; (3) Edward jones shall complete the transmission of all amounts in accordance with the approved calculation within 120 days of the order date; and (4) Edward jones shall submit to the SEC staff , for its review and approval the final accounting for the disgorgement within 180 days of the order date. Pursuant to the settlement, the SEC staff may extend these dates for good cause shown.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":1970},{"d":"2015-08-12","di":"2015-06-04","dr":"2015-08-12","k":"Regulatory Action","rg":"Other","reg":"Korean Financial Services Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1758.0,"al":"Orbis unintentionally failed to timely report to the Korean Financial Services Commission (FSC\") that the Orbis funds held in excess of 4% of the total outstanding voting shares of a Korean bank holding company. Upon realizing this omission, Orbis promptly made the required filing. On August 12, 2015, Orbis, through its legal counsel, paid an administrative fine of KRW2,080,000 to resolve the matter, which was equivalent to less than US$1,800 at exchange rates as of that date.","res":"Consent","sm":"On August 12, 2015, Orbis, through its counsel, paid an administrative fine of KRW2,080,000 to resolve the above-mentioned late filing, which was equivalent to less than US$1,800 at exchange rates as of that date. No information Filed","ab":"Orbis Investment Management Limited","self":true,"firms":[157571],"id":1971},{"d":"2015-08-11","di":"2015-08-11","dr":"2015-08-11","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":35000.0,"dk":"2014-111","al":"An ICE Futures U.S., Inc. (\"IFUS\") subcommittee of the business conduct committee (the \"BCC subcommittee\") determined that J. Aron & Company (\"j. Aron\") may have violated IFUS rule 6.20(b) in one (1) instance by carrying a position in excess of applicable spot month position limits.","res":"Consent","sm":"Without admitting or denying any violation of ifus rules, j. Aron entered into a settlement agreement, which was approved by the BCC subcommittee, in which j. Aron: (I) agreed to cease and desist from future violations of ifus rule 6.20(b); and (II) consented to a fine in the amount of $35,000, which was paid by submission of a wire on September 2, 2015.","ab":"J. Aron & Company","firms":[361],"id":1972},{"d":"2015-08-10","di":"2015-08-10","dr":"2015-08-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":70000.0,"dk":"2012031645001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to show the terms and conditions on the memorandum of 82 brokerage orders. The findings stated that on five occasions, the firm accepted a short sale order in an equity security from another person, or effected a short sale in an equity security for its own account, without: borrowing the security, or entering into a bona-fide arrangement to borrow the security; or having reasonable grounds to believe that the security could be borrowed so that it could be delivered on the date delivery is due; and documenting compliance with SEC rule 203(b)(1) of Regulation SHO. The findings also stated that the firm transmitted 33 reports to the order audit trail system (OATS) that contained inaccurate, incomplete, or improperly formatted data. The findings also included that the failed to append the short sale indicator on 24 trade reports submitted to the FINRA/Nasdaq trade reporting facility for a short sale transaction in a reportable security and failed to timely report to the FINRA/Nasdaq trade reporting facility reporting by 8:00 P.M. Eastern time 12 transactions that required a .RX modifier. FINRA found that for the month of April 2012, the firm made available a report on the covered orders in national market system securities that it received for execution from any person that included inaccurate information.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $70,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1973},{"d":"2015-08-06","di":"2015-08-16","dr":"2015-08-06","k":"Regulatory Action","rg":"State regulator","reg":"Mississippi Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"FILE NO. LS-15-1376","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Mississippi Securities Division (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Mississippi, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Mississippi. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Mississippi through sales assistants that were highly likely not registered in Mississippi, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Mississippi constituted bases for the assessment of an administrative fine pursuant to section 75-71-604(a)(3)(b) of the Mississippi Securities Act miss code ann.§§ 75­71­101 et seq. Currently in force and section 75­71­715(2)(a) of its predecessor Securities Act. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Mississippi's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1974},{"d":"2015-08-03","di":"2015-07-31","dr":"2015-08-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"51792-S","al":"LPL consented to the sanctions and the entry of the findings that from September 2009 to September 2013, LPL allowed one of its registered representatives to engage in investment advisory business from an office in the state of Florida without being lawfully registered in Florida.","res":"Stipulation and Consent","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1975},{"d":"2015-08-03","di":"2015-08-03","dr":"2015-08-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":500000.0,"dk":"2012033568901","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it made unsuitable recommendations to retail customers to purchase structured repackaged asset-backed trust securities (STRATS), a complex structured product that paid a floating rate of periodic income up to a minimum or maximum rate, based on the STRATS trust's interest in a capital security issued by a financial institution and the STRATS trust's interest in an interest rate swap contract. The firm sold approximately $12 million worth of the STRATS to its retail customers, in both primary and secondary markets. Although the firm provided its sales-force training on structured products, none of this training related specifically to the unique features and risks of the STRATS. Additionally, although the firm's intranet page dedicated to fixed income products provided basic information concerning the STRATS, it did not provide any information concerning the risks of investing in these products, and specifically did not address the risks to customer principal in the event of a redemption of the underlying capital security. Under the terms of the prospectus for the STRATS, the amount paid to a customer in the event of a termination was the proceeds of the redemption of underlying capital security plus accrued interest and less the swap termination fee. In certain circumstances, the customer would face a substantial risk of loss of principal upon termination of the STRATS due to the amount of the swap termination fee. The firm's registered representatives generally were not familiar with such risks of investing in the STRATS and were consequently unable to explain such risks when recommending the product to the firm's retail customers. Eventually, the financial institution redeemed the underlying capital security, causing the STRATS to be terminated. The financial institution redeemed the underlying capital security at par value plus accrued interest. Based on the terms of the[NTC] STRATS, customers received the proceeds of the redemption [NTC] of the underlying capital security less the swap termination fee paid. As a result, at the time of the STRATS' termination, many customers holding the STRATS received less, and in some cases significantly less, than the amount they paid for the STRATS. Nevertheless, the firm's registered representatives did not comprehend the risks to customers of investing in the STRATS and thus lacked a reasonable basis for recommending these products to the firm's retail customers. The findings stated that the firm made available to its sales-force certain internal-use only documents regarding the STRATS. These documents did not contain adequate descriptions of the product, nor did they disclose the degree to which STRATS customers could lose principal if the underlying capital security was redeemed. Accordingly, the firm's internal-use only communications were not fair and balanced and did not provide a sound basis for evaluating the facts surrounding the STRATS or its risks. The findings also stated that the firm failed to establish and maintain supervisory procedures, including training of its registered representatives, reasonably designed to achieve compliance with FINRA suitability standards. The firm's supervisory system for the sale of STRATS was not reasonably designed because it failed to include adequate training for the firm's sales-force regarding the risks of investing in the product. The firm did not provide product specific training to its registered representatives, and the internal-use only materials made available to its registered","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":1976},{"d":"2015-07-28","di":"2015-07-28","dr":"2015-07-28","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"NO. CO-2015-0015","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Alabama Securities Commission (the \"commission\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Alabama, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Alabama. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the commission alleged that the acceptance of client orders in Alabama through sales assistants that were highly likely not registered in Alabama, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Alabama constituted bases for the assessment of an administrative fine pursuant to section 8-6-19(j)(1), code of Alabama 1975. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the commission a sum in the amount of $35,000, Alabama's allocated portion of the amount agreed to with nasaa. Finally, the commission and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1977},{"d":"2015-07-27","di":"2015-07-27","dr":"2015-07-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":450000.0,"dk":"20130377846-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":1978},{"d":"2015-07-24","di":"2015-07-24","dr":"2015-07-24","k":"Regulatory Action","rg":"State regulator","reg":"Rhode Island Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"ORDER NO. 15-21","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Rhode Island division of securities (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Rhode Island, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Rhode Island. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Rhode Island through sales assistants that were highly likely not registered in Rhode Island, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Rhode Island constituted bases for the assessment of an administrative fine pursuant to section 7-11-602(b)(4) of the Rhode Island uniform Securities Act. Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Rhode Island's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1979},{"d":"2015-07-22","di":"2015-07-22","dr":"2015-07-22","k":"Regulatory Action","rg":"Other","reg":"Anbima ­ AssociaÇÃO Brasileira Das Entidades Dos Mercados Financeiro E de Capitais","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":144982.17,"dk":"005/2015","al":"Anbima ­ AssociaÇÃO Brasileira Das Entidades Dos Mercados Financeiro E de Capitais (\"Anbima\") filed a proceeding for investigation of irregularities (\"PAI\") to investigate whether Goldman Sachs Do Brasil banco mÚltiplo S.A. (\"GSBR\") may have violated article 27, paragraph 3, v of the Anbima code of regulation and best practices to investment funds (cÓdigo Anbima de regulaÇÃo e melhores PRÁticas para fundos de investimento, \"Anbima's code of funds\") in connection with GSBR's tax treatment of payments of interest on capital in connection with stock lending trades involving a brazilian investment fund managed by GSBR (the \"fund\").","res":"Settled","sm":"Without admitting or denying the rule violation, Anbima and GSBR entered into a settlement agreement on July 22, 2015, in which GSBR agreed to: (I) ensure full compliance with all provisions of the Anbima's code of funds, specifically with respect to matters relating to the pai; (II) adopt additional internal controls relating to governance and management of the fund and conduct related training with submission to Anbima of a list of attendees of the training once completed; (III) refrain from preparation of any material for distribution, solicitation, advertisement or any other material intended to solicit new shareholders for the fund; and (IV) refrain from using the fund's performance track record in the marketing material of any other fund managed by GSBR for a period of twelve (12) months. In addition, GSBR agreed to make a financial payment to Anbima in the amount of five hundred thousand reais (BRL$500,000.00), which amount was paid by GSBR on August 3, 2015.","ab":"Goldman Sachs Do Brasil","firms":[361],"id":1980},{"d":"2015-07-21","di":"2015-07-21","dr":"2015-07-21","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"DOCKET NO. 2015-0071","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Massachusetts Securities Division (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Massachusetts, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Massachusetts. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual states may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in Massachusetts through sales assistants that were highly likely not registered in Massachusetts, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Massachusetts violated mass. Gen. Laws CH. 110a § 201(a) and (b) and 950 mass. Code regs. 12.203(3)(a). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, Massachusetts' allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1981},{"d":"2015-07-16","di":"2015-02-26","dr":"2015-07-16","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"15-0005 / 20150442706","al":"Chicago Board Options Exchange, Incorporated (\"CBOE\") business conduct committee (the \"committee\") alleged that Goldman, Sachs & co. (the \"firm\") failed to appropriately register with the CBOE: (I) on various dates between on or about November 5, 2011 through on or about October 10, 2014, five (5) associated persons as a proprietary trader (PT), and (II) by November 5, 2011, its chief compliance officer as a proprietary trader compliance officer (CT), each in alleged violation of CBOE rule 3.6a.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted an offer of settlement to the committee. On July 16, 2015, the committee issued a decision accepting the offer of settlement, and on July 30, 2015, the firm submitted a wire in payment of the fine in the amount of $15,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1982},{"d":"2015-07-16","di":"2015-02-26","dr":"2015-07-16","k":"Regulatory Action","rg":"Other","reg":"C2 Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2500.0,"dk":"C2 15-0001 / 20150442481","al":"C2 Options Exchange, Incorporated (\"C2\") business conduct committee (the \"committee\") alleged that, from on or about March 27, 2013 through on or about July 11, 2014, Goldman, Sachs & co. (the \"firm\") failed to appropriately register its financial and operations principal as a financial and operations principal (FN) with C2, in alleged violation of C2 rule 3.4.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted an offer of settlement to the committee. On July 16, 2015, the committee issued a decision accepting the offer of settlement, and on July 30, 2015, the firm submitted a wire in payment of the fine in the amount of $2,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1983},{"d":"2015-07-14","di":"2015-07-08","dr":"2015-07-14","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":19000.0,"dk":"2015-404B-020","al":"ICE Clear Credit LLC (\"ICC\") alleged that during the month of June 2015, Goldman, Sachs & co. (the \"firm\") failed to submit certain index prices in accordance with ICC rules and procedures, in alleged violation of ICC rule 404(b).","res":"Consent","sm":"Icc made a summary assessment against the firm in the amount of $19,000, which amount was direct debited in an icc monthly clearing fee invoice.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1984},{"d":"2015-07-14","di":"2015-07-08","dr":"2015-07-14","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":127000.0,"dk":"2015-404B-021","al":"ICE Clear Credit LLC (\"ICC\") alleged that during the month of June 2015, Goldman Sachs international (\"GSI\") failed to submit certain single name end of day prices and certain index prices in accordance with ICC rules and procedures, in alleged violation of ICC rule 404(b).","res":"Consent","sm":"Icc made a summary assessment against gsi in the amount of $127,000, which amount was direct debited in an icc monthly clearing fee invoice.","ab":"Goldman Sachs","firms":[361],"id":1985},{"d":"2015-07-14","di":"2015-07-10","dr":"2015-07-14","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250000.0,"dk":"2015-0033","al":"LPL consented to the findings that it did not establish, maintain, or enforce adequate procedures to review senior-specific titles for compliance with the commonwealth's senior designations regulations adopted June 1, 2007. As a result, LPL allowed its broker-dealer agents and investment adviser representatives to use prohibited senior-specific designations.","res":"Order","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":1986},{"d":"2015-07-13","di":"2015-07-13","dr":"2015-07-13","k":"Regulatory Action","rg":"State regulator","reg":"South Carolina Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"FILE NO. 14027","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the South Carolina Securities Division (the \"division\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in South Carolina, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in South Carolina. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual states may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the division alleged that the acceptance of client orders in South Carolina through sales assistants that were highly likely not registered in South Carolina, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in South Carolina constituted bases for the assessment of an administrative fine pursuant to S.C. Code ann. § 35­ 1-604(d). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the division a sum in the amount of $35,000, South Carolina's allocated portion of the amount agreed to with nasaa. Finally, the division and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1987},{"d":"2015-07-10","di":"2015-07-10","dr":"2015-07-10","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":35000.0,"dk":"CASE NO. S-15-0016","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Arkansas Securities Department (the \"department\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Arkansas, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Arkansas. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual states may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the department alleged that the acceptance of client orders in Arkansas through sales assistants that were highly likely not registered in Arkansas, the failure to monitor the registration status of these sales assistants and the failure to enforce supervisory procedures to ensure that these persons were registered in Arkansas constituted bases for the assessment of an administrative fine pursuant to ark. Code ann. § 23­42­308(g). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the department a sum in the amount of $35,000, Arkansas's allocated portion of the amount agreed to with nasaa. Finally, the department and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":1988},{"d":"2015-07-06","di":"2015-07-06","dr":"2015-07-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","dk":"2014042689901","al":"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 these 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 eligible customers who purchased mutual fund shares received the benefit of applicable sales charge waivers. The firm failed to adopt adequate controls to detect instances in which they did not provide sales charge waivers to customers in connection with their mutual fund purchases.","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC; Raymond James & Associates, Inc.; Wells Fargo Advisors Financial Network, LLC; Wells Fargo Clearing Services, LLC","self":true,"firms":[705,6413,11025,19616],"id":1989},{"d":"2015-06-30","di":"2015-06-30","dr":"2015-06-30","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure","st":"Final","fine":7000000.0,"dk":"3-16665","al":"The U.S. Securities and Exchange Commission (the \"SEC\") has alleged that Goldman, Sachs & co. (the \"firm\") did not have a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of market access in relation to its listed equity options business, which contributed to the entry of erroneous electronic options orders on multiple options exchanges on August 20, 2013. The SEC alleged that the firm willfully violated section 15(c) (3) of the Exchange Act and rule 15C3-5 thereunder in relation to its controls and supervisory procedures addressing (I) the entry of orders that exceed appropriate pre-set credit or capital thresholds; (II) the entry of erroneous orders that exceed appropriate price or size parameters or that indicate duplicative orders; and (III) the management of software changes that impact order flow.","res":"Order","sm":"Without admitting or denying the violations, the firm consented to the entry of an order instituting administrative and cease- and-desist proceedings, pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease-and-desist order on June 30, 2015 by the SEC pursuant to which the firm: (I) shall cease and desist from committing or causing any violations and any future violations of section 15(c)(3) of the Exchange Act and rule 15C3-5 thereunder; (II) is censured; and (III) paid a total civil money penalty of $7 million on June 30, 2015.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1990},{"d":"2015-06-29","di":"2015-06-29","dr":"2015-06-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Delaware","san":"Cease and Desist","os":"Administrative consent order and monetary fine","st":"Final","fine":105000.0,"dk":"11-2-4","al":"It was alleged that former financial advisor, who left the firm on November 7, 2008, recommended certain unsuitable transactions and that block was not reasonably supervised.","res":"Order","sd":"The firm agreed to pay an administrative fine of $75,000, $30,000 toward the cost of the state's investigation and refrain from any future violations.","sm":"The State of Delaware, office of investor protection, and Janney Montgomery Scott LLC entered into an administrative consent order, which was adopted by the office through a final order dated June 10, 2015 and received by the firm on June 29, 2015. The firm consented to findings that one of its financial advisors, who left the firm on November 7, 2008, recommended certain unsuitable transactions and that financial advisor was not reasonably supervised. The firm agreed to pay an administrative fine of $75,000, $30,000 toward the cost of the state's investigation and refrain from any future violations.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":1991},{"d":"2015-06-29","di":"2015-06-29","dr":"2015-06-29","k":"Regulatory Action","rg":"OCC","reg":"Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; remedial actions","st":"Final","fine":1104530.0,"dk":"AA-EC-2015-18 AND AA-EC-2015-19","al":"On June 29, 2015, the Comptroller of the Currency (\"OCC\") issued a consent order and a consent order for a civil money penalty (together, the \"orders\") against Bank of America, N.A. (\"BANA\") relating to the BANA's practices that resulted in violations of the national flood insurance act of 1968, as amended, and the flood disaster protection act of 1973, as amended (collectively, \"fdpa\"), 42 U.S.C. § 4001, et seq., and their implementing regulations. Specifically, the OCC found that, since at least 2011, BANA violated 42 U.S.C. § 4012a(e) (placement of flood insurance by lender) and 12 C.F.R. §§ 22.3 (requirement to purchase flood insurance where available) and 22.9 (notice of special flood hazards and availability of federal disaster relief assistance) in making, increasing, extending, renewing, and/or servicing \"designated loans\" (loans secured by buildings or mobile homes located in special flood hazard areas in which flood insurance is available under the national flood insurance act of 1968). The OCC found that these violations resulted from deficient policies, procedures, and processes and an ineffective fdpa compliance program.","res":"Settled","sm":"In settlement of this matter, bana consented and agreed to the issuance of the orders, which the OCC has determined to accept and has issued. Bana neither admits nor denies the findings in the orders. The allegations, dispositions, findings and sanctions of the orders are described above in items 7 and 12.","ab":"Bank of America, NA","firms":[142558],"id":1992},{"d":"2015-06-23","di":"2015-06-23","dr":"2015-06-23","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx BX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":315000.0,"dk":"2011027729903","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that when trading on the boston options exchange (BOX) as a facility of the Nasdaq Omx BX, Inc. ceased, the firm executed numerous transactions with incorrect origin codes across multiple markets, including the Nasdaq Omx BX, Inc. the firm's execution of orders with incorrect origin codes resulted from certain accounts having been on-boarded with incorrect origin codes in their respective account profiles, limitations in its order management system that failed to include all potential origin code designations or defaulted to an improper origin code at various points during the review period, and from errors made by the firm's employees when placing origin codes on orders at the point of order acceptance, entry, or execution. The findings stated that despite the fact that the firm traded millions of contracts by executing orders with incorrect origin codes, the firm lacked procedures for ensuring orders had been entered with correct origin codes, and for conducting reviews to detect that orders had been entered and executed with incorrect origin codes. Instead, the firm only learned about misrepresented orders in isolation and then addressed each instance in isolation and on an ad hoc basis. The findings also stated that despite the knowledge that the firm had of the use of incorrect origin codes, the firm did not take measures to ensure that it executed orders with correct origin codes, or to detect instances in which it had executed orders with incorrect origin codes. The findings also included that although the firm began taking steps to address the execution of orders with incorrect origin codes after conducting a review that led to the creation and implementation of exception reports to identify instances in which it had executed orders with incorrect origin codes, it still continued trading hundreds of thousands of contracts each year with incorrect origin codes, when trading on BOX as a facility of the Nasdaq Omx BX, Inc. ceased. FINRA found that each instance in which the firm executed an order with an incorrect origin code could have had adverse consequences, such as creating inaccurate order records, creating an inaccurate audit trail, reporting trades to the options clearing corporation (OCC) with inaccurate trade details, and adversely impacting the Nasdaq Omx BX, Inc.'s ability to surveil for and detect potential violations of its rules and federal securities laws. FINRA also found that the firm failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the Nasdaq Omx BX, Inc.'s origin code requirements.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, jointly and severally fined $9,000,000, of which $315,000 shall be paid to the Nasdaq Omx BX, Inc., and undertakes to, at intervals of 90, 180, 270, and 360 days after acceptance of this AWC, make a written submission to the Nasdaq Omx BX, Inc., in care of FINRA, regarding its compliance with the Nasdaq Omx BX, Inc.'s rules and policies governing the inclusion of account origin codes in order and execution data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1993},{"d":"2015-06-23","di":"2015-06-23","dr":"2015-06-23","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure;undertaking","st":"Final","fine":9000000.0,"dk":"2011027729904","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm executed numerous transactions with incorrect origin codes across multiple markets, including the Nasdaq options market, LLC (NOM). The firm's execution of orders with incorrect origin codes resulted from certain accounts having been on-boarded with incorrect origin codes in their respective account profiles, limitations in its order management system that failed to include all potential origin code designations or defaulted to an improper origin code at various points during the review period, and from errors made by the firm's employees when placing origin codes on orders at the point of order acceptance, entry, or execution. The findings stated that despite the fact that the firm traded millions of contracts by executing orders with incorrect origin codes, the firm lacked procedures for ensuring orders had been entered with correct origin codes, and for conducting reviews to detect that orders had been entered and executed with incorrect origin codes. Instead, the firm only learned about misrepresented orders in isolation and then addressed each instance in isolation and on an ad hoc basis. The findings also stated that despite the knowledge that the firm had of the use of incorrect origin codes, the firm did not take measures to ensure that it executed orders with correct origin codes, or to detect instances in which it had executed orders with incorrect origin codes. The findings also included that although the firm began taking steps to address the execution of orders with incorrect origin codes after conducting a review that led to the creation and implementation of exception reports to identify instances in which it had executed orders with incorrect origin codes, it still continued trading hundreds of thousands of contracts each year with incorrect origin codes. FINRA found that each instance in which the firm executed an order with an incorrect origin code could have had adverse consequences, such as creating inaccurate order records, creating an inaccurate audit trail, reporting trades to the options clearing corporation (OCC) with inaccurate trade details, and adversely impacting NOM's ability to surveil for and detect potential violations of its rules and federal securities laws. FINRA also found that the firm failed to have supervisory systems and controls in place, including a separate system of follow- up and review, reasonably designed to achieve compliance with NOM's origin code requirements.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, jointly and severally fined $9,000,000, of which $225,000 shall be paid to nom, and undertakes to, at intervals of 90, 180, 270, and 360 days after acceptance of this AWC, make a written submission to nom in care of FINRA, regarding its compliance with nom's rules and policies governing the inclusion of account origin codes in order and execution data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1994},{"d":"2015-06-23","dr":"2015-06-23","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":9000000.0,"dk":"15-0052","al":"Without admitting or denying that a violation of exchange rules has been committed, the firm consented to the following stipulation of facts and findings and sanctions: from on or about January 2004 through on or about February 2014, the firm violated certain federal securities laws and certain CBOE rules by improperly marking numerous options orders on behalf of broker-dealers with incorrect option origin codes that were thereafter sent to the exchange through various order entry systems employed by the firm to send options orders, resulting in (I) transactions executed by the firm that may have traded adhead of other orders entitled to execution priority; (II) potential adverse impact to the execution price and/or contract quality of other market participants' orders; (III) an inaccurate exchange audit trail and inaccurate books and records; (IV) trades being report to the options clearing corporation with inaccurate trade details; and (v) an adverse impact to the exchange's ability to surveil for and detect potential violations of its rules and of federal securities laws. In addition, the staff concluded that the firm had supervisory deficiencies related to the improper marking, execution and clearance of incorrect order origin codes.","res":"Consent","sm":"The firm was censured, fined $9,000,000, of which $4,500,000 shall be paid to the CBOE, and undertakes to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1995},{"d":"2015-06-22","di":"2015-05-27","dr":"2015-06-22","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":868000.0,"dk":"2011027729902","al":"A FINRA hearing officer considered a stipulation of facts and consent to penalty entered into between FINRA on behalf of NYSE regulation, inc. and the firm. Without admitting or denying any allegations or findings, the firm stipulated to the facts and findings that the firm violated exchange rules 16, 153, 324, 955(c)(1), 956NY(a)(8), 957NY(e), 963NY(a) and (b), and 964NY(b)(2)(a), as well as section 17(a)(1) of the Securities Exchange Act of 1934 and SEC rule 17A-3(a)(6)(I) thereunder by misrepresenting options orders executed on the exchange with inaccurate account origin codes. Respondent also violated exchange rule 320 by failing to reasonably supervise and implement adequate controls, including separate systems of follow-up and review, reasonably designed to achieve compliance with the exchange's rules and policies governing the use of account origin codes. During the review the firm violated certain NYSE MKT rules and federal securities laws when entering and executing certain orders on behalf of their broker-dealer clients. The firm improperly marked numerous options orders with incorrect origin codes and sent those orders to the exchange through various order entry systems employed by the firm to send options orders, resulting in the following: transactions executed by the firm that may have traded ahead of other orders entitled to execution priority; potential adverse impact to the execution price and quantity of other market participants' orders; an inaccurate audit trail and inaccurate order records; trades being reported to the options clearing corporation (\"OCC\") with inaccurate trade details; and an adverse impact to the exchange's ability to surveil for and detect potential violations of its rules and of federal securities laws. Additionally, it was concluded that the firm had supervisory deficiencies related to these matters.","res":"Stipulation and Consent","sm":"Hearing officer decision rendered May 27, 2015; therefore the firm is censured and fined jointly and severally fined $868,000. In addition, the firm shall undertake at intervals of 90, 180, 270, and 360 days after the date of this decision to make a written submission to NYSE regulation, inc., in care of FINRA, regarding its compliance with the exchange's rules and policies governing the inclusion of account origin codes in order and execution data. The firm violated exchange rules 16, 153, 324, 955(c)(1), 956NY(a)(8), 957NY(e), 963NY(a) and (b), and 964NY(b)(2)(a), as well as section 17(a)(1) of the Securities Exchange Act of 1934 and SEC rule 17A-3(a)(6)(I) thereunder by misrepresenting options orders executed on the exchange with inaccurate account origin codes. Respondent also violated exchange rule 320 by failing to reasonably supervise and implement adequate controls, including separate systems of follow-up and review, reasonably designed to achieve compliance with the exchange's rules and policies governing the use of account origin codes. The decision became final at the close of business on June 22, 2015. This proceeding includes proceeding number 20110277298.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1996},{"d":"2015-06-18","di":"2015-06-18","dr":"2015-06-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":500000.0,"dk":"3-16619","al":"The U.S. Securities and Exchange Commission (the \"SEC\") has alleged that Goldman, Sachs & co. (the \"firm\") 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 SEC alleged that the firm willfully violated section 17(a)(2) of the Securities Act of 1933. The violations discussed in the order were self-reported by the firm to the SEC pursuant to the division of enforcement's municipalities continuing disclosure cooperation initiative.","res":"Order","sm":"Without admitting or denying the violations, the firm consented to the entry of an 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 on June 18, 2015 by the SEC pursuant to which the firm: (I) shall cease and desist from committing or causing any violations and any future violations of section 17(a)(2) of the Securities Act of 1933; (II) paid a civil money penalty in the amount of $500,000 on June 25, 2015; and (III) shall comply with the undertakings enumerated in the order.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":1997},{"d":"2015-06-18","di":"2015-06-18","dr":"2015-06-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil monetary penalty","st":"Final","fine":500000.0,"dk":"3-16638","al":"SEC admin releases 33-9845; 34-75239, 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 Stifel, Nicolaus & Company, inc. (\"respondent\"). Respondent 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 respondent's underwriting of certain municipal securities offerings. Respondent, 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 respondent offering and selling municipal securities on the basis of materially misleading disclosure documents. The violations were self-reported by respondent to the commission pursuant to the division of enforcement's (the \"division\") municipalities continuing disclosure cooperation (MCDC) initiative.","res":"Order","sm":"Stifel voluntarily participated in the MCDC initiative and is one of 36 firms that entered into a settlement with the SEC. FINRA has established a streamlined process to permit the settling firms to seek a waiver of the statutory disqualification resulting from the settlement. Stifel has submitted an MC-400-A application pursuant to the FINRA streamlined process, in order to obtain a waiver of the statutory disqualification, which it anticipates receiving","ab":"Stifel, Nicolaus & Company, Incorporated","self":true,"firms":[793],"id":1998},{"d":"2015-06-18","di":"2015-06-18","dr":"2015-06-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist;undertaking","st":"Final","fine":500000.0,"dk":"3-16626","al":"SEC admin releases 33-9833; 34-75227, 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 Merrill Lynch, Pierce, Fenner & Smith, incorporated (\"respondent\"). Respondent willfully violated section 17(a)(2) of the Securities Act. Respondent, 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 the assertions by these issuers and/or obligors regarding their compliance with previous continuing disclosure undertakings pursuant to rule 15C2-12. This resulted in respondent offering and selling municipal securities on the basis of materially misleading disclosure documents. The violations were self-reported by respondent to the commission pursuant to the division of enforcement's (the \"division\") municipalities continuing disclosure cooperation (MCDC) initiative.","res":"Order","sm":"In anticipation of the institution of these proceedings, respondent 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 it and the subject matter of these proceedings, which are admitted, respondent consents to 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 respondent's offer. Accordingly, it is hereby ordered that respondent 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 respondent's policies and procedures as they relate to municipal securities underwriting due diligence.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":1999},{"d":"2015-06-18","di":"2015-06-18","dr":"2015-06-18","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Monetary penalty","st":"Final","fine":500000.0,"dk":"3-16632","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2000},{"d":"2015-06-17","di":"2015-06-17","dr":"2015-06-17","k":"Regulatory Action","rg":"Other","reg":"Capital Market Authority of the Kingdom of Saudi Arabia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2666.35,"dk":"161/4/2015","al":"In a letter dated June 17, 2015 to Goldman Sachs Saudi arabia (\"GSSA\") from the kingdom of saudi arabia capital market authority (the \"cma\"), the cma informed GSSA of a cma decision alleging that GSSA was late in notifying the cma of the resignation of GSSA's chief executive officer, in alleged violation of article 15 paragraph a of the cma licensees regulations.","res":"Decision","sm":"Gssa agreed to the payment of a financial penalty to the cma in the amount of 10,000 saudi arabian riyals (SAR), which was paid by submission of a wire on July 5, 2015. The cma's decision stipulated the need for gssa to discuss the matter of the violation at the next meeting of the board of directors of gssa and to notify the cma of the board's response in this regard.","ab":"Goldman Sachs Saudi","firms":[361],"id":2001},{"d":"2015-06-11","di":"2015-06-11","dr":"2015-06-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":10000.0,"dk":"2014041621101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report information regarding purchase and sale transactions effected in municipal securities to the real-time transaction reporting system (RTRS). Specifically, in transactions with customers, the firm failed to include specific items of information listed for such transactions in the specifications for real-time reporting of municipal securities transactions, namely the correct time of execution in 46 customer transactions; the correct time, price, and commission in 33 customer transactions; and the correct price and commission in 1,032 customer transactions. The findings stated that the firm failed to show the correct time of execution on the memorandum of brokerage orders. The findings also stated that the firm failed to disclose the accurate dollar price of the trade and the dollar amount of the commission on customer confirmations for trades in municipal securities.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $10,000.","ab":"Advisors Asset Management, Inc.","self":true,"firms":[46727],"id":2002},{"d":"2015-06-09","di":"2015-06-09","dr":"2015-06-09","k":"Regulatory Action","rg":"Other","reg":"Bats Exchange, Inc. (\"Bats\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":200000.0,"dk":"20110277299","al":"On behalf of Bats, the staff of FINRA's market regulation department conducted a review of the firm's order entry activities in their capacity as an options member during the period between February 2010 through 2014 (the \"review period\") for compliance with Bats rules and policies governing the use of origin codes. During the review period, the firm violated certain Bats rules and federal securities laws when entering and executing certain orders on behalf of their broker-dealer clients. The firm improperly marked numerous options orders with incorrect origin codes and sent those orders to Bats through various order entry systems employed by the firm to send option orders, resulting in: (I) an inaccurate audit trail and inaccurate order records; (II) trades being reported to the options clearing corporation (\"OCC\") with inaccurate trade details; and (III) an adverse impact to Bats's ability to surveil for and detect potential violations of its rules and of federal securities laws. Additionally, the staff concluded that the firm had supervisory deficiencies related to these matters. As a result, the firm was found to have violated section 17(a)(1) of the Securities Exchange Act of 1934 and SEC rule 17A-3(a)(6)(I) promulgated thereunder, and Bats rules 5.1, 5.2, 18.1, 18.2(a)(2), 18.2(a)(6), 20.1(b)(4), 20.7(b)(17), and 24.1(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to a censure, a joint and several fine in the amount of $9,000,000, of which $200,000 shall be paid to Bats; and to an undertaking pursuant to which at intervals of 90, 180, 270, and 360 days after the acceptance of the AWC, the firm shall make a written submission to Bats, in care of FINRA, regarding its compliance with Bats's rules and policies governing the inclusion of accurate account origin codes in order and execution data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2003},{"d":"2015-06-08","di":"2015-05-28","dr":"2015-06-08","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx PHLX LLC (The \"Exchange\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":9000000.0,"dk":"20110277299","al":"On behalf of the exchange, the staff of FINRA's market regulation staff conducted a review of the firm's order entry activities in their capacity as a member organization during the period between 2004 and 2014 (the \"review period\") for compliance with various rules and federal securities laws. During the review period, the firm violated certain exchange rules and federal securities laws when entering certain orders on behalf of their broker-dealer clients. The firm improperly marked numerous options orders with incorrect origin codes and sent those orders to the exchange through various order entry systems employed by the firm to send option orders, resulting in the following: (I) transactions executed by the firm that may have traded ahead of other orders entitled to execution priority; (II) potential adverse impact to the execution price and quantity of other market participants' orders; (III) an inaccurate audit trail and inaccurate order records; (IV) trades being reported to the options clearing corporation (\"OCC\") with inaccurate trade details; and (v) an adverse impact to the exchange's ability to surveil for and detect potential violations of its rules and of federal securities laws. Additionally, the staff concluded that the firm had supervisory deficiencies related to these matters. As a result, the firm was found to have violated section 17(a)(1) of the Securities Exchange Act of 1934 and SEC rule 17A-3(a)(6)(I) promulgated thereunder, and PHLX rules 707, 748(b), (d), (g), later (h), 760, 785(c), 1014(g)(I)(a), 1053(IX), and 1063(e)(I).","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the allegations or conclusions, the firm consented to a censure, a joint and several fine in the amount of $9,000,000, of which $1,125,000 shall be paid to the exchange; and to an undertaking pursuant to which at intervals of 90, 180, 270, and 360 days after the decision on this offer becomes final, the firm shall make a written submission to the exchange, in care of FINRA, regarding its compliance with exchange rules and policies governing the inclusion of accurate account origin codes in order and execution data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2004},{"d":"2015-06-04","di":"2015-06-04","dr":"2015-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":10000.0,"dk":"2014041068801","al":"On June 4, 2015, FINRA alleged that Edward jones failed to capture the correct time of trade execution for transactions in trade reporting and compliance engine (TRACE)-eligible securitized products, failed to report to TRACE the correct time of trade execution for those transactions, and failed to show the correct time of execution on the memorandum of brokerage orders in violation of FINRA rule 6730(c)(8), rule 17A-3 under the Securities Exchange Act of 1934, and FINRA rules 2010 and 4511. On June 4, 2015, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent (AWC) with FINRA. Pursuant to the AWC, Edward jones was censured and ordered to pay a fine of $10,000. The fine was paid on June 18, 2015.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2005},{"d":"2015-06-03","di":"2015-06-03","dr":"2015-06-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":185000.0,"dk":"2013037909601","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) Goldman, Sachs & co. (\"GSCO\") failed to timely report to the trade reporting and compliance engine (\"TRACE\"), certain transactions in (a) TRACE-eligible corporate debt securities, during the period of April 1, 2013 through June 30, 2013 in alleged violation of FINRA rules 6730(a) and 2010; and (b) securitized products and agency debt securities, during the period of January 1, 2014 through March 31, 2014, each in alleged violation of FINRA rule 6730(a), and with regard to the TRACE-eligible securitized products, in alleged violation of FINRA rule 2010; and (II) GSCO's written supervisory procedures failed to provide for the minimum requirements for timely submission of accurate reports to TRACE, in alleged violation of FINRA rule 2010 and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure, fine and undertaking and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on June 3, 2015, and on July 9, 2015, the firm submitted a wire in payment of the fine in the amount of $185,000. In the undertaking, the firm consented to provide three reports, written and oral, to FINRA on dates that are no more than 3 months, 6 months, and 12 months after the date of the notice of acceptance of the AWC, regarding the effectiveness of the firm's written supervisory procedures with respect to timely submission of accurate reports to TRACE.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2006},{"d":"2015-06-03","di":"2015-05-20","dr":"2015-06-03","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange, LLC (\"Ise\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":1350000.0,"dk":"20110277299","al":"On behalf of the ise staff, FINRA staff members conducted a review of the firm's order entry activities in their capacity as electronic access members during the period between 2004 and 2014 (the \"review period\") for compliance with ise rules. During the review period, the firm violated certain ise rules and federal securities laws when entering and executing certain orders on behalf of their broker-dealer clients. The firm improperly marked numerous options orders with incorrect origin codes and sent those orders to ise through various order entry systems employed by the firm to send option orders, resulting in: (I) transactions executed by the firm that may have traded ahead of other orders entitled to execution priority; (II) potential adverse impact to the execution price and quantity of other market participants' orders; (III) an inaccurate audit trail and inaccurate order records; (IV) trades being reported to OCC with inaccurate trade details; and (v) an adverse impact to ise's ability to surveil for and detect potential violations of its rules and of federal securities laws. Additionally, the staff concluded that the firm had supervisory deficiencies related to these matters. As a result, the firm was found to have violated or caused violations of section 17(a)(1) of the Securities Exchange Act of 1934, as amended and Exchange Act rule 17A-3(a)(6)(I) promulgated thereunder, and ise rules 400, 401, 712(a), 713(c), and 1400(a).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure, a joint and several fine in the amount of $9,000,000, of which $1,350,000 shall be paid to ise; and to an undertaking pursuant to which at intervals of 90, 180, 270, and 360 days after the acceptance of the AWC, the firm shall make a written submission to ise, in care of FINRA, regarding its compliance with ise's rules and policies governing the inclusion of accurate account origin codes in order and execution data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2007},{"d":"2015-06-03","di":"2015-06-03","dr":"2015-06-03","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency","san":"Cease and Desist","os":"Civil money penalties and customer remediation","st":"Final","fine":4000000.0,"dk":"AA-EC-2015-06 AND AA-EC-2015-13","al":"The OCC alleged Wells Fargo Bank, N.A. engaged in unfair billing and deceptive marketing practices with regard to identity protection and debt cancellation products that resulted in violations of section 5 of the federal trade commission act.","res":"Stipulation and Consent","ab":"Wells Fargo Bank, N.A; Wells Fargo Bank, N.A.","firms":[11025,19616],"id":2008},{"d":"2015-06-01","di":"2015-06-01","dr":"2015-06-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement; cease and desist; censure; undertaking; prejudgment interest","st":"Final","fine":9000000.0,"dk":"3-16567","al":"On June 1, 2015, pursuant to SEC administrative release 34-75083 the Securities and Exchange Commission announced that public administrative and cease and desist proceedings were instituted against Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill Lynch\") and Merrill Lynch professional clearing corp. (\"MLPRO\") (collective, \"Merrill') for violations of rule 203(b) of Regulation SHO in connection with its practices related to its execution of short sales. The violations arose from two separate issues with respect to Merrill's use of its easy to borrow list (\"etb list\") in connection with the execution of short sale transactions. First, Merrill's execution platforms continued to accept short sales orders in reliance on the firm's etb list as the source of the locate after having learned of facts indicating that such reliance was no longer reasonable. As a consequence, Merrill's conducted violated rule 203(b) of reg sho in that Merrill lacked the requisite reasonable grounds to believe the affected securities could be borrowed for delivery on delivery date as required by the rule. In addition, by recording the etb list as the locate source in instances where Merrill had determined that such was no longer reasonable, Merrill failed to document an appropriate locate as required by the rule. Second, there were in certain instances in which Merrill utilized data that was more than 24 hours old to construct its etb list, which, at times, resulted in securities being included on the etb list when they otherwise should not have been. Merrill Lynch and MLPRO have consented to (a) cease and desist from committing or causing any violations and any future violations of rule 203(b) of Regulation SHO; (b) be censured; (c) pay disgorgement of $1.56 million plus prejudgment interest; (d) pay a civil monetary penalty of $9 million; and (e) comply with certain undertakings, including retaining an independent consultant within thirty (30) days of entry of the administrative order to conduct a review of their policies, procedures and practices with respect to their acceptance of short sale orders for execution in reliance on the firm's etb list and procedures to monitor compliance therewith to satisfy certain of its obligations under rule 203(b) of Regulation SHO.","res":"Order","sm":"In anticipation of the institution of these proceedings, respondent has submitted an offer of settlement (the \"offer\") which the commission has determined to accept. Merrill admits the findings, acknowledges that its conduct violated the federal securities laws, admits the commission's jurisdiction over it and the subject matter of these proceedings, and consents to the entry of this order instituting administrative and cease-and-desist proceedings pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease-and-desist order. Accordingly, it is hereby ordered that the respondent cease and desist from committing or causing any violations and any future violations of rule 203(b) of Regulation SHO and is censured. Respondent shall, within fifteen (15) days of the entry of this order, pay disgorgement, which represents profits gained as a result of the conduct, of $1,566,245.67 and prejudgment interest of $334,564.65 to the Securities and Exchange Commission. Respondent shall, within fifteen (15) days of the entry of this order, pay a civil money penalty in the amount of $9 million to the Securities and Exchange Commission. Respondent shall comply with the undertakings enumerated in the offer of settlement.","ab":"Merrill Lynch","firms":[7691],"id":2009},{"d":"2015-05-29","di":"2015-05-29","dr":"2015-05-29","k":"Regulatory Action","rg":"OCC","reg":"Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; remedial actions","st":"Final","fine":30000000.0,"dk":"AA-EC-2015-1 AND AA-EC-2015-2","al":"On May 29, 2015, the Comptroller of the Currency (\"OCC\") issued an order to cease and desist and order of assessment of a civil money penalty (together, the \"orders\") against bank of america, N.A. (\"BANA\") relating to the servicemembers civil relief act (\"SCRA\") and BANA's sworn document and collections litigation practices. In the orders, the OCC identified (I) unsafe or unsound practices in connection with BANA's efforts to comply with the SCRA, (II) SCRA violations, and (III) unsafe or unsound practices in connection with BANA's sworn document and collections litigation practices. Regarding the SCRA, the orders stated BANA failed to have effective policies and procedures to ensure compliance with SCRA; failed to devote sufficient financial, staffing, and managerial resources to ensure proper administration of its SCRA compliance processes; failed to devote to its SCRA compliance processes adequate internal controls, compliance risk management, internal audit, third party management, and training; and engaged in violations of the SCRA. Regarding the sworn document and collections litigation process, the orders stated that BANA filed or caused to be filed in courts affidavits executed by its employees or employees of third party service providers making assertions that, in many cases, were not based on personal knowledge or review of relevant books and records; filed or caused to be filed in court affidavits when BANA did not follow proper notary procedures; failed to devote sufficient financial, staffing, and managerial resources to ensure proper administration of its sworn document and collections litigation processes; and failed to sufficiently oversee outside counsel and other third-party providers handling sworn document and collections litigation services.","res":"Settled","sm":"In settlement of this matter, bana consented and agreed to the issuance of the orders, which the OCC has determined to accept and has issued. Bana neither admits nor denies the findings in the orders. The allegations, dispositions, findings and sanctions of the orders are described above in items 7 and 12.","ab":"Bank of America, National","firms":[142558],"id":2010},{"d":"2015-05-27","di":"2015-05-27","dr":"2015-05-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":300000.0,"dk":"2011027872601","al":"Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that it violated NYSE ARCA equities rule 6.18 by failing to establish and maintain a system of supervision that was reasonably designed to ensure full compliance with rule 105 by its customers. The findings stated as a result the firm's retail customers effected short sales during rule 105's restricted period and bought shares of the same securities from the firm in follow-on offerings. The firm failed to take reasonable steps to prevent or identify the transactions. The findings also stated that the firm violated ARCA equities rule 6.18 with respect to its institutional customers' compliance with rule 105 in that it relied on a third-party vendor that, in some instances, provided inaccurate data, which the firm used to calculate the restricted period for surveillance purposes.","res":"Decision & Order of Offer of Settlement","sm":"The firm was censured, fined $300,000, and undertakes to revise its written supervisory procedures and design reasonable surveillance systems with respect to preventing and detecting violations of rule 105 by retail customers.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2011},{"d":"2015-05-27","di":"2015-05-27","dr":"2015-05-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":417000.0,"dk":"2011027729901","al":"Without admitting or denying any allegations or findings, the hearing officer accepted the offer of settlement and consent and issued a decision. A FINRA hearing officer considered an offer of settlement and consent entered into between FINRA on behalf of NYSE regulation, inc. and the firm. The firm violated 17A-3(a)(6)(1) thereunder, and NYSE ARCA options rules 6.68(a)(8), 6.69, 11.1(b), 11.16(a), and 11.18(a) by failing to place the correct origin codes on orders. The firm also violated NYSE ARCA options rule 11.18 by failing to provide an adequate system of supervision, including written procedures and a system of follow-up and review, with respect to compliance with NYSE ARCA options rules and policies governing the use of account origin codes on orders. During the review period, the firm violated certain NYSE ARCA options rules and federal securities laws when entering and executing certain orders on behalf of its broker-dealer clients. The firm improperly marked numerous options orders with incorrect origin codes and sent those orders to the exchange through various order entry systems employed by the firm to send options orders, resulting in: transactions executed by the firm that may have traded ahead of other orders entitled to execution priority; potential adverse impact to the execution price and quantity of other market participants' orders; an inaccurate audit trail and inaccurate order records; trades being reported to the options clearing corporation (\"OCC\") with inaccurate trade details; and an adverse impact to the exchange's ability to surveil for and detect potential violations of its rules and of federal securities laws. Additionally, it was concluded that the firm had supervisory deficiencies related to these matters.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This matter is related to proceeding number 20110277298.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2012},{"d":"2015-05-26","di":"2015-05-26","dr":"2015-05-26","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"2015-042","al":"ICE Futures U.S., Inc. (\"IFUS\") compliance department issued a notice of summary fine, dated May 26, 2015, to Goldman, Sachs & co. (the \"firm\"), stating that the firm may have violated IFUS rule 4.07 on March 9, 2015 by failing to report a block trade in a timely manner.","res":"Decision","sm":"The summary fine, in the amount of $1,000, was paid by submission of a wire on June 9, 2015.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2013},{"d":"2015-05-20","di":"2015-05-08","dr":"2015-05-20","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2014-131","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was fined $5000 (paid on 6/2/15) - no amount was waived.","ab":"Raymond James & Associates, Inc.","self":true,"firms":[705],"id":2014},{"d":"2015-05-20","di":"2015-05-20","dr":"2015-05-20","k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":342000000.0,"dk":"15-008-B-HC","al":"On May 20, 2015, Citigroup Inc. (\"Citigroup\") consented to the issuance of an order to cease and desist and order of assessment of a civil money penalty (the \"order\") by the U.S. Board of Governors of the Federal Reserve system (\"FRB\"). Citigroup agreed to pay a penalty of $342 million and to further enhance the control framework governing Citigroup's foreign exchange (\"FX\") trading and related sales activities and certain other commodities and interest rate market activities. The order alleges that Citigroup lacked adequate firm-wide governance, risk management, compliance and audit policies and procedures relating to its FX activities. The order further alleges that Citigroup's deficient policies and procedures prevented it from detecting and addressing unsafe and unsound conduct by its FX traders, including agreements with external traders to coordinate trading in a manner designed to influence certain FX benchmark fixes and market prices and trading strategies that raised potential conflicts of interest.","res":"Consent","sm":"On May 20, 2015, Citigroup consented to the issuance of an order to cease and desist and order of assessment of a civil money penalty by the FRB. The order requires Citigroup to pay a civil money penalty of $342 million and to take specific steps to improve its oversight, internal controls, compliance, risk management and audit programs, including to submit within 90 days of the order, written plans and programs relating to remediation.","ab":"Citigroup Inc.","firms":[7059,119537],"id":2015},{"d":"2015-05-20","di":"2015-05-20","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist other remedial actions","st":"Final","fine":205000000.0,"dk":"15-010-B-HC, 15-010-CMP-HC","al":"On May 20, 2015, the Board of Governors of the Federal Reserve System (\"FRB\") issued an order to cease and desist and order of assessment of a civil money penalty against Bank of America corporation (\"BAC\") relating to its foreign exchange (\"FX\") activities (\"order\") from 2008 through 2013. The order states that (a) BAC lacked adequate firm-wide governance, risk management, compliance and audit policies and procedures to ensure that certain of the firm's FX activities complied with safe and sound banking practices, applicable U.S. laws and regulations, including policies and procedures to prevent potential violations of the U.S. commodities, antitrust and criminal fraud laws, and applicable internal policies; (b) BAC's deficient policies and procedures prevented BAC from detecting and addressing periodic conduct by Bank of America, N.A.'s traders relating to certain communications by these traders; and (c) as a result of deficient policies and procedures described above, BAC engaged in unsafe and unsound banking practices.","res":"Settled","sm":"[Continued from 12.c. Above] (f) bac shall not in the future directly or indirectly retain any individual as an officer, employee, agent, consultant, or contractor of bac or of any subsidiary who, based on the investigative record compiled by U.S. authorities, participated in the misconduct underlying the order, has been subject to formal disciplinary action as a result of bac's internal disciplinary review or performance review in connection with the conduct, and has either separated from bac or any subsidiary thereof or had his/her employment terminated in connection with the conduct. In settlement of this matter, bac consented and agreed to the issuance of the order, which the FRB has determined to accept and has issued. The allegations, dispositions, findings and sanctions of the order are described above in items 7 and 12.","ab":"Bank of America","firms":[7691,142558],"id":2016},{"d":"2015-05-15","di":"2015-05-15","dr":"2015-05-15","k":"Regulatory Action","rg":"Other","reg":"Delaware Investor Protection Unit","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":135000.0,"dk":"IPU CASE NO. 9-11-1","al":"In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (\"NASAA\"), the Delaware Investor Protection Unit (the \"unit\") alleged that Citigroup Global Markets Inc. (\"CGMI\") accepted client orders through sales assistants who were highly likely not registered in Delaware, and that CGMI failed to monitor the registration status of these sales assistants and to enforce its supervisory procedures to ensure that these persons were registered in Delaware. The alleged conduct constituted bases for the assessment of an administrative fine against the firm.","res":"Consent","sm":"This action is part of a global settlement regarding the activities of sales assistants and the supervision of sales assistants' registration status during the period January 1, 2007 through September 30, 2014 reached by cgmi with a multistate task force composed of members of nasaa. As part of the global settlement, individual states may enter consent orders, in which cgmi neither admits nor denies the allegations. In this instance, the unit alleged that the acceptance of client orders in Delaware through sales assistants that were highly likely not registered in Delaware, the failure to monitor the registration status of these sales assistants and the failure to enforce its supervisory procedures to ensure that these persons were registered in Delaware constituted bases for the assessment of an administrative fine pursuant to 6 del. C. § 601(b). Without admitting or denying the allegations, cgmi agreed to (1) certain undertakings, and (2) to pay the unit a sum in the amount of $135,000, of which $35,000 is an administrative fine and $100,000 is for the costs associated with the unit's investigation. Finally, the unit and cgmi agreed that the order would not subject cgmi to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":2017},{"d":"2015-05-15","di":"2011-09-02","dr":"2015-05-15","k":"Civil Judicial Action","st":"On appeal","al":"The federal housing finance agency (FHFA), as conservator for the federal national mortgage association (fannie mae) and the federal home loan mortgage corporation (freddie mac) filed a complaint against Nomura holding america inc., Nomura asset acceptance corporation, Nomura home equity loan, inc., Nomura credit & capital, inc., Nomura Securities international, inc., certain of their officers and an unaffiliated underwriter. The suit asserts claims pursuant to sections 11, 12, and 15 of the Securities Act of 1933, state securities law and state common law in connection with the sale of residential mortgage-backed securities to fannie mae and freddie mac. The suit alleges that the registration statements for such securities contained misstatements and omissions concerning the underlying mortgages.","ab":"Nomura Securities","firms":[7897],"id":2018},{"d":"2015-05-12","dr":"2015-05-12","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"2013036228501","al":"The firm violated NYSE ARCA equities rule 2.24 and SEC rule 17A-3, by failing to record on its trade blotters accurate execution times for 226 transactions in six separate securities.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm is censured and fined $7,500.","sm":"A FINRA hearing officer considered an offer of settlement and consent entered into between FINRA on behalf of NYSE regulation, inc. and the firm. Without admitting or denying any allegations or findings, the hearing officer accepted the offer of settlement and consent and issued a decision on May 12, 2015.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2019},{"d":"2015-05-11","dr":"2015-05-11","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"15-8395","al":"Alleged violation of rule 576 in that Citigroup Global Markets Inc. failed to maintain accurate and current registration in the exchange fee system as required during the review period of November 2014 through January 2015.","res":"Consent","sm":"Cgmi consented to a summary fine in the amount of $5,000","ab":"Citigroup Global Markets Inc.","self":true,"firms":[7059],"id":2020},{"d":"2015-05-06","di":"2015-05-06","dr":"2015-05-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":10000000.0,"dk":"2013035109701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to enforce its supervisory procedures for the sales of complex non-traditional exchange traded funds (ETFS), certain variable annuity contracts, non-traded real estate investment trusts (REITS) and other complex products, as well as its failure to monitor and report trades and deliver to customers more than 14 million trade confirmations. The findings stated that with regard to non-traditional ETFS, the firm did not have a system to monitor the length of time that customers held these securities in their accounts, did not enforce its limits on the concentration of those products in customer accounts, and failed to ensure that all of its registered representatives were adequately trained on the risks of the products. The findings also stated that the firm failed to supervise its sales of variable annuities, in some instances permitting sales without disclosing surrender fees, and in connection with certain mutual fund \"switch\" transactions, it used an automated surveillance system that excluded these trades from supervisory review. The firm also failed to supervise non-traded REITS by, among other things, failing to identify accounts eligible for volume sales charge discounts. FINRA found that the firm failed to implement adequate systems for the review and accurate reporting of trades and for the accurate delivery of trade confirmations. The firm failed to review low priced equity trades, concentrated positions, actively traded accounts, and potential front running by employees. The findings also stated that the firm failed to accurately report to the options clearing corporation (OCC) options data using the large options positions report (LOPR) and failed to report its correct capacity to the real-time transaction reporting system (RTRS) and to the trade reporting and compliance engine (TRACE). The findings also included that the firm further failed to establish and maintain supervisory procedures reasonably designed to ensure compliance with its reporting requirements for options, municipal securities, and TRACE eligible securities. FINRA found that the firm failed to deliver contemporaneous trade confirmations and failed to establish and maintain a supervisory system, reasonably designed to ensure delivery of contemporaneous trade confirmations. FINRA also found that the firm's anti-money laundering (AML) surveillance system failed to generate alerts for excessive atm withdrawals and atm withdrawals in foreign jurisdictions. In addition, FINRA determined that the firm failed to ensure it provided complete and accurate information to FINRA and to federal and state regulators concerning certain variable annuity transactions. Moreover, FINRA found that the firm failed to reasonably supervise its advertising and other communications, including its registered representatives' use of consolidated reports, the creation or use of consolidated reports, and failed to ensure that these reports reflected complete and accurate information. Furthermore, FINRA found that the firm failed to comply with certain registration requirements such as verifying prior employment of certain of its registered representatives and failing to timely file Form U4 amendments and forms U5. The findings also stated that the firm had a fail to deliver position at a registered clearing agency in an equity security resulting from a long sale trade and did not close-out the position by purchasing or borrowing securities of like kind and quantity within the time frame. The findings also","res":"Acceptance, Waiver & Consent(AWC)","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2021},{"d":"2015-05-06","di":"2015-05-06","dr":"2015-05-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":35000.0,"dk":"2012035222801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it accepted and held customer market orders, traded for its own account at prices that would have satisfied the customer market orders, and failed to immediately thereafter execute the customer market orders. The findings stated that the firm failed to show the correct time of execution on the memorandum of brokerage orders and failed to show the correct time of entry on the memorandum of brokerage orders. The findings also stated that the firm failed to report the correct time of execution to the OTC reporting facility (OTCRF) last sale reports of transactions in designated securities. The findings also included 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 FINRA rules, concerning OTC order protection. The firm's written supervisory procedures (WSPS) failed to provide for the minimum requirements for adequate WSPS concerning OTC order protection.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $35,000, and undertakes to revise its WSPS to address the deficiencies described in the AWC.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2022},{"d":"2015-05-05","di":"2015-05-05","dr":"2015-05-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":15000.0,"dk":"2013035825401","al":"Alleged non-adjustment of open limit orders, in a minimal number of instances and inadequate written supervisory procedures involving a limited number of trading rules.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$15,000 and undertakes to revise its WSPS.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2023},{"d":"2015-04-23","dr":"2015-04-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine and restitution","st":"Final","fine":1000000.0,"dk":"2010022918701","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2024},{"d":"2015-04-12","di":"2015-04-12","dr":"2015-04-12","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"105141/107480","al":"CBOE Futures Exchange, LLC (\"CFE\") alleged that Goldman, Sachs & co. failed to designate one CFE off exchange trade on an account statement as a block trade, and to provide an order ticket for another block trade, each in alleged violation of CFE rule 415(e).","res":"Consent","sm":"The cfe imposed a fine for minor rule violations in the amount of $2,500, which was paid by the submission of a wire on April 9, 2015.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2025},{"d":"2015-04-10","di":"2015-04-08","dr":"2015-04-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":17500.0,"dk":"2013036214001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to properly mark sell orders as long or short and, as a result, also failed to report the transactions in reportable securities to the FINRA trade reporting facility with the correct symbol indicating whether the transactions were long or short.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $17,500.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2026},{"d":"2015-03-23","di":"2014-01-14","dr":"2015-03-23","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist censure undertaking","st":"Final","fine":2500000.0,"dk":"E-2014-0002","al":"The consent order addresses allegations that Merrill lynch violated the Massachusetts uniform Securities Act and code of Massachusetts regulations resulting from its use of an unapproved internal presentation given to its financial advisors.","res":"Consent","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2027},{"d":"2015-03-18","di":"2015-03-18","dr":"2015-03-18","k":"Regulatory Action","rg":"Other","reg":"Anbima ­ AssociaÇÃO Brasileira Das Entidades Dos Mercados Financeiro E de Capitais","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6137.87,"al":"Anbima ­ AssociaÇÃO Brasileira Das Entidades Dos Mercados Financeiro E de Capitais (\"Anbima\") alleged that, certain brazilian financial institutions, including Goldman Sachs Do Brasil banco mÚltiplo S.A. (\"Offering coordinators\") acting in a public offering (the \"offering\") of equity securities of the brazilian issuer oi S.A. (The \"issuer\"), failed to appropriately disclose certain relationships in the offering materials associated with certain offering coordinators being creditors and security holders of the issuer who used part of the proceeds from the offering to amortize such loans (partially or totally), in alleged contravention of article 10 of the Anbima code of regulation and best practices to public offerings (cÓdigo Anbima de regulaÇÃo e melhores PRÁticas para ofertas pÚblicas de distribuiÇÃo e aquisiÇÃo de valores mobiliÁrios, \"Anbima's code\").","res":"Settled","sm":"Anbima and the offering coordinators entered into a settlement agreement on March 18, 2015, in which the offering coordinators agreed to prepare an educational material and schedule internal workshops to be presented by representatives from Anbima to the investment banking team of each offering coordinator on the rules of Anbima's code. In addition, the offering coordinators agreed to a financial payment to Anbima, Goldman Sachs Do Brasil banco mÚltiplo S.A.'S portion of which was BRL$18,894.83, which amount will be paid by Goldman Sachs Do Brasil banco mÚltiplo S.A. Upon receipt of an invoice.","ab":"Goldman Sachs Do Brasil","firms":[361],"id":2028},{"d":"2015-03-18","di":"2015-03-18","dr":"2015-03-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":48580.17,"dk":"2014-0094","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2029},{"d":"2015-03-03","di":"2015-03-03","dr":"2015-03-03","k":"Regulatory Action","rg":"Other","reg":"Intercontinental Exchange Futures U.S. (\"Ifus\")","san":"Cease and Desist","st":"Final","fine":650000.0,"dk":"2011-054","al":"Ifus alleges that Deutsche bank AG may have violated exchange rule 4.06(b) (v) by not maintaining confirmation statements to substantiate the related physical trade in currency exchange for physical transactions in numerous instances between September 2011 and December 2013.","res":"Settled","sm":"Without admitting or denying the allegations, dbag agreed to pay the fine of $650,000.00 which was paid on March 12, 2015. Dbag agreed to cease and desist from future violations of ifus rule 4.06(b) (v).","ab":"Deutsche Bank AG (\"Dbag\")","firms":[300838],"id":2030},{"d":"2015-03-02","di":"2015-03-02","dr":"2015-03-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":17500.0,"dk":"20120341461-01","al":"FINRA alleged the firm failed to show the correct time of entry and the terms and conditions on the memorandum of 50 brokerage orders during the review period in violation of SEC rule 17A-3 and FINRA rule 4511. Additionally, during the review period, the firm transmitted to OATS 50 reports that contained inaccurate, incomplete, or improperly formatted data. Specifically, the reports contained 50 inaccurate order receipt timestamps, 33 inaccurate account type codes, 33 inaccurate capacity codes, and 50 incomplete special handling codes in violation of FINRA rule 7450(a).","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm paid the required penalty of $17,500.","sm":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to show the correct time of entry and the terms and conditions on the memorandum of 50 brokerage orders and transmitted 50 reports that contained inaccurate, incomplete, or improperly formatted data to the order audit trail system (OATS). The firm has paid the required penalty ($17,500) and the processes in question have since been automated and the firms policies and procedures updated accordingly.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2031},{"d":"2015-02-26","di":"2015-02-26","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated Business Conduct Committee (The \"Committee\")","st":"Pending","dk":"STAR NO. 20150442656","al":"The committee has alleged that during the approximate period from in or about January 2009 through in or about May 2013, the firm, on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available, and, on numerous occasions, failed to use due diligence to execute orders at the best prices available in violation of exchange rules 6.45a, 6.45b and 6.73. In addition, during the approximate period from in or about January 2009 through in or about May 2013, the firm failed to assure compliance with said exchange rules which constitutes a violation of exchange rule 4.2.","sm":"Please remove this disclosure reporting page. This matter was settled and reported as part of occurrence 1919669.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2032},{"d":"2015-02-24","di":"2015-02-06","dr":"2015-02-24","k":"Regulatory Action","rg":"State regulator","reg":"State of California Department of Business Oversight","san":"Revocation","st":"Final","al":"Exempt status revoked due to failure to pay annual renewal fee to the state of California","res":"Other","sm":"Slow Ventures, LLC reapplied for its license by filing form ADV and paying the requisite fee(s) on February 24, 2015. No information Filed","ab":"Slow Ventures, LLC","self":true,"firms":[171144],"id":2033},{"d":"2015-02-17","di":"2015-02-17","dr":"2015-02-17","k":"Regulatory Action","rg":"State regulator","reg":"ComisiÓN Nacional Bancaria Y de Valores of the United Mexican States (Mexican National Banking and Securities Commission)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":17274.33,"dk":"211/21378/2015","al":"On February 17, 2015, the mexican national banking and securities commission notified Goldman Sachs MÉXico, casa de bolsa, S.A. De C.V. (\"GS mexico\") of its decision to impose an administrative penalty for the failure by GS mexico to timely file a quarterly report of U.S. dollar cash transactions effected during the first quarter of 2014 in accordance with section 35 of the new general guidelines to article 212 of the mexican securities market law (nuevas disposiciones de carÁcter general a que se refiere el artÍculo 212 de la ley del mercado de valores).","res":"Decision","sm":"The mexican national banking and securities commission imposed an administrative financial penalty on GS mexico in the amount of MXN$269,160, which amount was paid by submission of a wire on March 10, 2015.","ab":"Goldman Sachs MÉXico,","firms":[361],"id":2034},{"d":"2015-02-13","di":"2015-02-13","dr":"2015-02-13","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Department of Insurance","san":"Revocation","st":"Final","dk":"N/A","al":"On or about September 4, 2014, LPL entered into a consent agreement with the Ohio department of insurance regarding the reporting of various administrative actions on its license. Pursuant to the agreement, LPL was required to pay a civil penalty and administrative costs. LPL failed to comply with the order in paying the civil penalty and administrative costs.","res":"Order","sm":"LPL did not receive the invoice for the $1,000 civil penalty and administrative costs. When the firm became aware of the order of revocation, the monetary penalty was paid promptly and the firm's license was reinstated on February 27, 2015. On February 27, 2015, the Ohio department of insurance issued an order vacating the prior order of revocation entered on February 13, 2015.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2035},{"d":"2015-02-12","di":"2015-02-12","dr":"2015-02-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":115000.0,"dk":"2012031807001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that for settlement dates between September 15, 2010 and February 29, 2012, the firm failed to report 4,200 short interest positions totaling 22,850,177 shares, and on June 29, 2012, failed to report one position totaling 4,800 shares. The findings stated that for settlement dates between September 15, 2010 and February 29, 2012, the firm under-reported its short interest positions in that it inaccurately reported 7,065 short interest positions totaling 3,535,247,474 shares, when it should have reported 7,065 positions totaling 3,561,396,771 shares. The findings also stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with FINRA rule 4560.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $115,000. In determining to resolve this matter in the manner set forth herein, and in determining the appropriate monetary sanction, FINRA took into consideration that the firm self-reported the violations at issue after conducting an internal investigation, and promptly took action to correct the violative activity.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2036},{"d":"2015-02-11","di":"2015-02-11","dr":"2015-02-11","k":"Regulatory Action","rg":"Other","reg":"ICE Futures US, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2013-051","al":"ICE Futures US, Inc. (the \"exchange\") concluded that the firm violated exchange rule 27.12a by failing to provide electronic audit trail data corresponding to one (1) order that was entered into the exchange's electronic trade system in August 2013.","res":"Other","sm":"The firm was issued a summary fine in the amount of $5,000 pursuant to exchange disciplinary rule 21.02.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2037},{"d":"2015-02-11","di":"2015-02-11","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Market Commission (Greece)","st":"Pending","dk":"132/15.1.2015; 2317/19.6.2015","al":"Certain private investment fund entities referenced above in part I.a of this DRP (each such fund, an \"Elliott fund\") each separately received a letter from the Hellenic capital market commission (the \"HCMC\") regarding short-sale orders for a security placed on May 6, 2014. HCMC has alleged that, in its view, each Elliott fund violated an EU short-selling rule by placing the short- sale order on the day before the security was approved for trading, without adequately ensuring that the security would be available for settlement when due.","sm":"The HCMC requested the Elliott funds' views on the foregoing allegations before making any final determination. The Elliott funds each responded to the HCMC and contested the allegations. In particular, the Elliott funds stated that they did in fact ensure that the relevant security would be available for settlement when due in accordance with the relevant EU short-selling rule. Each Elliott fund did so by entering into a binding agreement, before effecting the short sale, to acquire the security to be delivered prior to the settlement date. In fact, in accordance with such agreement, the shares were acquired prior to the settlement date and were delivered to the buyer on the settlement date. These matters remain pending before the HCMC. On November 28, 2017, Elliott's counsel received an email from the HCMC stating that the HCMC decided to impose a fine of euro 64,500 on the liverpool limited partnership relating to the above-referenced activity. On February 21, 2018, Elliott's counsel received a substantially identical email from the HCMC imposing a fine of euro 116,500 on Elliott International, L.P. these decisions are not considered final and are subject to appeal.","ab":"Elliott International, L.P.","firms":[307151],"id":2038},{"d":"2015-02-05","di":"2015-02-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"2011028644501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that for approximately 13 months, it failed to send required regulatory disclosures and notices in connection with the opening of approximately 12,989 firm accounts, and for approximately 11 months, it failed to capture a customer's employer address information for approximately 345,789 accounts. The firm discovered that its platform failed to send welcome letter packages to customers as required, because the firm did not activate a mechanism on the platform to deliver the welcome letter packages to the accounts. As a result, for approximately 13 months, the firm did not send welcome letter packages with required privacy policy disclosures, policies on payment for order flow, affiliate marketing notices and business continuity plans to the 12,989 new accounts enrolled in college savings 529 accounts, education savings accounts or individual investor accounts. The findings also stated that for almost a year, the firm failed to collect employer addresses for 345,789 accounts of customers as required by FINRA rule 4512.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $100.000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2039},{"d":"2015-02-04","di":"2015-01-22","dr":"2015-02-04","k":"Civil Judicial Action","san":"Other","os":"Compliance plan to ensure compliance with the order and administration of payments to redress affected consumers.","st":"Final","fine":21000000.0,"al":"The complaint alleges from 2009 through 2013, genuine title, LLC provided Wells fargo loan officers marketing services that assisted the loan officers in generating business and increasing the number of loans Wells fargo originated or financed. The complaint alleges that under agreements or understanding between genuine title and the loan officers, the loan officers referred settlement service business to genuine title.","res":"Judgment Rendered","sd":"Restitution of $10,809,807.71 to be provided to affected consumers. Any funds remaining will be deposited in US Treasury as disgorgement.","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":2040},{"d":"2015-01-23","di":"2015-01-23","dr":"2015-01-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":75000.0,"dk":"2013037060701","al":"On January 23, 2015, FINRA alleged that Edward jones failed to establish, maintain, and enforce an adequate supervisory system, including a written supervisory control system, to prevent unauthorized transfers of client funds to third-party accounts in violation of NASD rules 3010, 3012(a)(2)(b)(I), and 2110 and FINRA rule 2010. On January 23, 2015, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent (AWC) with FINRA. Pursuant to the AWC, Edward jones was censured and ordered to pay a fine of $75,000. The fine was paid on February 3, 2015.","res":"Acceptance, Waiver & Consent(AWC)","sm":"See above.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2041},{"d":"2015-01-23","di":"2015-01-23","dr":"2015-01-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"2014-0458","al":"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.","res":"Consent","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2042},{"d":"2015-01-22","di":"2015-01-22","dr":"2015-01-22","k":"Regulatory Action","rg":"Other","reg":"United States of America Consumer Financial Protection Bureau","san":"Other","os":"Consent order with conduct provision and order distribution and acknowledgement.","st":"Final","dk":"2015-CFPB-0002","al":"The complaint alleges from 2009 through 2013, genuine title, LLC provided Wells fargo loan officers marketing services that assisted the loan officers in generating business and increasing the number of loans Wells fargo originated or financed. The complaint alleges that under agreements or understanding between genuine title and the loan officers, the loan officers referred settlement service business to genuine title.","res":"Consent","sm":"Wells Fargo Bank, N.A., neither admits or denies any allegations except to establish the bureau's jurisdiction over Wells fargo and the subject matter.","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":2043},{"d":"2015-01-15","di":"2015-01-15","dr":"2015-01-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":60000.0,"dk":"2012032011102","al":"On January 15, 2015, FINRA alleged that Edward jones failed to establish, maintain, and enforce an adequate supervisory system and written policies and procedures concerning the certification of customer signatures on certain documents in violation of NASD rules 3010(a) and (b), NASD rule 2110 (for the period before December 15, 2008) and FINRA rule 2010 (for the period on or after December 15, 2008). On January 15, 2015, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent (AWC) with FINRA. Pursuant to the AWC, Edward jones was censured and ordered to pay a fine of $60,000. The fine was paid on January 21, 2015.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2044},{"d":"2015-01-15","di":"2015-01-15","dr":"2015-01-15","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Customer remediation and restitution","st":"Final","fine":2000000.0,"dk":"NONE","al":"A former affiliate of Wells fargo bank, N.A. was alleged to have offered credit cards to New York state residents secured by residential real estate and originated residential mortgages in a manner inconsistent with New York law.","res":"Consent","ab":"Wells Fargo Bank, N.A. on","firms":[19616],"id":2045},{"d":"2015-01-13","di":"2015-01-13","dr":"2015-01-13","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":175000.0,"dk":"2013037137602","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to timely report written customer complaints against a representative. The findings stated that the firm received complaints alleging misappropriation of customer funds by the representative but failed to disclose the complaints within 30 days of becoming aware of them. The representative misappropriated over 1.7 million from firm customers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $175,000.00.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2046},{"d":"2014-12-29","di":"2014-12-29","dr":"2014-12-29","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Bureau of Securities Regulation (\"Bureau\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking; cost of investigation","st":"Final","fine":350000.0,"dk":"C-2013000010","al":"The bureau determined that, in violation of New Hampshire law, the firm's agents licensed in New Hampshire placed telemarketing calls to New Hampshire residents who were not clients of the firm at the time of the calls and whose numbers appeared on the firm's internal do not call list or on the FTC's national do not call registry. Further during the course of its investigation, the bureau determined that the firm did not reasonably supervise the telemarketing activities of its agents licensed in New Hampshire.","res":"Order","sm":"Without admitting or denying the facts or allegations, the firm consented to the entry of the consent order and consented to (I) cease and desist from further violations of N.H. Rsa 421-b, (II) pay the bureau's cost of investigation in the amount of $50,000, (III) pay an administrative fine of $350,000, and (IV) comply with all other undertakings and sanctions. Since the initiation of the bureau's investigation, the firm agreed to and completed enhancements and provided evidence to the bureau of the completed enhancements to its telemarketing policies and procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2047},{"d":"2014-12-29","di":"2014-12-29","dr":"2014-12-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":20000.0,"dk":"2011029293401","al":"Alleged effecting of a limited number of transactions during a trading halt.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $20,000.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2048},{"d":"2014-12-23","di":"2014-12-23","dr":"2014-12-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":18750.0,"dk":"2012031743301","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that during the period of August 2003 through December 2011, Goldman, Sachs & co. (the \"firm\") failed to: (I) have adequate procedures, including written supervisory procedures, reasonably designed to identify material changes in access and management of certain accounts that were granted an exemption from aggregating options positions by the intermarket surveillance group (ISG) in order to assure that proper notice was given to certain options exchanges (the \"exchanges\"); and (II) provide notice to the exchanges of any such changes, in alleged violation of NASD rules 3010 and 2110 (for conduct prior to December 15, 2008) and FINRA rule 2010 (for conduct on and after December 15, 2008).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on December 23, 2014, and on January 9, 2015, the firm submitted a wire in payment of a fine in the amount of $18,750.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2049},{"d":"2014-12-22","di":"2014-12-22","dr":"2014-12-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":5796000.0,"dk":"2012032249301","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it submitted inaccurate reports or failed to submit reports to the large option position reporting (LOPR) system in approximately 30,090,400 instances from January 2010 through November 2013. The firm's customers exceeded position limits for three securities for periods of time ranging from 11 to 98 consecutive days, and one customer exceeded position limits in a fourth security for 44 non-consecutive days. In addition, for its proprietary accounts, the firm exceeded a position limit in one security for 11 consecutive days and in a second security for 13 consecutive days. The findings further stated that the firm failed to establish adequate systems of supervision, including systems of follow up and review, that were reasonably designed to achieve compliance with the rules governing the reporting of positions to the LOPR system. The firm lacked sufficient written supervisory procedures requiring reviews to determine accurate and complete LOPR submissions. As a result, the firm failed to detect the above violations when they occurred. Instead, in most instances, the violations became known through the reviews conducted by FINRA.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Consideration has been given to the fact that the firm has already taken significant remedial action, including providing extraordinary cooperation with this investigation by retaining outside counsel to conduct a review and report its findings to FINRA periodically; enhancing its lopr reporting systems and written supervisory procedures; hiring an independent consultant to conduct a complete review of the firm's lopr systems and identify any additional or remaining deficiencies; and correcting the deficiencies identified by the independent consultant.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2050},{"d":"2014-12-22","di":"2014-12-22","dr":"2014-12-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx PHLX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":5796000.0,"dk":"2012032249304","al":"Without admitting or denying the allegations or conclusions, the firm consented to the sanctions and to the conclusion of violations of certain exchange rules. The findings state that, in violation of PHLX rule 1003(a), the firm submitted inaccurate reports or failed to submit reports to the large option position reporting (LOPR) system in approximately 30,090,400 instances from January 2010 through November 2013. The findings further stated that, from 2008 through 2013, the firm failed to establish adequate systems of supervision, including systems of follow up and review, that were reasonably designed to achieve compliance with the rules governing the reporting of positions to the LOPR system. From 2008 through 2013, the firm lacked sufficient written supervisory procedures requiring reviews to determine accurate and complete LOPR submissions. As a result, the firm failed to detect the above violations when they occurred. This conduct constitutes violations of PHLX rule 748(b), (d), (g), and rule 748(g)'s successor rule, rule 748(h).","res":"Decision","sm":"Consideration has been given to the fact that the firm has already taken significant remedial action, including providing extraordinary cooperation with this investigation by retaining outside counsel to conduct a review and report its findings to FINRA periodically; enhancing their lopr reporting systems and written supervisory procedures; hiring an independent consultant to conduct a complete review of the firm's lopr reporting systems and identify any additional or remaining deficiencies; and correcting the deficiencies identified by the independent consultant.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2051},{"d":"2014-12-22","di":"2014-12-22","dr":"2014-12-22","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx BX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":5796000.0,"dk":"2012032249302","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that, in violation of box trading rule chapter III, section 10, it submitted inaccurate reports or failed to submit reports to the large option position reporting (LOPR) system in approximately 30,090,400 instances from January 2010 through November 2013. The findings further stated that the firm failed to establish adequate systems of supervision, including systems of follow up and review, that were reasonably designed to achieve compliance with the rules governing the reporting of positions to the LOPR system. The firm lacked sufficient written supervisory procedures requiring reviews to determine accurate and complete LOPR submissions. As a result, the firm failed to detect the above violations when they occurred. Instead, in most instances, the violations became known through the reviews conducted by FINRA on behalf of Nasdaq Omx BX, Inc. for this reason, the firm violated chapter III, sections 1, 2(a), and 2(a)(I) of the box trading rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Consideration has been given to the fact that the firm has already taken significant remedial action, including providing extraordinary cooperation with this investigation by retaining outside counsel to conduct a review and report its findings to FINRA periodically; enhancing its lopr reporting systems and written supervisory procedures; hiring an independent consultant to conduct a complete review of the firm's lopr systems and identify any additional or remaining deficiencies; and correcting the deficiencies identified by the independent consultant.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2052},{"d":"2014-12-19","di":"2014-12-19","dr":"2014-12-19","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":142500.0,"dk":"2010023896602","al":"Alleged non-compliance with certain regulation NMS and Nasdaq rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $142,500 and undertakes to revise the its written supervisory procedures.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2053},{"d":"2014-12-18","di":"2014-12-18","dr":"2014-12-18","k":"Regulatory Action","rg":"Other","reg":"Box Options Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":5796000.0,"dk":"2014-004","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that from May 2012, when it became a member of box, through November 2013, the firm violated box rule 3150(a) by submitting inaccurate reports and failing to submit reports to the large option position reporting (LOPR) system. The findings state that the firm submitted inaccurate reports or failed to submit reports to the LOPR system in approximately 30,090,400 instances from January 2010 through November 2013. The findings also stated that from May 2012, when it became a member of box, through November 2013, the firm failed to establish adequate systems of supervision, including systems of follow up and review, that were reasonably designed to achieve compliance with box rule 3150(a) governing the reporting of positions to the LOPR system. The firm lacked sufficient written supervisory procedures requiring reviews to determine accurate and complete LOPR submissions. As a result, the firm failed to detect the above violations when they occurred. Instead, in most instances, the violations became known through the reviews conducted by the market regulation department. As a result, the firm violated box rules 3010 and 3070(a).","res":"Consent","sm":"In arriving at the sanctions, consideration has been given to the fact that the firm has already taken significant remedial action, including providing extraordinary cooperation with this investigation by retaining outside counsel to conduct a review and report its findings to FINRA periodically; enhancing its lopr reporting systems and written supervisory procedures; hiring an idependent consultant to conduct a complete review of the firm's lopr systems and identify any additional or remaining deficiencies; and correcting the deficiencies identified by the independent consultant.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2054},{"d":"2014-12-18","di":"2014-12-18","dr":"2014-12-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":1500000.0,"dk":"2012034123501","al":"FINRA has alleged potential violations of FINRA rules 3310 and 2010 and NASD rule 2110. Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that for several years the firm failed to comply fully with a key aspect of the anti-money laundering (\"AML\") compliance program requirements for broker-dealers. To satisfy those requirements, every broker-dealer must establish and maintain a customer identification program (\"CIP\") under which it verifies the identity of each customer opening a new account, and, during the relevant period, the firm's CIP was deficient, in that it did not subject certain new customers to identity verification. The findings stated that during the relevant period, when the firm's transaction- processing system, the beta system, assigned customer identifiers to new securities accounts, it sometimes recycled identifiers previously assigned to accounts that had been closed. When this happened, the CIP system recognized the identifiers and treated the new accounts as if they had already gone through the CIP system. Thus, even though the appurtenant customer information - such as customer name, address, tax-identification number, and date of birth - was different from the previous instance of identity verification, the CIP system did not subject the customers associated with these new accounts to identity verification. For that reason, the firm's CIP system did not verify the identities of new customers with recycled identifiers. This resulted in the firms' failure to conduct customer-identity verification for nearly 220,000 accounts during the relevant period. The findings also stated that of the accounts that were not subjected to identity verification, approximately 120,000 were already closed when the problem came to light. These accounts were never subjected to identity verification. The accounts that were still open when the firm discovered the design flaw were subsequently sent through the CIP process, with the firm eventually prohibiting further activity in 345 accounts for which identity verification could not be completed. In determining the appropriate sanctions, FINRA considered that the firm discovered the CIP-related violations through the firm's compliance risk analysis system (CRAS) test, investigated their causes and scope, performed remediation CIP on the approximately 100,000 affected accounts that remained open, made programming changes to the CIP system and to the firm's beta in an effort to prevent recurrences, and reported the violations to FINRA in accordance with rule 4530(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"In determining the appropriate sanctions, FINRA considered that the firm discovered the cip-related violations through the firm's compliance risk analysis system (CRAS) test, investigated their causes and scope, performed remediation cip on the approximately 100,000 affected accounts that remained open, made programming changes to the cip system and to the firm's beta in an effort to prevent recurrences, and reported the violations to FINRA in accordance with rule 4530(b).","ab":"Wells Fargo Advisors; Wells Fargo Advisors, LLC","firms":[11025,19616],"id":2055},{"d":"2014-12-18","di":"2014-07-15","dr":"2014-12-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","dk":"20100212725","al":"FINRA enforcement staff informed the firm that it had made a preliminary determination to recommend that disciplinary action be brought against the firm for violations of NASD rules 3011 and 2110 and FINRA rule 2010 for failing to implement policies and procedures reasonably designed to achieve compliance with the Bank Secrecy Act and its implementing regulations to detect and cause the reporting of suspicious activity. On 12-18-2014, FINRA enforcement staff notified the firm that it had determined that it will not recommend the commencement of a disciplinary action regarding this matter.","res":"Other","sm":"******Please remove this DRP.****** on 12-18-2014, FINRA enforcement staff notified the firm that it had determined that it will not recommend the commencement of a disciplinary action regarding this matter.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2056},{"d":"2014-12-18","di":"2012-04-02","dr":"2014-12-18","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Injunction","st":"Final","fine":35000000.0,"dk":"12-CV-2497 (AKH/KNF)","al":"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.","res":"Consent","ab":"Royal Bank of Canada","firms":[31194],"id":2057},{"d":"2014-12-16","di":"2014-12-16","dr":"2014-12-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, restitution, undertaking, interest","st":"Final","fine":1900000.0,"dk":"2010022691101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in 716 corporate bond transactions, the firm bought corporate bonds from customers and failed to buy such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each bond at the time of the transaction, the expense involved and that the firm was entitled to a profit. The findings stated that all 716 transactions at issue in this matter involved retail customers selling their senior notes issued by a company to the firm. The notes were de- listed from the New York Stock Exchange after a bankruptcy filing. After the de-listing, the notes were highly distressed and required to be executed manually at the firm. The firm's credit desk provided bids away from the prevailing market to the firm's service desks, which ultimately resulted in the firm purchasing the notes from retail customers at prices below the prevailing market price. Moreover, of the 716 transactions, 510 of these had markdowns in excess of 10 percent. The findings also stated that the firm did not have an adequate supervisory system in place to detect whether the firm's credit desk executed a retail customer transaction at a price consistent with the prevailing market price of that security. Specifically, the firm did not conduct fair pricing post-trade reviews of the transactions here, or fair pricing or best execution post-trade reviews of other retail customer trades executed on the credit desk. As a result, the firm's supervisory system during the review period was deficient. Moreover, the firm's written supervisory procedures (WSPS) were deficient, with respect to the transactions here and other retail customer trades executed on the credit desk, because they did not establish: the identification of the person responsible for supervision with respect to fair pricing and best execution reviews of retail customer transactions executed by the credit desk; a statement of the supervisory steps to be taken by the identified person; a statement as to how often such person should take such steps; and a statement as to how the completion of the steps included in the WSPS should be documented.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $1,900,000, ordered to pay restitution in the amount of $541,629.19, plus interest, and undertakes to provide three reports, written and oral, to FINRA on dates that are no more than six months, 12 months, and 18 months after the date of the notice of acceptance of this AWC, regarding the effectiveness of the firm's supervisory system with respect to the pricing of retail customer transactions executed by the credit desk.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2058},{"d":"2014-12-11","di":"2014-12-11","dr":"2014-12-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":4000000.0,"dk":"2011030683501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm violated provisions of NASD rule 2711, through its participation in a planned initial public offering (IPO). The findings stated that a company and its private equity owners (\"SPONSORS\") invited the firm to compete for a role in the company's planned IPO. The firm allowed its research analyst to participate in the firm's solicitation efforts by making a presentation to the company and its SPONSORS during the solicitation period. To win this investment banking business from the company the firm allowed its equity research analyst to participate in the firm's solicitation efforts. Therefore, in the context of the company's IPO, this was a conflict of interest by the research analyst as they were prohibited from participating in efforts to solicit investment banking business. Additionally, the firm complied with the company's request for a valuation that included the analyst's views. The findings also stated that to win this investment banking business from the company the firm offered favorable research coverage to the company. Under the circumstances of the IPO, the company offered favorable research coverage to induce receipt of investment banking business by submitting to the company, during the solicitation period, information related to a valuation template requested by the company and the SPONSORS. Therefore, in the context of the company's IPO this was a violation, which prohibits firm from directly or indirectly offering favorable research to obtain investment banking business. The firm understood that the company and the SPONSORS wanted a final valuation that the entire firm, including its analyst, would support if selected as an underwriter. Although the firm did not complete the actual template provided to the firm by the company, it provided the valuation information the company had requested. The cover email noted that the valuation range presented reflects the views across the firm's platform, and provides absolute clarity on the firm's perspective on value. The following day, an investment banker of the firm forwarded its response to one of the SPONSORS, noting that the response reflects a fully vetted firm view on valuation for the company. The investment bankers also understood that the company management and SPONSORS were looking at the analysts and their view of the potential transaction for purposes of distinguishing the firm from others competing for the role in the company's planned IPO. By providing the company the unified valuation it sought, the firm indicated to the company that post-IPO research coverage would be positive and aligned with investment banking. Shortly thereafter, the company and the SPONSORS selected the firm as an active book-runner for the company's IPO. The company, however, eventually decided not to proceed with the offering.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured and fined $4,000,000. The firm did not publish any equity research reports about the company during the period described in the settlement document, as the company decided not to proceed with the IPO.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2059},{"d":"2014-12-10","di":"2014-12-10","dr":"2014-12-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":5000000.0,"dk":"2011030683301","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of enforcement alleged that in connection with efforts by Goldman, Sachs & co. (the \"firm\") and other broker-dealers to participate in a company's planned initial public offering (IPO), the firm: (a) allowed a research analyst to participate in the solicitation of certain investment banking business; (b) offered favorable research coverage to induce the receipt of investment banking business; and (c) failed to adopt and implement policies and procedures reasonably designed to prevent violations of NASD rule 2711, in alleged violation of NASD rules 2711(c)(4), 2711(e), and 2711(I), respectively, and each in alleged violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on December 10, 2014, and on December 18, 2014, the firm submitted a wire in payment of a fine in the amount of $5,000,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2060},{"d":"2014-12-09","di":"2014-12-09","dr":"2014-12-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":67500.0,"dk":"2011026107603","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it transmitted reports to the order audit trail system (OATS) that contained inaccurate, incomplete, or improperly formatted data. The findings stated that the firm failed to provide written notifications disclosing to its customers that transactions were executed at average prices, that transaction details were available upon request, its capacity in the transactions, and/or that it charged commissions or commission equivalents. The firm failed to prepare accurate books and records. The firm failed to properly mark proprietary sell orders as long and failed to mark sale orders as short and as a result, the firm failed to report these transactions to various exchanges with the correct symbol indicating whether the transactions were long or short. The firm failed to report transactions in trade reporting and compliance engine (TRACE)-eligible securitized products to TRACE within 15 minutes of the time of execution. The findings also 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 FINRA rules. The firm's written supervisory procedures (WSPS) failed to provide for one or more of the four minimum requirements for adequate WSPS regarding accurately identify buy, short sale, and long sale information and clearly erroneous filings, and failed to provide evidence of supervisory review regarding accuracy of books and records. The findings also included that the firm allowed a registered representative to engage in proprietary trading and routing customers' orders for execution on behalf of the firm without being properly registered as a general securities representative and equity trader.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $67,500 and undertakes to revise its WSPS.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2061},{"d":"2014-12-04","di":"2014-12-04","dr":"2014-12-04","k":"Regulatory Action","rg":"Other","reg":"Edga Exchange, Inc.","st":"Final","fine":42500.0,"dk":"2010023896601","al":"Alleged non-compliance with certain regulation NMS and Edga rules regarding the definitional requirements of intermarket sweep orders and related supervision.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $42,500 and undertakes to revise the firm's written supervisory procedures.","sm":"Please see question 7.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2062},{"d":"2014-12-01","di":"2014-12-01","dr":"2014-12-01","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"14-0047","al":"The Chicago Board Options Exchange, Incorporated (\"CBOE\") alleged that, during the approximate period from in or about January 2009 through in or about February 2011, Goldman, Sachs & co. (the \"firm\") failed: (I) on certain occasions, to grant priority to the highest bid and/or lowest offer when such bid or offer was available, and to use due diligence to execute certain orders at the best prices available, in alleged violation of CBOE rules 6.45a, 6.45b and 6.73; and (II) to assure compliance with such rules, in alleged violation of CBOE rule 4.2.","res":"Consent","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of consent which was approved by the CBOE business conduct committee on December 1, 2014, and on December 9, 2014, the firm submitted a wire in payment of the fine in the amount of $20,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2063},{"d":"2014-12-01","di":"2014-12-01","dr":"2014-12-01","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":125000.0,"dk":"2012033090601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that during the period, the firm participated in the NYSE's supplemental liquidity provider (SLP) program. As a SLP, the firm provided liquidity in its assigned securities by electronically entering resting orders into the systems and facilities of the NYSE. The firm utilized numerous algorithms within its quantitative systemic arbitrage (QSA) desk to fulfill its obligations as a SLP. As of March 26, 2014, the firm discontinued its QSA desk trading operations and related NYSE SLP trading algorithms. However, during the relevant period, approximately 600,000 SLP orders the firm entered through its SLP algorithms resulted in executions on the NYSE against orders entered by other of the firm's proprietary algorithms. All QSA algorithmic trading strategies ran on the firm's algorithmic trading platform and were subject to a wash sale control procedure governed by price. Although the firm's SLP algorithms were designed to prevent the matching of buy and sell orders within a single algorithm, the firm had no systemic pre- trade block in place to prevent the entry of orders across different algorithms that could potentially interact. The firm's QSA trading supervision group utilized the wash sale crossing report, which was a t+1 report designed to capture instances where an individual algorithm is on both the buy side and sell side of a trade. In addition, at a point, the firm added the QSA system data to its preexisting contemporaneous transaction (wash sale) review, which was used by its equity surveillance group to identify scenarios in which a buy and sell transation in the same security occurred in the same customer or firm house account at the same price on the same trade date for possible prohibited trading strategy. During the period, the firm did not have a report to detect instances where two separate firm algorithms were on the buy side and sell side of a trade. As a result, the self-trade controls and reports were not capable of reasonably detecting and/or preventing SLP trades that resulted in no beneficial change of ownership. The conduct described herein constitutes a separate and distinct violation of NYSE rule 342.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm is censured and fined $125.000. This AWC case included other cases - nos. 20130354782, 20130382689, and 20130387807.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2064},{"d":"2014-12-01","dr":"2014-12-01","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange's (\"CBOE\") Business Conduct Committee","san":"Other","os":"N/a","st":"Final","dk":"FILE NO. 14-0144","al":"The CBOE business conduct committee alleged that during the approximate period from on or about March 8, 2010 to March 31,2010, Merrill Lynch, Pierce, Fenner & Smith Incorporated (the \"firm\") violated exchange rule 4.2 and reg sho rule 204(d) in that the firm unreasonably allocated the responsibility to close-out a portion of a fail-to-deliver position on numerous occasions to a broker-dealer customer when that customer had established a pattern of repeatedly failing to close-out previous allocations; violated exchange rule 4.2 and Regulation SHO rule 204(a) in that the firm failed to close out a fail-to-deliver position on numerous occasions within the required timeframe; and violated exchange rule 4.2 in that the firm failed to establish, maintain and enforce adequate policies and procedures for determining the reasonableness of fail to deliver position allocations to be made to broker dealer customers.","res":"Dismissed","sm":"The CBOE's business conduct committee issued a decision on December 1, 2014 dismissing charges relating to the alleged violations against the firm.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2065},{"d":"2014-12-01","di":"2014-10-02","dr":"2014-12-01","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"14-0143","al":"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.","res":"Settled","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2066},{"d":"2014-11-28","di":"2014-08-21","dr":"2014-11-28","k":"Regulatory Action","rg":"Other","reg":"Hellenic Capital Market Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":71000.0,"dk":"NO. F.092.22/3408","al":"HCMC alleged that MS failed to properly or timely report when MS holdings in certain companies increased or decreased by more than 3%, or exceeded or fell below 5%, 10% and 15% thresholds, as required by greek presidential decree PD 51/1992 and law 3556/2007.","res":"Decision","sm":"On August 21, 2014, Morgan Stanley (MS) was informed that the board of directors of the Hellenic Capital Market Commission (HCMC) issued a decision that commended a proceeding asserting that a) MS failed to properly or timely report when MS holdings in certain companies increased or decreased more by than 3%, or exceeded or fell below 5%, 10% and 15% thresholds, as required by greek presidential decree PD 51/1992 and law 3556/2007, and b) MS should be summarily fined 71,000 euros. MS did not challenge the summary decision and fine, which became final on November 28, 2014 when MS paid the summary fine.","ab":"Morgan Stanley","firms":[149777],"id":2067},{"d":"2014-11-25","di":"2014-07-16","dr":"2014-11-25","k":"Regulatory Action","rg":"Other","reg":"Bourse de MontrÉAl Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":61969.15,"dk":"12-011-DISC","al":"In an originating notice to Goldman, Sachs & co. (the \"firm\") dated June 18, 2013, the Bourse de MontrÉAl Inc. (the \"Bourse\") alleged that, during the period from December 1, 2005 to June 30, 2012, the firm provided certain personnel access to the electronic trading system of the Bourse without having obtained the prior approval of the Bourse, in alleged contravention of section a) of article 6366 of the rules of the Bourse.","res":"Decision","sm":"On November 25, 2014, the disciplinary committee of the Bourse (the \"committee\") informed the firm of the committee's approval of an offer of settlement (the \"offer of settlement\") negotiated between the staff of the regulatory division of the Bourse and the firm. The committee approved the offer of settlement on November 14, 2014. In the offer of settlement, the firm agreed to the payment of a fine in the amount of cad$65,000, as well as an additional amount of cad$6,500 for costs, which amount was paid by submission of a wire on December 18, 2014. As indicated in the committee's approval of the offer of settlement, upon learning of certain unapproved access to the electronic trading system of the Bourse, the firm took corrective measures, and the Bourse noted that the problem was corrected.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2068},{"d":"2014-11-25","di":"2013-08-06","dr":"2014-11-25","k":"Civil Judicial Action","san":"Injunction","os":"Disgorgement of $109,220,000, prejudgment interest of $6,620,000, and civil penalty of $109,220,000.","st":"Final","al":"SEC litigation release 22772, August 7, 2013: on August 6, 2013, the Securities and Exchange Commission (\"commission\") filed a civil injunctive action against Merrill Lynch, Pierce, Fenner & Smith, inc. f/k/a banc of america securities LLC (\"firm\") and other entities (collectively the \"entities\"). The commission alleges that the entities made material misrepresentations and omissions in connection with the sale of residential mortgage-backed securities. Specifically, the complaint alleges that the entities failed to disclose the disproportionate concentration of wholesale loans (72% by unpaid principal balance) underlying the residential mortgage-backed securities as compared to prior residential mortgage-backed securities offerings. The complaint also alleges that the entities failed to disclose known risks associated with the high concentration of wholesale loans in the residential mortgage-backed securities including higher likelihood that the loans would be subject to material underwriting errors, become severely delinquent, fail early in the life of the loan, or prepay. The complaint further alleges that the entities violated regulation s-k and subpart regulation ab of the Securities Act of 1933 (the \"Securities Act\") by failing to disclose the material characteristics of the pool of loans underlying the residential mortgage-backed securities. The complaint also alleges that the entities made material misrepresentations and omissions in its public filings and in the loan tapes it provided to investors and rating agencies that the loans in the residential mortgage-backed securities complied with underwriting standards when a material amount did not. Finally, the complaint alleges that the firm violated section 5(b)(1) of the Securities Act by failing to file with the commission certain loan tapes that it provided only to select investors. The commission's complaint, filed in the United States district court for the western district of North Carolina, charges the firm with violating the antifraud provisions of the federal securities laws. The complaint alleges that that the firm violated sections 17(a)(2) and 17(a)(3) of the Securities Act. The complaint also alleges that the firm violated section 5(b)(1) of the Securities Act. The complaint seeks against the firm a permanent injunction, disgorgement with prejudgment interest and civil monetary penalties pursuant section 20(d) of the Securities Act.","res":"Judgment Rendered","sd":"On November 25, 2014, the United States district court for the western district of North Carolina (\"district court\") entered a final JUDGMENT (\"JUDGMENT\") against the firm , Bank of America, N.A. (\"BANA\"), and banc of america mortgage securities, inc. (\"BOAMS\") (collectively, the \"respondents\") that enjoined respondents from violating, directly or indirectly, sections 17(a) (2) and (3) of the Securities Act of 1933 (\"Securities Act\"), and the firm and BOAMS from violating, directly or indirectly, section 5(b)(1) of the Securities Act. BANA was not named as a defendant in connection with the section 5(b)(1) claim and therefore did not consent to entry of an injunction under that section. Additionally, as stated in the SEC's press release, \" [a]s part of the [global RMBS settlement], Bank of America agreed to resolve the U.S. [Securities and Exchange Commission's (\"SEC\" or \"commission\")] original case by paying disgorgement of $109.22 million, prejudgment interest of $6.62 million, and a penalty of $109.22 million.\"","ab":"Bank of America, N.A.; Merrill Lynch, Pierce,","firms":[7691,142558],"id":2069},{"d":"2014-11-24","di":"2014-11-24","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; disgorgement","st":"Final","fine":20000.0,"dk":"2013-155","al":"ICE Futures U.S., Inc. (\"IFUS\") business conduct committee (\"BCC\") determined that J. Aron & Company (\"j. Aron\") may have, in one (1) instance, exceeded the spot month speculative position limit established by IFUS in an energy futures contract during contract expiration, in alleged violation of IFUS rule 6.20(b).","res":"Consent","sm":"Without admitting or denying any violation of ifus rules, j. Aron entered into a settlement agreement, which was approved by the BCC, in which j. Aron: (I) agreed to cease and desist from future violations of ifus rule 6.20(b); and (II) consented to a monetary payment of $82,064 in the aggregate, consisting of a fine in the amount of $20,000, and disgorgement of profits in the amount of $62,064, both of which were paid by submission of a wire on November 26, 2014.","ab":"J. Aron & Company","firms":[361],"id":2070},{"d":"2014-11-20","di":"2014-06-06","dr":"2014-11-20","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":2447043.38,"dk":"3-15913","al":"The SEC alleges the firm willfully violated section 15(c)(3) of the Exchange Act and rule 15C3-5 thereunder because it did not maintain exclusive control over risk management controls in sponsored access trading platforms; did not have a system of risk management controls and supervisory procedures that was reasonably designed to ensure compliance with all regulatory requirements, including those that must be satisfied on a pre-order entry basis; did not have controls and procedures reasonably designed to restrict access to market access trading systems to persons and accounts pre-approved and authorized by the firm; did not establish, document, and maintain a system for regularly reviewing the effectiveness of its risk management controls and supervisory procedures relating to market access; and did not conduct an adequate review of its market access controls and procedures. The firm willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder because it failed to file reports of suspicious trading activity in connection with is market access business. The firm willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder because it failed to preserve originals or copies of communications containing trading instructions relating to isos submitted by its customers under a firm MPID through third- party trading platforms. The firm willfully violated rule 203(b)(1) of Regulation SHO because it allowed sponsored access customers to submit short-sale orders for securities that were not easy to borrow without first otherwise locating shares to borrow. The firm willfully violated rule 611(c) of regulation NMS because it allowed sponsored access customers to submit isos without the firm taking reasonable steps to ensure that it satisfied the requirements for sending isos.","res":"Order","sd":"Ordered that: respondent Wedbush cease and desist from committing or causing any violations and any future violations, is censured and shall, within ten (10) days of the entry of this order, pay a civil money penalty in the amount of $2,447,043.38 to the Securities and Exchange Commission. Respondent Wedbush shall comply with the undertakings enumerated in the offer of settlement. In connection with the conduct described, Wedbush acted willfully.","sm":"It is further ordered that the administrative law judge shall issue an initial decision no later than 300 days from the date of service of this order. SEC admin release 34-73652, ia release 40-3971 / November 20, 2014: respondent Wedbush has submitted an offer of settlement that the commission has determined to accept. Respondent admits the facts and acknowledges that its conduct violated the federal securities laws, admits the commission's jurisdiction over it and the subject matter of these proceedings, and consents to the entry of this order making findings and imposing remedial sanctions and a cease-and-desist order pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 and section 203(e) of the Investment Advisers Act of 1940 as to Wedbush Securities Inc. in view of the foregoing, the commission deems it appropriate in the public interest to impose the sanctions agreed to in respondent Wedbush's offer. Accordingly, pursuant to sections 15(b) and 21c of the Exchange Act and section 203(e) of the Advisers Act, it is hereby ordered that: respondent Wedbush cease and desist from committing or causing any violations and any future violations of sections 15(c)(3) and 17(a) of the Exchange Act; rules 15C3-5, 17A-4, and 17A-8 thereunder; rule 203(b)(1) of Regulation SHO; and rule 611(c) of regulation NMS. Respondent Wedbush is censured. Respondent Wedbush shall, within ten (10) days of the entry of this order, pay a civil money penalty in the amount of $2,447,043.38 to the Securities and Exchange Commission. Respondent Wedbush shall comply with the undertakings enumerated in the offer of settlement.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2071},{"d":"2014-11-20","di":"2014-11-20","dr":"2014-11-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":12500.0,"dk":"2010022632402","al":"Alleged non-compliance with certain Regulation SHO rules in a limited number of instances. Fail to deliver positions were not closed within the time frame prescribed by the rule for two instances of sales marked long and two instances of sales that the seller was deemed to own.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $12,500.","sm":"Please see question 7.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2072},{"d":"2014-11-19","di":"2014-11-19","dr":"2014-11-19","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"2013-016/028","al":"ICE Futures U.S., Inc. (\"IFUS\") compliance department issued a notice of summary fine, dated November 19, 2014, to Goldman, Sachs & CO. (the \"firm\"), stating that: (I) on February 11, 2013 and March 11, 2013, the firm failed to enter certain crossing orders (\"CO\") for certain opposing orders submitted simultaneously by a common account manager on behalf of accounts with separate beneficial owners; and (II) specifically, on each date, the firm entered certain opposing orders without the use of IFUS CO functionality, resulting in certain futures spreads transacting against one another, in violation of IFUS rule 4.02(I)(2).","res":"Decision","sm":"The summary fine, in the amount of $15,000, was paid by submission of a wire on November 28, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2073},{"d":"2014-11-12","di":"2014-11-12","dr":"2014-11-12","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2014-404B-025","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of September, 2014, Goldman Sachs international (\"GSI\") failed to submit fifty-four (54) single name end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Decision","sm":"ICE made a summary assessment against gsi in the amount of $20,000, which was finalized by notice dated November 12, 2014. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on December 18, 2014.","ab":"Goldman Sachs","firms":[361],"id":2074},{"d":"2014-11-11","di":"2014-11-11","dr":"2014-11-11","k":"Regulatory Action","rg":"OCC","reg":"The Comptroller of the Currency of the United States of America","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Remedial sanctions","st":"Final","fine":250000000.0,"dk":"AA-EC-14-99","al":"On November 11, 2014, the office of The Comptroller of the Currency of the United States of America (\"OCC\") issued a consent order and a consent order for the assessment of a civil money penalty against bank of america, N.A. (\"bank of america\") related to its foreign exchange (FX) business (\"ORDERS\") from 2008 through 2013. The OCC found, and bank of america neither admitted nor denied, that bank of america had deficiencies in its internal controls and had engaged in unsafe or unsound banking practices with respect to the oversight and governance of bank of america's FX trading business such that the bank failed to detect and prevent certain conduct. Specifically, the OCC found that: a) bank of america's compliance risk assessment lacked sufficient granularity and failed to identify the risks related to sales, trading and supervisory employees in that business (\"EMPLOYEE\"); b) bank of america's transaction monitoring and communications surveillance lacked an adequate analysis of risk-behavior related to EMPLOYEE market conduct in its wholesale foreign exchange business where it is acting as principal (\"FX trading\"); c) bank of america's compliance testing procedures were inadequate to measure adherence to its standards of EMPLOYEE conduct and firm policies applicable to EMPLOYEE market conduct in FX trading; and d) bank of america's risk assessment and coverage of the FX trading business needed improvement to identify and mitigate compliance risks related to EMPLOYEE market conduct; e) bank of america's customer information controls were inadequate regarding the WM/reuters order book to prevent the misuse of customer information; f) bank of america's risk and profitability reporting was inadequate to identify potential EMPLOYEE market misconduct in FX trading; and g) bank of america's FX business supervision routines were inadequate because they created \"gaps\" in the EMPLOYEE market conduct supervisory framework.","res":"Settled","sm":"(Continued from 12.c. Above) g) submit an acceptable internal audit written plan for the internal audit program to adequately address employee market conduct in FX trading; and h) submit an acceptable other trading activities written plan to ensure that bank of america proactively uses a risk-based approach to apply employee market conduct remedial measures in the orders to other wholesale trading as principal for the bank of america and benchmark activities as appropriate and defined in the bank of america's written plan. [Item 13 summary] in settlement of this matter, bank of america consented and agreed to the issuance of the orders, which the OCC has determined to accept and has issued. The allegations, dispositions, findings and sanctions of the orders are described above in items 7 and 12.","ab":"Bank of America, National","firms":[142558],"id":2075},{"d":"2014-11-05","di":"2014-10-01","dr":"2014-11-05","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"CFE-14-0003","al":"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.","res":"Decision & Order of Offer of Settlement","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2076},{"d":"2014-11-03","di":"2014-11-02","dr":"2014-11-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":67200.0,"dk":"3-16240","al":"SEC admin release 34-73506 / November 3, 2014: 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 pursuant to sections 15(b), 15b(c)(2) and 21c of the Securities Exchange Act of 1934 against Wedbush Securities Inc. (\"Wedbush\" or \"respondent\"). In anticipation of the institution of these proceedings, respondent 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, respondent consents to the entry of this order instituting administrative and cease-and-desist proceedings pursuant to sections 15(b), 15b(c)(2) and 21c of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease-and-desist order. On the basis of this order and respondent's offer, the commission finds that: these proceedings involve the sale of non-investment grade or \"junk\" bonds issued by the commonwealth of Puerto Rico (\"Puerto Rico\") by Wedbush, a registered broker-dealer and municipal securities dealer, to customers in amounts below the minimum denomination of the issue. Rule G-15(f) promulgated by the municipal securities rulemaking board (\"MSRB\") prohibits dealers from effecting customer transactions in municipal securities in amounts below the minimum denominations of the issues. Minimum denominations are generally intended to limit sales of municipal securities to retail customers for whom such bonds may not be suitable, but the proscriptions of rule G-15(f) apply to all transactions with customers, regardless of whether the securities are suitable for the customer. In March 2014, Wedbush violated MSRB rule G-15(f) by executing three sales transactions in the Puerto Rico bonds with customers in amounts below the $100,000 minimum denomination of the issue established by the issuer, Puerto Rico, and specified in the official statement. The limited exceptions provided under MSRB rule G-15(f) for customer transactions in municipal securities below the minimum denomination of an issue did not apply to these transactions. Respondent solicited all of the customer sales transactions. As a result of the conduct described above, respondent willfully violated MSRB rule G-15(f). As a result of respondent's willful violations of MSRB rule G-15(f), respondent willfully violated section 15b(c)(1) of the Exchange Act.","res":"Order","sd":"Accordingly, it is hereby ordered that: respondent cease and desist from committing or causing any violations and any future violations of section 15b(c)(1) of the Exchange Act and MSRB rule G-15(f) . Respondent is censured. Respondent shall, within seven (7) days of the entry of this order, pay a civil money penalty in the amount of $67,200. Respondent willfully violated MSRB rule G-15(f). As a result of respondent's willful violations of MSRB rule G-15(f), respondent willfully violated section 15b(c)(1) of the Exchange Act.","sm":"In determining to accept the offer, the commission considered remedial acts promptly undertaken by respondent. After it became aware that it had effected customer transactions in the 2014 bonds below the minimum denomination of the issue, respondent cancelled the transactions. Respondent will undertake to review the adequacy of its existing policies and procedures relating to compliance with MSRB rule G-15(f). After that review, respondent will make such changes as are necessary to effect compliance with MSRB rule G-15(f), including adopting new policies and procedures or supplementing existing policies and procedures. Respondent will implement these policies and procedures, and conduct training as to the policies and procedures and compliance with MSRB rule G-15(f). Respondent will inform commission staff no later than six (6) months after the entry of this order that it has complied with the above undertakings.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2077},{"d":"2014-10-31","di":"2014-10-31","dr":"2014-10-31","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois, Illinois Securities Department","san":"Restitution","os":"Notice of hearing","st":"Final","fine":500000.0,"dk":"1200385","al":"LPL Financial failed to detect improper and fraudulent coduct on the part of david lisnek toward his LPL clients. LPL Financial allowed MR. lisnek to remain a registered representative while several facts, viewed together as a pattern of conduct, would have constituted multiple cautionary indicators (\"red flags\") of the potential for improper conduct.","res":"Consent","sm":"LPL entered into a consent agreement pursuant to which LPL paid a fine of $500,000 and restitution to investors meeting the consent agreement criteria.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2078},{"d":"2014-10-30","di":"2014-10-30","dr":"2014-10-30","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"NYMEX 10-04626-BC","al":"A panel of the New York Mercantile Exchange (\"NYMEX\") business conduct committee (the \"panel\") accepted a negotiated settlement offer made by Goldman, Sachs & co. (the \"firm\") and supported by the market regulation department which concerned allegations that the firm, on January 18, 2013, and January 23, 2013: (I) executed certain block trades in commodities futures contracts that were not reported to NYMEX within the applicable time limit following execution; (II) reported inaccurate execution times for these block trades; and (III) executed the trades as spread transactions but misreported them as outright transactions, each in alleged violation of NYMEX rule 526.f.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted a settlement offer to the panel. On October 28, 2014, the panel accepted the settlement offer and issued a decision effective on October 30, 2014. On November 7, 2014, the firm submitted a wire in payment of the fine in the amount of $40,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2079},{"d":"2014-10-30","di":"2014-10-30","dr":"2014-10-30","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":90000.0,"dk":"CBOT 10-04626-BC","al":"A panel of the Chicago Board of Trade (\"CBOT\") business conduct committee (the \"panel\") accepted a negotiated settlement offer made by Goldman, Sachs & co. (the \"firm\") and supported by the market regulation department which concerned allegations that the firm: (I) on several occasions between December 30, 2009, and November 27, 2012, executed multiple block trades for customers in various CBOT interest rate futures contracts that were not reported to CBOT within the applicable time limit following execution, reported to CBOT inaccurate execution times of certain block trades, failed to maintain accurate records with respect to certain block trade executions, and did not accurately reflect the time of execution on certain order tickets, in alleged violation of CBOT rules 526.f and 536.a; and (II) on January 6, 2010, and on August 1, 2013, the firm consummated a block trade with a customer and, after realizing the trade was not reported to CBOT within the requisite time limit, canceled the block trade and executed an identical trade with the same customer, in alleged violation of CBOT rule 526.f.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted a settlement offer to the panel. On October 28, 2014, the panel accepted the settlement offer and issued a decision effective on October 30, 2014. On November 7, 2014, the firm submitted a wire in payment of the fine in the amount of $90,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2080},{"d":"2014-10-30","di":"2014-10-30","dr":"2014-10-30","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000.0,"dk":"CME 10-04626-BC","al":"A panel of the Chicago Mercantile Exchange (\"CME\") business conduct committee (the \"panel\") accepted a negotiated settlement offer made by Goldman, Sachs & co. (the \"firm\") and supported by the market regulation department which concerned allegations that the firm: (I) on three occasions between November 28, 2011, and June 26, 2013, executed certain block trades for customers in CME contracts that were not reported to CME within the applicable time limit following execution, in violation of CME rule 526.f, and on two additional occasions, executed block eligible spread trades where each leg of the spread was not executed at the same price, in alleged violation of CME rule 526.d; (II) on June 26, 2013, consummated a block trade to sell currency futures to a customer and, after realizing the trade was not reported to CME within the requisite time limit, canceled the block trade and executed an identical trade with the same customer, in alleged violation of CME rule 526.f; and (III) on one of the above occasions, failed to maintain accurate records with respect to the block trade executions in that an order ticket was missing, and on at least one of the above occasions, reported to CME an inaccurate execution time of the block trade, in alleged violation of CME rules 536.a and 526.f.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted a settlement offer to the panel. On October 28, 2014, the panel accepted the settlement offer and issued a decision effective on October 30, 2014. On November 7, 2014, the firm submitted a wire in payment of the fine in the amount of $70,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2081},{"d":"2014-10-30","di":"2014-10-30","dr":"2014-10-30","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CBOT 13-7766-7767-BC","al":"A panel of the Chicago Board of Trade (\"CBOT\") business conduct committee (the \"panel\") accepted a negotiated settlement offer made by Goldman, Sachs & co. (the \"firm\") and supported by the market regulation department which concerned allegations that on one or more occasions from 2010 through 2013, Goldman, Sachs & co. (the \"firm\") failed to properly register certain TAG50 user ids and allowed certain orders to be entered on globex using incorrect TAG50 user ids, in alleged violation of CBOT rule 576.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted a settlement offer to the panel. On October 28, 2014, the panel accepted the settlement offer and issued a decision effective on October 30, 2014. On November 7, 2014, the firm submitted a wire in payment of the fine in the amount of $1,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2082},{"d":"2014-10-30","di":"2014-10-30","dr":"2014-10-30","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"CME 13-7766-7767-BC","al":"A panel of the Chicago Mercantile Exchange (\"CME\") business conduct committee (the \"panel\") accepted a negotiated settlement offer made by Goldman, Sachs & co. (the \"firm\") and supported by the market regulation department which concerned allegations that on one or more occasions from 2010 through 2013, the firm failed to properly register certain TAG50 user ids and allowed certain orders to be entered on globex using incorrect TAG50 user ids, in alleged violation of CME rule 576.","res":"Consent","sm":"Without admitting or denying the rule violations, allegations or findings, the firm submitted a settlement offer to the panel. On October 28, 2014, the panel accepted the settlement offer and issued a decision effective on October 30, 2014. On November 7, 2014, the firm submitted a wire in payment of the fine in the amount of $2,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2083},{"d":"2014-10-29","dr":"2014-10-29","k":"Civil Judicial Action","san":"Injunction","os":"Restitution","st":"Final","al":"The only remaining allegation in this litigation is that Wells Fargo Bank violated the provisions of California business & professions code section 17200 et seq. Relating to alleged fraudulent misrepresentations as to the order by which the bank posted items to consumer deposit accounts in the state of California.","res":"Judgment Rendered","sd":"Effective July 15, 2013 the order enjoins the bank permanently \"from making or disseminating, or permitting to be made or disseminated, any false or misleading representations relating to the posting order of debit-card purchases, checks, and ach transactions in its customer bank accounts.\" Restitution of $203,000,000.00 was ordered. Restitution has not been paid pending appeal. Wells fargo paid the judgment (and post-judgment interest) of approximately $205,000,000 in June 2016.","ab":"Wells Fargo Bank N.A.","firms":[11025,19616],"id":2084},{"d":"2014-10-27","di":"2014-10-27","dr":"2014-10-27","k":"Regulatory Action","rg":"Other","reg":"Swiss Federal Department of Finance","san":"Other","os":"Reparation payment","st":"Final","fine":20842.02,"dk":"442.2-126","al":"The federal department of finance (\"FDF\") of the Swiss confederation alleged that Goldman Sachs international (\"GSI\") was late in publishing a drop below a notifiable threshold in the firm's holdings in a qualified interest in certain securities in the period between September 25, 2012, and December 20, 2012, in alleged infringement of article 41 of the Swiss federal act on stock exchanges and securities trading (SESTA).","res":"Consent","sm":"Without admitting any intentional infringement of sesta articles or wrongdoing, gsi entered into a settlement agreement with FDF on October 27, 2014, and consented to a payment to the Swiss confederation in the amount of CHF20,000, which amount was paid on November 4, 2014.","ab":"Goldman Sachs","firms":[361],"id":2085},{"d":"2014-10-27","di":"2014-10-27","dr":"2014-10-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":2500000.0,"dk":"2010022971201","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain and enforce adequate supervisory systems and procedures, including in some instances written supervisory procedures, that were reasonably designed to ensure compliance with applicable securities laws and regulations including Regulation SHO, emergency orders issued by the SEC, customer reserve, and record retention requirements of the Securities Exchange Act of 1934 and anti-money laundering requirements. The findings stated that the firm's supervisory systems and procedures, including its written supervisory procedures regarding the allocation of fail-to-deliver (FTD) positions considered its broker-dealer clients' short positions without also considering their trading activities as stated in the rule 204t and rule 2014 adopting releases. The firm's processes failed to ensure that its allocations were made to the specific entity that contributed to its FTD position as required, and thereby the firm netted the short positions of four related but separate and distinct broker-dealer entities when allocating its FTD positions. Therefore, the firm failed to establish, maintain and enforce adequate supervisory systems and procedures, including written supervisory procedures that were reasonably designed to ensure compliance with the requirements of rule 204 of Regulation SHO by allocating its continuous net settlement (CNS) FTD positions based on its broker-dealer clients' short positions and without also considering which clients contributed to those positions. The findings also stated that the firm failed to establish, maintain and enforce adequate supervisory systems and procedures, including written supervisory procedures, reasonably designed to ensure compliance with the requirements of rules 204t(b) and (c) and 204(b) and (c) to notify its clients when it had an aged FTD position in a given security and to refrain from effecting or accepting from its clients short sales in securities in which it had an aged FTD position. The findings also included that the firm failed to establish, maintain and enforce adequate supervisory systems and procedures, including written supervisory procedures that were reasonably designed to do surveillance of the activities of certain of its direct market access, naked access and sponsored access clients for the purpose of detecting and reporting, where appropriate, suspicious and/or manipulative trading. Because the firm's programs for suspicious activity monitoring failed to capture certain trading data necessary to monitor for suspicious activity, the firm failed to implement and establish procedures and internal controls reasonably designed to detect and cause the reporting of suspicious transactions. FINRA found that the firm effected short sales in the securities restricted by SEC emergency orders. The firm submitted inaccurate focus reports in that they contained inaccurate reserve formula computations.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $2,500,000 and required to, within 120 days of the issuance of a notice of acceptance of this AWC, to adopt and implement supervisory systems and written procedures reasonably designed to achieve compliance with the current requirements of rule 204 of reg sho.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2086},{"d":"2014-10-24","di":"2014-10-24","dr":"2014-10-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":55000.0,"dk":"2011026096702","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\"): (a) based upon certain items from the 2011 trading and market making surveillance examination of the firm which examined trade dates October 5, 2011 and October 6, 2011, failed to (I) report certain apparent customer order events to the order audit trail system (\"OATS\"); (II) provide a record of certain order route reports submitted to OATS; and (III) accurately append the short sale indicator to certain FINRA/Nasdaq trade reporting facility (TRF) reports, in alleged violation of FINRA rules 7450, 7440 and 6182, respectively; and (IV) document \"stopped stock\" information on certain customer order memoranda, provide certain complete and/or accurate customer order memoranda, and accurately mark certain sell transactions on the firm's trading ledger, in alleged violation of section 17 of the Securities Exchange Act of 1934, as amended, and rule 17(a)-3 thereunder, as well as NASD rule 3110; and (b) based upon certain items from the 2012 trading and market making surveillance examination of the firm which examined trade dates October 11, 2012 and October 12, 2012, (I) incorrectly reported the number of shares executed at the market center as away executed shares in certain instances in the firm's rule 605 of regulation NMS report, and (II) transmitted certain reports that contained inaccurate, incomplete, or improperly formatted data to OATS, in alleged violation of rule 605 of regulation NMS and FINRA rule 7450, respectively.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on October 24, 2014, and on November 13, 2014, the firm submitted a wire in payment of a fine in the amount of $55,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2087},{"d":"2014-10-22","dr":"2014-10-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"2010021544001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in 16 instances, the firm had a fail-to-deliver position at a registered clearing agency in an equity security that resulted from sales of a security that the seller was deemed to own pursuant to §242.200 of Regulation SHO and intended to deliver once all restrictions on delivery had been removed, and did not close the fail-to-deliver position by purchasing or borrowing securities of like kind and quantity within the timeframe prescribed by rule 204(a)(2) of Regulation SHO.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $20,000.","sm":"The firm was censured and fined $20,000 on 10/22/2014","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2088},{"d":"2014-10-21","di":"2014-10-21","dr":"2014-10-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":250000.0,"dk":"2010022950801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and NASD and FINRA rules, concerning the detections of orders for the purchase and sale of securities that resulted in no change of beneficial ownership. The findings stated that the firm's supervisory system failed to detect and review trades emanating from customer orders and did not include the value \"usd\" in the currency indicator field, which left a gap in the firm's surveillance system that resulted in the firm failing to review in its wash trade surveillance program numerous trades, representing millions of shares in various securities across 83 customer accounts, and allowed wash transactions to occur undetected by the firm.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm was censured, fined $250,000 and undertakes to revise its written supervisory procedures.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2089},{"d":"2014-10-10","di":"2014-10-10","dr":"2014-10-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":100000.0,"dk":"2012031611301","al":"On October 10, 2014, FINRA alleged that Edward jones failed to develop and implement adequate anti-money laundering (AML) procedures for reviewing deposits and liquidations of third-party stock certificates in customer accounts in violation of NASD rules 3011(a) and 2110 and FINRA rules 3310(a) and 2010. On October 10, 2014, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent (AWC) with FINRA. Pursuant to the AWC, Edward jones was censured and ordered to pay a fine of $100,000. The fine was paid on October 23, 2014.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2090},{"d":"2014-10-06","di":"2014-10-06","dr":"2014-10-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":5000.0,"dk":"2012033550001","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, for the period between April 1, 2012 and June 30, 2012, Goldman, Sachs & co. (the \"firm\") improperly submitted certain execution or combined order/execution reports that the firm was not required to report, in alleged violation of FINRA rule 7450.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on October 6, 2014, and on October 16, 2014, the firm submitted a wire in payment of a fine in the amount of $5,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2091},{"d":"2014-10-06","di":"2014-10-06","dr":"2014-10-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"2010023889001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce written policies and procedures that were reasonably designed to prevent trade-throughs of protected quotations in NMS stocks that do not fall within any applicable exception, and if relying on an exception, are reasonably designed to assure compliance with the terms of the exception. The findings stated that the firm failed to take reasonable steps to establish that the intermarket sweep orders it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the findings and was censured and fined $50,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2092},{"d":"2014-09-29","di":"2014-09-29","dr":"2014-09-29","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":7650000.0,"dk":"3-16177","al":"The Securities and Exchange Commission (\"commission\") alleged that Bank of America corporation (\"BAC\"), as part of its regulatory capital calculations, failed to deduct certain realized losses on certain structured notes and other financial instruments (the \"notes\") issued by Merrill lynch & co., inc. (\"ML&co.\") that BAC assumed or acquired as part of its acquisition of ML&co. and, therefore, BAC overstated its regulatory capital in its Form 10-q filings from 2009-2014 and in its Form 10-k filings for financial years 2009-2013. The commission alleged that BAC violated section 13(b)(2)(a) and (b) of the Exchange Act.","res":"Settled","sm":"The commission noted that bac self identified and self reported the overstatements and the commission noted that bac had provided substantial cooperation to the commission staff. The commission also noted that bac had voluntarily undertaken steps to remediate and address, among other things, the inadequate books and records and internal accounting control deficiencies that were the subject of the proceeding.","ab":"Bank of America","firms":[7691,142558],"id":2093},{"d":"2014-09-25","di":"2014-09-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":19000.0,"dk":"2013038742701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that as managing underwriter, under the market participant identifier (MPID) of \"bofa\", the firm failed to timely report 33 new issue offerings and under the MPID \"mlco\", the firm failed to timely report 40 new issue offerings in trade reporting compliance engine (TRACE)- eligible securities to FINRA in accordance with the requirements of FINRA rule 6760(c)","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the findings and was censured and fined $19,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2094},{"d":"2014-09-24","di":"2011-03-09","dr":"2014-09-24","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Secretary of the Commonwealth of Massachusetts, Securities Division","san":"Other","os":"The order required respondents to comply with 203(a) and 203a of the Massachusetts Securities Act and Massachusetts","st":"Final","fine":50000.0,"dk":"DOCKET # E-2010-0057","al":"In March 2011, the Massachusetts securities division filed an administrative complaint against james a. Silverman and affiliated entities, then known as risk reward capital management corp., RRC management, LLC, and RRC bio fund, LP, now known as Opaleye Management Inc., Opaleye GP LLC, and Opaleye, L.P., alleging deficiencies relating to policies and procedures concerning material non-public information and recordkeeping. In September 2014, the parties entered into a consent order to settle the matter, without admitting or denying the allegations.","res":"Settled","sd":"Respondents jointly and severally paid a fine of $50,000 on October 1, 2014.","sm":"On September 24, 2014, Opaleye Management Inc., Opaleye GP LLC, and Opaleye, L.P. entered into a consent order with the Massachusetts securities division to resolve an administrative complaint alleging deficiencies relating to policies and procedures concerning material non-public information and recordkeeping. The respondents neither admitted nor denied the allegations. The matter was resolved with an administrative fine. No information Filed","ab":"Silverman, James, Aaron","firms":[124513],"id":2095},{"d":"2014-09-22","di":"2014-09-22","dr":"2014-09-22","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","st":"Final","fine":5000000.0,"dk":"3-16153","al":"SEC admin release 34-73175, ia release 40-3928/September 22, 2014: 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 pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934 and sections 203(e) and 203(k) of the Investment Advisers Act of 1940 against Wells fargo advisors, LLC (\"Wells fargo advisors\" or \"respondent\"). In anticipation of the institution of these proceedings,respondent has submitted an offer of settlement which the commission has determined to accept. Wells fargo advisors admits the findings, acknowledges that its conduct violated the federal securities laws, admits the commission's jurisdiction over it and the subject matter of these proceedings, and consents to the entry of this order instituting administrative and cease-and-desist proceedings. This case involves the failure of Wells fargo advisors to adequately establish, maintain, and enforce policies and procedures reasonably designed to prevent the misuse of material nonpublic information, specifically, the material nonpublic information obtained from its customers and its advisory clients. Wells fargo advisors' policies and procedures to prevent the misuse of material nonpublic information were not reasonably designed to address the risk that its associated persons could obtain material nonpublic information from its customers and advisory clients even though the firm expressly identified that risk in multiple internal documents. This risk manifested itself in 2010 when one of the registered representatives of Wells fargo advisors misappropriated information from one of his customers about a company's securities, traded on the basis of that information,and tipped others including several of his Wells fargo advisors customers. The manner in which the policies and procedures were designed affected the company securities review. Multiple units within the firm received indications suggesting that the registered representative was misusing material nonpublic information obtained from a customer to trade in the company's securities. Because of a lack of assigned responsibility or coordination, each of these units failed to take needed actions. The policies and procedures designed caused respondent not to recognize several red flags that its representative was engaging in insider trading in the company's securities. In addition the respondent did not effectively maintain and enforce the policies and procedures. Additionally, although the policies and procedures required \"daily review to identify situations when profit or avoidance of loss could most likely result from trading prior to the public release of information,\" for a ten month period the retail control group (RCG), a unit in the firm's compliance department, failed to perform reviews in a timely manner of at least 40 instances of possible insider trading flagged for review. When the respondent produced documents, as requested by the commission,relating to reviews of trading by the registered representative who traded in the company's securities, in response to the commission's request,documents relating to the RCG review of the securities trading were not produced. Respondent unreasonably delayed,without any explanation,for six months producing documents relating to the RCG review of the representative who traded in the company's securities. When the documents were produced, the firm failed to produce an accurate record of the review as it existed at the time of the request.","res":"Order","sm":"See sanction details in 12.b.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2096},{"d":"2014-09-16","di":"2014-09-16","dr":"2014-09-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease & desist","st":"Final","fine":3972.17,"dk":"SEU-2011-13","al":"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.","res":"Stipulation and Consent","sd":"On 9/16/2014, Raymond james paid a fine in the amount of $3,972.17 to the treasurer of State of Hawaii.","sm":"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.","ab":"Raymond James Financial","firms":[705],"id":2097},{"d":"2014-09-16","di":"2014-09-16","dr":"2014-09-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution","st":"Final","fine":5000.0,"dk":"20120317576-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2098},{"d":"2014-09-16","di":"2014-09-16","dr":"2014-09-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Civil and administrative penalt(IES) / fine(s) disgorgement","st":"Final","fine":904570.84,"dk":"3-16109","al":"The regulatory action stems from allegations that the adviser violated rule 105 of Regulation M of the Securities Exchange Act of 1934 (the \"Exchange Act\").","res":"Decision & Order of Offer of Settlement","sd":"The adviser was ordered to pay disgorgement of $2,646,395.21 and prejudgment interest of $73,394.16, which was paid to the United States Treasury on September 19, 2014. The adviser was also ordered to pay a civil monetary penalty in the amount of $904,570.84, which was paid to the United States Treasury on September 19, 2014.","sm":"The action has reached a final resolution and the adviser was ordered to cease and desist from committing or causing any violation and any future violations of rule 105 of Regulation M of the Exchange Act. The adviser has complied with all terms of the order, and payment of the disgorgement and monetary penalty amounts set forth above was made on September 19, 2014. No information Filed","ab":"Ra Capital Management, LP","self":true,"firms":[160174],"id":2099},{"d":"2014-09-10","di":"2013-07-25","dr":"2014-09-10","k":"Regulatory Action","rg":"Other","reg":"U.S Securities and Exhange Commission","san":"Cease and Desist","os":"Civil money penalty","st":"Final","fine":75000.0,"dk":"3-16705","al":"On September 10, 2014 neil Gagnon consented to the entry of an order instituting administrative and cease-and-desist proceedings (\"order\") by the U.S. Securities and Exchange Commission (the \"SEC\"). In the order, the SEC found that MR. Gagnon failed to timely file beneficial ownership reports required under section 13(d) and section 16(a) of the Securities Exchange Act of 1934 (\"Exchange Act\"). Specifically, the SEC alleged that MR. Gagnon failed to filed timely amendments to its schedules 13g's and continued to file as a passive investor on a schedule 13g, despite owning in excess of 20% of the outstanding voting securities of a particular issuer, thereby requiring a schedule 13d filing and subsequent amendments. Further, MR. Gagnon failed to make timely reports on forms 4 and 5 to in accordance with section 16(a) of the Exchange Act. Without admitting or denying the SEC's findings, MR. Gagnon agreed to cease and desist from future violations of sections 13(d) and 16(a) of the Exchange Act and rules 13D-1, 13D-2 and 16A-3 thereunder, and to pay a civil monetary penalty of $75,000.","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the violations, neil Gagnon consented to the entry of an SEC order finding that MR. Gagnon failed to make timely filings in accordance with sections 13(d) and 16(a) of the Securities Exchange Act of 1934. Neil Gagnon submitted an offer of settlement which was accepted by the SEC. without admitting or denying the violations, MR. Gagnon will pay a civil monetary penalty of $75,000. MR. Gagnon also agreed to cease and desist from committing or causing any violations of sections 13(d) and 16(a) of the Securities Exchange Act of 1934 and rules 13D-1, 13D-2 and 16A-3 thereunder. No information Filed","ab":"Gagnon, Neil Joseph","firms":[103727],"id":2100},{"d":"2014-09-10","di":"2013-08-22","dr":"2014-09-10","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Order and monetary penalty","st":"Final","fine":150000.0,"dk":"3-16079","al":"SEC alleged that JLL was the cause of violations by certain of its officers and directors of certain federal securities laws and SEC rules requiring prompt reporting on SEC forms of transactions and holdings, which led to inaccurate statements in JLL's proxy statement with respect to the timely filing of such forms","res":"Settled","sd":"Total fine: $150,000. 100% of the fine was levied against Jones Lang Lasalle Incorporated. The fine was paid by Jones Lang Lasalle Incorporated on 9-16-2014.","sm":"Provided). On 10 September 2014, the US securities exchange commission announced that it accepted JLL's offer to settle proceedings initiated by the SEC in relation to certain federal securities laws and SEC rules requiring prompt reporting of transactions and holdings. In particular, the SEC's settlement order concerned the settlement of enforcement actions relating to the late filing of forms that disclose changes in ownership of stock owned by executive officers and directors at the JLL holding company level. All of JLL's filings included as part of the settlement related to restricted stock units granted to officers and directors as part of JLL's equity compensation plans. The settlement provides for JLL to pay a US $150,000 penalty to the SEC and to cease and desist from any current or future violations. In accepting the settlement, the SEC acknowledged JLL's cooperation and remedial acts undertaken by JLL. No information Filed","ab":"Jones Lang Lasalle Incorporated","firms":[111179],"id":2101},{"d":"2014-09-04","di":"2014-08-25","dr":"2014-09-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Department of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":800.0,"dk":"NONE","al":"From approximately December 2010 through December 12, 2012, LPL Financial was subject to various FINRA actions and other administrative actions on its professional licenses in the states of Illinois, Kentucky, Missouri, and Texas. LPL Financial reported its administrative actions to the Ohio department of insurance. However, they weren't reported to the department within the required thirty-day time period.","res":"Order","sm":"LPL paid a civil fine of $800 and administrative costs of $200.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2102},{"d":"2014-08-29","di":"2013-08-06","dr":"2014-08-29","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"None","st":"Final","al":"On August 6, 2013, the Department of Justice filed a civil action against Merrill Lynch, Pierce, fenner & smith, inc. f/k/a banc of america securities LLC (the \"firm\") and other entities (collectively the \"entities\"). The Department of Justice alleges that the entities violated the financial institutions reform, recovery and enforcement act of 1989, 12 U.S.C. § 1833a, through civil violations of 18 U.S.C. §§ 1001 and 1014. The complaint claims that the entities made false statements to and omitted material information from the government and federally insured financial institutions. Specifically, the complaint alleges that the entities failed to disclose the disproportionate concentration of wholesale channel loans originated by third parties underlying the residential mortgage backed securities. The complaint alleges that the entities knew the wholesale channel loans were riskier as compared to similar mortgages originated by the entities directly. The complaint also alleges that the entities failed to disclose the percentage of papersaver loans made to self-employed borrowers. The complaint alleges that the entities knew papersaver loans were riskier than mortgages given to salaried borrowers. The complaint further alleges that, even though the entities were aware of the risks associated with the characteristics of the pool, the entities failed to conduct third- party due diligence on the mortgages in the pool and violated the firm's due diligence policies. The complaint seeks a civil monetary judgment in an unstated amount pursuant to 12 U.S.C. § 1833a(b), prejudgment interest, and attorneys' fees.","res":"Dismissed","ab":"Merrill Lynch, Pierce,","firms":[142558],"id":2103},{"d":"2014-08-26","di":"2014-08-26","dr":"2014-08-26","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist undertaking","st":"Final","fine":1200000.0,"dk":"14-22","al":"From at least January 1, 2010 through April 2013 (the \"relevant period\"), the firm failed to supervise diligently its officers', employees', and agents' processing of exchange and clearing fees charged to its customers, in violation of CFTC regulation 166.3. As a result, the firm's reconciliation process for identifying and correcting discrepancies between the invoices from the exchange clearinghouses and the amounts charged to customers has been inaccurate and faulty since at least January 1, 2010, and led to instances in which the firm appears to have overcharged some customers and undercharged others. Where the firm has confirmed that there was an overcharge to a customer, the customer's account has been adjusted, but the firm has been unable to fully resolve some discrepancies. Additionally, during the relevant period, the firm did not hire qualified personnel to conduct and oversee the fee reconciliations or provide adequate training to existing personnel regarding fee reconciliations.","res":"Other","sm":"Without admitting or denying any of the findings or conclusions, the firm agreed to the entry of the order, agreed to pay a civil monetary penalty of $1,200,000, cease and desist from further violations of CFTC regulation 166.3, and undertake to implement strengthened processes and procedures related to futures exchange and clearing fee reconciliations that will not only improve accuracy, but will detect when the firm's customers have been charged inaccurate futures exchange and clearing fees. The firm self-identified this matter before the CFTC began its investigation and has fully cooperated with the CFTC's review of this matter.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2104},{"d":"2014-08-25","di":"2014-08-25","dr":"2014-08-25","k":"Regulatory Action","rg":"Other","reg":"Mexder, Mercado Mexicano de Derivados, S.A. de C.V.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":851.36,"dk":"SAN0372014","al":"In a notice of a disciplinary measure dated August 25, 2014, the secretary of the disciplinary and arbitration committee of Mexder, Mercado Mexicano de Derivados, S.A. De C.V. (\"Mexder\"), informed Goldman, Sachs & co. (the \"firm\") of Mexder's conclusion that the firm failed to timely notify Mexder of the withdrawal from registration with Mexder of an employee of the firm who was an accredited Mexder sales representative and trader, in alleged failure to comply with article 6036.00 subsection III of Mexder internal regulations.","res":"Decision","sm":"Mexder imposed an economic penalty on the firm in the amount of $11,268.24 mexican pesos in the aggregate, which amount was paid by submission of a wire on September 18, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2105},{"d":"2014-08-21","di":"2014-08-21","dr":"2014-08-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":20000000.0,"dk":"ADMINISTRATIVE PROCEEDING NO. 3-16028","al":"The Securities and Exchange Commission (\"commission\") alleged that Bank of America corporation (\"BAC\") failed to make required disclosures in the management's discussion and analysis and results of operations (\"MD&a\") sections of periodic filings, related to known uncertainties as to whether certain costs related to loans BAC would ultimately be required to repurchase from certain insurers would have a material effect on BAC's future income from continuing operations. The commission alleged that BAC violated section 13(a) of the Exchange Act and rules 12B-20 and 13A-13 thereunder.","res":"Settled","sm":"Bac admitted to certain facts set out in an annex to the administrative order, acknowledged that its conduct set forth in the annex to the administrative order violated the federal securities law and admitted to the commission's jurisdiction over it and the subject matter of the proceedings.","ab":"Bank of America","firms":[7691,142558],"id":2106},{"d":"2014-08-20","di":"2014-08-20","dr":"2014-08-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":300000.0,"dk":"2011030744101","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to record and preserve certain record keeping information required on options order memoranda. The findings stated that representatives in one branch did not follow the firm's procedure to complete a paper ticket when options orders were called into the trading desk. Thus in 1,801 instances of large options orders, the firm's order memoranda did not have the information reflecting the time the order was received and the identity of any other person who entered or accepted the order on behalf of the customer. The findings also stated that the firm failed to adequately enforce its written supervisory procedures, at one of its branches, requiring that its registered representatives accurately recorded all required order memoranda information for options orders that were telephoned to the trading desk. The branch audit involved a review of a select number of manual tickets that may include various products, but manual tickets for options were not necessarily reviewed. As such, the firm did not adequately review and monitor options order tickets for orders that were called into the trading desk by certain registered representatives during a two-year period.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to a fine of $300,000 and a censure.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2107},{"d":"2014-08-14","di":"2014-08-14","dr":"2014-08-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":72500.0,"dk":"2011028587301","al":"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) for which the OATS system was unable to link the execution reports to the related trade reports in a FINRA transaction reporting system due to inaccurate, incomplete or improperly formatted data, and transmitted execution or combined order/execution reports to OATS for which it failed to append the required reporting exception code. The findings stated that the firm transmitted new order reports and related subsequent reports to OATS for which the OATS system was unable to create an accurate, time sequenced record from the receipt of the order through its resolution because the timestamp for the related subsequent report occurred prior to receipt of the order, and transmitted execution or combined order/execution reports to OATS that contained inaccurate, incomplete or improperly formatted data. In some of these instances, the OATS system was unable to link the execution reports to the related trade reports in a FINRA trade reporting system and in other instances, the firm failed to append the required reporting exception code. The firm transmitted route or combined order/route reports to OATS for which the OATS system was unable to link to the related exchange due to inaccurate, incomplete or improperly formatted data, transmitted route or combined order/route reports to OATS for which the OATS system was unable to link to the corresponding new order transmitted by the receiving member firm due to inaccurate, incomplete or improperly formatted data, and transmitted route or combined order/route reports to OATS, which were submitted by other members where the firm was named as the \"sent to firm,\" for which the OATS system was unable to match. The findings also stated that the firm failed to transmit and failed to timely transmit reportable order events (ROES) to OATS. The firm failed to accept or decline in the FINRA/Nasdaq trade reporting facility (FNTRF) transactions in reportable securities within 20 minutes after execution and failed to timely report to the FNTRF by 8:00 P.M. Eastern time transactions that required an .RX modifier.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the sanctions, paid a fine of $72,500, and was censured.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2108},{"d":"2014-08-07","di":"2014-08-07","dr":"2014-08-07","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":27500.0,"dk":"2012030914701","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to reasonably avoid displaying, and engaged in a pattern or practice of displaying, quotations that locked or crossed a protected quotation. The findings stated that the firm gave another broker-dealer, which was not a member of Nasdaq, sponsored access to Nasdaq and that broker-dealer entered intermarket sweep orders into the Nasdaq single book execution system that locked or crossed a quotation previously disseminated pursuant to an effective national market system plan and failed to simultaneously route an intermarket sweep order to execute against the full displayed size of the locked or crossed protected quote. This conduct violated Nasdaq rule 4613(e). The findings also stated that the firm failed to supervise its sponsored access clients to reasonably prevent these clients from engaging in a pattern or practice of displaying quotations in the Nasdaq single book execution system, that locked or crossed a protected quotation. As a result, 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 Nasdaq rules concerning locked/crossed markets. 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. This conduct violated Nasdaq rules 2110 and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the entry of the findings, a fine of $27,500, a censure, and to the undertaking outlined in 12.b. Above.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2109},{"d":"2014-08-07","di":"2014-08-07","dr":"2014-08-07","k":"Regulatory Action","rg":"Other","reg":"Australian Securities & Investments Commission (\"ASIC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":89108.95,"dk":"MDP REF NO: 20034/13; ASIC REF NO. 23929/12","al":"Merrill Lynch Equities (AUSTRALIA) limited (\"mle(a)l\") contravened ASIC market integrity rules 5.6.1 and 5.9.1 and thereby contravened subsection 798h(1) of the act in that the mle(a)l failed to have in place an appropriate automated price filter for one client account, which interfered with the efficiency and integrity of the market; and mle(a)l's misconduct resulted in a market not being both fair and orderly.","res":"Other","sm":"Without admitting to guilt or liability in relation to the alleged contravention, mle(a)l agreed to pay a penalty of aud$96,000.00 (approximately usd$89,108.95). Mle(a)l cooperated with ASIC throughout its investigation.","ab":"Merrill Lynch Equities","firms":[7691],"id":2110},{"d":"2014-08-01","di":"2014-08-01","dr":"2014-08-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"2012032500201","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period of October 1, 2011 through March 31, 2012, Goldman, Sachs & co. (the \"firm\") failed to timely report certain new issue offerings in TRACE-eligible corporate debt securities, in alleged violation of FINRA rule 6760(c).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on August 1, 2014, and on August 13, 2014, the firm submitted a wire in payment of a fine in the amount of $7,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2111},{"d":"2014-07-31","dr":"2014-07-31","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Restitution; treble damages","st":"Final","fine":1267491770.0,"al":"After an individual commenced a qui tam lawsuit, the U.S. attorney filed a complaint-in-intervention in 2012 in the United States district COURT for the southern district of New York (\"COURT\") against countrywide home loans, inc., countrywide bank, FSB, bank of america, N.A. and certain affiliates (\"defendants\") alleging that the defendants engaged in an intentional scheme to misrepresent the quality of the mortgage loans that it processed through a particular loan origination program and sold to fannie mae and freddie mac during August 2007 to May 2008. The complaint sought to recover treble damages and penalties under the false claims act, 31 U.S.C. § 3729 et. Seq. (\"FCA\") and civil penalties under the financial institutions reform, recovery, and enforcement act, 12 U.S.C. § 1833a (\"FIRREA\").","res":"Judgment Rendered","ab":"Bank of America, National","firms":[142558],"id":2112},{"d":"2014-07-30","di":"2014-07-30","dr":"2014-07-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":30000.0,"dk":"2012031659001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to execute orders fully and promptly. The findings stated that the firm transmitted to OATS reports that contained inaccurate, incomplete, or improperly formatted data. Specifically, the reports contained inaccurate timestamps. Additionally, the firm failed to transmit two reportable order events (ROES) to OATS. The findings also stated that the firm failed to show the correct order receipt time on the memorandum. The findings also included 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 or the SEC. FINRA found that the firm failed to report S1 transactions in TRACE-eligible agency debt securities within 15 minutes of the time of execution to TRACE.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, LPL consented to a censure and a fine of $30,000, which LPL paid.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2113},{"d":"2014-07-16","di":"2014-07-16","dr":"2014-07-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20120333211-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period of January 1, 2012 through April 30, 2012, Goldman, Sachs & co. (the \"firm\") failed to accept or decline in the FINRA/Nasdaq trade reporting facility certain transactions in reportable securities within twenty minutes after execution, in alleged violation of FINRA rules 7230a(b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on July 16, 2014, and on July 29, 2014, the firm submitted a wire in payment of a fine in the amount of $20,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2114},{"d":"2014-07-15","di":"2014-07-15","dr":"2014-07-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":10000.0,"dk":"2012033330501","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it sold agency bonds to its customers and failed to buy or sell such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each at the time of the transaction, the expense involved and that the firm was entitled to a profit.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2115},{"d":"2014-07-15","di":"2014-07-15","dr":"2014-07-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut, Department of Banking, Securities and Business Investment Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Syndicated, its officers, representatives, agents, employees, and successors in interest shall refrain from engaging, directly or","st":"Final","fine":10000.0,"dk":"CO-14-7988B-S","al":"Former registered rep, stephen blankenship, offered high rates of return on promissory notes. In reality, he engaged in a ponzi scheme.","res":"Consent","sd":"Syndicated, it officers, representatives, agents, employees, affiliates, and successors in interest shall refrain from engaging, directly or indirectly, in conduct constituting or which would constitute a violation of the act or any regulation or order under the act, including failing to establish, enforce and maintain a system for supervising the activities of its agents and its CT office operations reasonably designed to achieve compliance with applicable securities laws.","sm":"Syndicated Capital reimbursed its share of money to the victims. The case is closed.","ab":"Syndicated Capital, Inc.","firms":[29037],"id":2116},{"d":"2014-07-14","di":"2014-07-14","dr":"2014-07-14","k":"Regulatory Action","rg":"Other","reg":"Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"CO-14-7988B-S","al":"On July 14, 2014, the banking commissioner entered a consent order (no. CO-14-7988B-S) with respect to Syndicated Capital, Inc., a Connecticut-registered broker-dealer located at 1299 ocean avenue, second floor, santa monica, California. From 2002 to 2006, the firm maintained a branch office at 152 deer hill avenue, suite 203, danbury, Connecticut, and employed stephen burton blankenship (CRD number 2234577) as a registered broker-dealer agent. Blankenship, the sole managing member and control person of deer hill financial group, LLC, also conducted tax preparation, financial planning and investment advisory services from the danbury location. Following allegations of unregistered investment advisory activity, fraud and misappropriation, the banking commissioner entered a consent order (docket no. CO-12-7988-S) with respect to blankenship and deer hill financial group, LLC on August 31, 2012. That consent order revoked blankenship's registration as a broker-dealer agent and permanently barred both blankenship and deer hill financial group, LLC from transacting securities business in or from Connecticut. In addition, the U.S. district court for the district of Connecticut fined blankenship $7,500, directed blankenship to make $607,516.81 in restitution and sentenced blankenship to 41 months in prison following blankenship's guilty plea to one count of federal mail fraud and one count of federal securities fraud (United States of america v. stephen blankenship, d. Conn. Case no. 3:12CR197 (VLB)). The consent order with Syndicated Capital, Inc. alleged that, in contravention of section 36B-31-6F of the regulations under the Connecticut uniform Securities Act, the firm failed to establish, enforce and maintain a system for supervising the activities of its agents, including blankenship, reasonably designed to achieve compliance with applicable securities laws and regulations.","res":"Consent","sd":"See response to item 12b","sm":"No Information Filed Arbitration DRPs No Information Filed Bond DRPs No Information Filed Judgment/Lien DRPs No Information Filed Part 1B Item 1 - State Registration You must complete this Part 1B only if you are applying for registration, or are registered, as an investment adviser with any of the state securities authorities. Complete this Item 1 if you are submitting an initial application for state registration or requesting additional state registration(s). Check the boxes next to the states to which you are submitting this application. If you are already registered with at least one state and are applying for registration with an additional state or states, check the boxes next to the states in which you are applying for registration. Do not check the boxes next to the states in which you are currently registered or where you have an application for registration pending. Jurisdictions AL IL NE SC AK IN NV SD AZ IA NH TN AR KS NJ TX CA KY NM UT CO LA NY VT CT ME NC VI DE MD ND VA DC MA OH WA FL MI OK WV GA MN OR WI GU MS PA WY HI MO PR","ab":"Syndicated Capital, Inc.","self":true,"firms":[29037],"id":2117},{"d":"2014-07-11","di":"2014-07-11","dr":"2014-07-11","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","st":"Final","fine":12500.0,"dk":"2012034405001","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to display immediately customer limit orders in Nasdaq securities (including the orders' full size and price) in its public quotation, when each such order was at a price that would have improved the firm's bid or offer in each such security; or when the order was priced equal to the firm's bid or offer and the national best bid or offer for each such security, and the size of the order represented more than a de minimis change in relation to the size associated with the firm's bid or offer in each such security, in violation of SEC rule 604 of regulation NMS.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, Janney entered in an AWC with Nasdaq in which it consented to a censure and fine in the amount of $12,500 related to SEC rule 604 of regulation NMS. The firm has updated its supervisory policies and procedures to address these findings.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2118},{"d":"2014-07-11","di":"2014-07-11","dr":"2014-07-11","k":"Regulatory Action","rg":"Department of Justice","reg":"United States Department of Justice, Several State Attorneys General and the FDIC","san":"p","st":"Final","fine":4500000000.0,"dk":"N/A","al":"The DOJ and state AGs alleged that Citi misrepresented the quality and characteristics of the mortgage loans it securitized and sold to investors, including that the loans were originated in accordance with underwriting guidelines and in compliance with federal, state and local laws and regulations. The FDIC had asserted, in several litigations commenced against Citigroup as issuer and underwriter of RMBS, similar claims of misrepresentations relating to the quality of the loan collateral in the RMBS at issue.","res":"Settled","sm":"On July 11, 2014, Citigroup entered into a settlement with the United States Department of Justice (the \"DOJ\"), several state attorneys general (the \"state AGs\") and the federal deposit insurance corporation (the \"FDIC\") relating to residential mortgage- backed securities (\"RMBS\") and collateralized debt obligations (\"CDOS\") issued, structured or underwritten by Citi between 2003 and 2008. Under the terms of the settlement, Citigroup will pay a total of $4.5 billion in cash and provide $2.5 billion in consumer relief. The cash portion of the settlement consists of a $4 billion civil monetary penalty payment to the DOJ pursuant to the financial institutions reform, recovery and enforcement act of 1989 (\"FIRREA\"), $208,250,000 to the FDIC and $291,750,000 to various state AGs. The settlement releases civil claims that could have been asserted under common law, FIRREA, the false claims act, the program fraud civil remedies act, the racketeer influenced and corrupt organizations act, the injunctions against fraud act, and various state statutes, including state securities laws.","ab":"Citigroup Inc.; Citigroup, Inc.","firms":[7059,119537],"id":2119},{"d":"2014-07-09","di":"2014-07-09","dr":"2014-07-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":21100.0,"dk":"2011027686301","al":"On July 9, 2014, Edward jones agreed to an acceptance, waiver and consent (AWC) with FINRA. Pursuant to the AWC, the firm will make restitution to sixteen public customers (in the amount of $9,784.25, plus interest) for failing to obtain the best execution price for trades occurring in 2011, in various government fixed income products. The firm will also pay a fine of $21,100.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2120},{"d":"2014-07-02","di":"2014-07-02","dr":"2014-07-02","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Office of Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":50220.17,"dk":"AP-14-11","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2121},{"d":"2014-06-30","di":"2014-06-30","dr":"2014-06-30","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois, Illinois Securities Department","san":"Restitution","os":"Notice of hearing","st":"Final","fine":2000000.0,"dk":"1200385","al":"From at least 2009 to 2013, LPL Financial failed to adequately maintain certain books and records documenting its variable annuity exchange business and failed to enforce its supervisory system and procedures in connection with the documentation of certain salespersons' variable annuity exchange activities. LPL Financial's conduct constitutes cause to impose sanctions pursuant to sections 8.E.1(e) and (q) of the Illinois securities law of 1953, [815 ilcs 5/1 et seq.,] (the \"act\") and violates section 12.a of the act.","res":"Consent","sm":"LPL entered into a consent agreement pursuant to which LPL paid a fine of $200,000 and restitution to investors meeting the consent agreement criteria.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2122},{"d":"2014-06-27","di":"2014-06-27","dr":"2014-06-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":12500.0,"dk":"20130358260-01","al":"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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2123},{"d":"2014-06-24","di":"2014-06-09","dr":"2014-06-24","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":18000.0,"dk":"2014-404B-007","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of may, 2014, Goldman Sachs international (\"GSI\") failed to submit seventy-two (72) single name and eight (8) index end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against gsi in the amount of of $18,000. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on July 17, 2014.","ab":"Goldman Sachs","firms":[361],"id":2124},{"d":"2014-06-24","di":"2014-06-09","dr":"2014-06-24","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3000.0,"dk":"2014-404B-008","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of may, 2014, Goldman, Sachs & co. (the \"firm\") failed to submit three (3) index end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against the firm in the amount of $3,000. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on July 17, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2125},{"d":"2014-06-20","di":"2014-06-19","dr":"2014-06-20","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"14-CH-1402","al":"Pursuant to an offer of settlement in which the firm neither admitted or denied the rule violation upon which the penalty is based, on June 19, 2014, the clearing house risk committee (the \"committee\") found that the firm violated CBOT rule 971.e - pre- approval requirements - disbursements not made for customer benefit.","res":"Settled","sm":"In accordance with the settlement offer, the committee fined the firm $25,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2126},{"d":"2014-06-20","di":"2014-06-20","dr":"2014-06-20","k":"Regulatory Action","rg":"Other","reg":"New York Office of the Attorney General","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":65370.17,"dk":"AOD NO. 14-126","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2127},{"d":"2014-06-18","dr":"2014-06-18","k":"Regulatory Action","rg":"State regulator","reg":"North Carolina Department of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":125175.05,"dk":"09SEC049","al":"Various state regulators, including the North Carolina Department of the Secretary of State, Securities Division, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the North Carolina Department of the Secretary of State, Securities Division, alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the North Carolina Department of the Secretary of State, Securities Division, on June 18, 2014, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $125,175.05 to the North Carolina Department of the Secretary of State, Securities Division, which amount was paid on June 26, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2128},{"d":"2014-06-16","di":"2014-06-16","dr":"2014-06-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, restitution","st":"Final","fine":8000000.0,"dk":"2011029999301","al":"This regulatory settlement is the result of matters that were self-reported by the firm and for which the firm previously made substantial voluntary customer restitution. Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that most of the mutual funds available on its retail platform offered waivers for up-front sales charges for returement plans and disclosed those waivers in their prospectuses, however, the firm failed to apply the waivers to certain eligible retirement plans that purchased shares of these mutual funds in brokerage accounts. The findings stated that since the 1980s, the firm offered a retirement account to small businesses known at the firm as the retirement cash management account 05 (rcma 05), maintained on the firm's retail brokerage platform. The firm therefore treated these accounts in the same manner as other retail customer accounts for purposes of determining share class eligibility for mutual fund purchases, rather than applying retirement plan-specified sales charge waivers. The firm failed to identify that most of the mutual funds available to rcma 05 accounts offered sales charge waivers to retirement plans and, as a result, disadvantaged retirement plan account participants. The firm later self-reported the matter to FINRA, and developed a remediation plan to restore disadvantaged customers to substantially the same financial position they would have been, if they had purchased class a shares without sales charges. The firm remediated approximately $58 million, including interest, to approximately 16,000 current and 12,000 former rcma 05 retirement plan accounts. Also, the firm will provide additional restitution to rcma 05 customers who purchased shares of 14 additional mutual fund families agreed to with FINRA. The firm estimates that the restitution will include approximately 13,000 accounts and will be approximately $21.2 million. The findings also stated that the firm offered 403(b) customers a retirement account called a retirement selector account (RSA). The firm later closed the RSA program to new 403(b) retirement accounts, and prohibited deposits of new assets for existing RSA accounts. Established RSA accounts could continue to buy and sell mutual funds with existing assets in their accounts. As with the rcma 05 program, the firm failed to apply available slaes charge waivers to these retirement accounts. The firm will provide restitution to 403(b) retirement accounts that purchased shares in three mutual fund families that qualified for, but did not receive, class a shares without sales charges. The firm estimates that the restitution will include approximately 3,178 RSA accounts and will be approximately $3.2 million. The firm will also voluntarily offer such retirement accounts only class a shares with sales charge waivers for all future mutual funds purchases. The findings also included that the firm disadvantaged charitable organizations that purchased shares of mutual funds by selling them class a shares with sales charges, or class b or class c shares that charged higher expense ratios than class a shares. The firm became aware of its failure to provide sales charge waivers to qualified charitable organizations accounts, and, it later, self-reported the issue to FINRA. The firm subsequently developed a plan to place disadvantaged customers in substantially the same financial positions they would have been in, had they purchased class a shares without a sales charge. (Cont. In comment section)","res":"Acceptance, Waiver & Consent(AWC)","sm":"This matter was self-reported under FINRA rule 4530. Before the regulatory action, the firm paid voluntary restitution to approximately 28,000 rcma 05 retirement plan accounts and 3,600 charitable accounts, totaling in excess of $64 million. And the firm remediated 1,505 charitable organization accounts more than $2.7 million, and it remediated an additional 2,119 charitable organization accounts nearly $4.1 million. FINRA found that the firm failed to establish and maintain an adequate supervisory system and written procedures to ensure that eligible accounts purchased class a shares with sales charge waivers when purchasing shares of certain mutual funds. The firm failed to maintain an adequate system and written procedures reasonably designed to identify applicable sales charge waivers in mutual fund prospectuses for charitable organizations. The firm maintained procedures for an annual review to identify potential net asset value (NAV) purchase privileges, but failed to identify this purchase privilege for charitable organization customers and communicate the information to its sales force, and did not have procedures in place to monitor whether financial advisors were informing customers of available mutual fund sales charge waivers or ensuring that eligible customers were receiving such waivers. The firm's policies and procedures concerning sales charge waivers were inadequate. The firm unreasonably relied on financial advisors to make appropriate determinations concerning mutual fund sales charges even after becoming aware of the problems related to the availablity class a shares at NAV. Thus, the firm failed to establish and maintain an adequate supervisory system and written procedures to identify class a mutual fund sales charge waivers in fund prospectuses, failed to adequately notify and train its financial advisors regarding mutual fund sales waiver eligibility requirements, and failed to have an adequate supervisory system to ensure that eligible accounts purchased class a shares with sales charge waivers.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2129},{"d":"2014-06-16","di":"2014-06-16","dr":"2014-06-16","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":35240.17,"dk":"N/A","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2130},{"d":"2014-06-05","di":"2014-05-20","dr":"2014-06-05","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"CBT-RSRH-13-1735","al":"CME Group, Inc. (\"CME\") market regulation alleged that Goldman, Sachs & co. (the \"firm\") submitted a position adjustment decreasing open interest in the June 2013 10-yr usd interest rate swap contract that resulted in an offset of contracts representing more than one percent of the reported open interest, in alleged violation of CBT rule 854.","res":"Consent","sm":"The firm consented to the imposition of a fine by the CME in the amount of $5,000, which was paid by submission of a wire on May 27, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2131},{"d":"2014-06-04","di":"2014-06-04","dr":"2014-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1000000.0,"dk":"2013037230001","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\"): (I) between 2004 and 2012, submitted to FINRA, the Securities and Exchange Commission (\"SEC\"), and other regulators, blue sheets that inaccurately reported certain short-sale transactions as long-sale transactions, and between November 2012 and January 2013, failed to include certain transactions in its blue sheets submissions to FINRA, each in alleged violation of section 17(a) of the securities and Exchange Act of 1934, as amended (the \"Exchange Act\"); rules 17A-4(j) and 17A-25 thereunder; NASD rules 8211, 8213, and 2110 (for inaccurate blue sheets submitted before December 15, 2008); and FINRA rules 8211, 8213, and 2010; and (II) between 2004 and 2013, did not have in place an adequate audit system providing for accountability of its blue sheet submissions, in alleged violation of section 17(a) of the Exchange Act and rule 17A-4(f)(3)(v) thereunder; NASD rule 2110 and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on June 4, 2014, and on June 18, 2014, the firm submitted a wire in payment of a fine in the amount of $1,000,000. The firm further agreed that it has conducted a review of its policies, systems and procedures relating to the deficiencies alleged in this AWC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2132},{"d":"2014-06-04","di":"2014-06-04","dr":"2014-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":1000000.0,"dk":"2013037904801","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it submitted at least 5,323 inaccurate blue sheets to various securities regulators, including the SEC and FINRA. The findings stated that the inaccurate blue sheets failed to include customer names and addresses for trades made on the day the customer opened a firm account. Between 2008 and January 2014, a trade could occur in a new customer's account before the customer's name and address data was fully populated. In such instances, the firm listed \"no name\" on the blue sheets associated with such trades. As a result of this problem, the firm submitted at least 2,980 inaccurate blue sheets to the SEC; 1,538 inaccurate blue sheets to FINRA; 733 inaccurate blue sheets to NYSE; and 72 inaccurate blue sheets to other regulators. The findings also stated that the firm failed to have in place an audit system reasonably providing for accountability of its blue sheet submissions and designed to ensure compliance with federal securities laws.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2133},{"d":"2014-06-02","di":"2014-06-02","dr":"2014-06-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":25000.0,"dk":"2010023976502","al":"Wells fargo advisors, LLC (\"WFA\") is the successor to Wells Fargo Investments, LLC (\"WFI\") (CRD-10582). The allegations solely involve WFI's dissemination of sales literature that failed to conform to the content standards of NASD rule 2210 and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC; Wells Fargo Investments,","self":true,"firms":[19616],"id":2134},{"d":"2014-05-19","di":"2014-05-19","dr":"2014-05-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"2013035797801","al":"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) block transactions in TRACE-eligible securities within 15 minutes of the time of execution.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2135},{"d":"2014-05-17","dr":"2014-05-17","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"13-1386","al":"CME Group, Inc. (\"CME\") market regulation alleged that Goldman, Sachs & co. (the \"firm\") failed to maintain a complete audit trail for a minimum of 5 years, in alleged violation of CME rule 536.B.2.","res":"Consent","sm":"The firm consented to the imposition of a fine by the CME in the amount of $10,000, which was paid by submission of a wire on May 19, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2136},{"d":"2014-05-15","di":"2014-05-15","dr":"2014-05-15","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2011026107601","al":"Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it entered orders into the Nasdaq market center that failed to correctly indicate whether the orders were a buy, short sale or long sale. As a result, the firm violated Nasdaq rule 4755.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2137},{"d":"2014-04-21","dr":"2014-04-21","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Kentucky Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":38020.17,"dk":"2014-AH-0021","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2138},{"d":"2014-04-16","di":"2014-04-16","dr":"2014-04-16","k":"Regulatory Action","rg":"NYSE","reg":"The New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":77500.0,"dk":"20120353783-01","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of market regulation, on behalf of The New York Stock Exchange LLC (\"NYSE\"), alleged that, during the period between April 1, 2009 and September 15, 2011, Goldman, Sachs & co. (the \"firm\"): (I) submitted certain trades with inaccurate account type indicators (ATIS) to the NYSE for comparison and/or settlement, in alleged violation of NYSE rule 132(a); and (II) failed to implement adequate systems and controls, including a separate system of follow-up and review, reasonably designed to achieve compliance with NYSE rule 132, in alleged violation of NYSE rule 342.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on behalf of the NYSE on April 16, 2014, and on May 5, 2014, the firm submitted a wire in payment of a fine in the amount of $77,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2139},{"d":"2014-04-14","di":"2014-04-14","dr":"2014-04-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"20110288572-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period of July 2010 through June 2011: (I) certain systems of Goldman, Sachs & co. (the \"firm\") failed to route intermarket sweep orders (ISOS) to bats y, edge a, and edge x, in alleged violation of SEC rule 611(a)(2); and that (II) the firm failed to implement reasonable procedures, including appropriate testing, to ensure that the order routing logic in certain trading systems was updated to account for all current market venues to which the firm routed orders to prevent trade-throughs of protected quotations in NMS stocks, in alleged violation of FINRA rule 2010 and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on April 14, 2014, and on April 28, 2014, the firm submitted a wire in payment of a fine in the amount of $15,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2140},{"d":"2014-04-07","di":"2014-04-07","dr":"2014-04-07","k":"Regulatory Action","rg":"Other","reg":"Consumer Financial Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; restitution; undertakings","st":"Final","fine":20000000.0,"dk":"2014-CFPB-0004","al":"On April 7, 2014, the Consumer Financial Protection Bureau (\"CFPB\") issued a consent order against Bank of America, National association and fia card services, national association. The order identified deficiencies in connection with fulfillment of customer processing concerning the provision of identity theft protection products as well as vendor and risk management protocols concerning so-called \"add-on\" products. In addition, the CFPB identified what it alleged were deceptive statements in connection with the marketing and sale of credit card debt cancellation products.","res":"Order","sm":"Without admitting or denying any findings of fact or violations of law or wrongdoing, Bank of America, National association and fia card services, national association consented to a civil monetary penalty of $20,000,000 and to cease and desist from engaging in further violations of law in connection with the marketing and administration of credit protection products and the billing and administration of identity protection products. Further, the consent order requires a restitution plan to be submitted to the CFPB and, following approval, the provision of restitution to borrowers. In addition, the consent order requires the submission of enhanced vendor management policies; enhanced risk management policies and procedures; and enhanced internal audit reviews of add-on products to assess unfair, deceptive, or abusive acts or practices (\"UDAAP\") risk.","ab":"Bank of America, National","firms":[142558],"id":2141},{"d":"2014-04-07","di":"2014-04-07","dr":"2014-04-07","k":"Regulatory Action","rg":"OCC","reg":"The Office of the Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; undertakings","st":"Final","fine":25000000.0,"dk":"AA-EC-2014-6","al":"On April 7, 2014, the Comptroller of the Currency of the United States of america (\"OCC\") issued a consent order against Bank of America, National association and fia card services, national association. The order identified deficiencies in connection with fulfillment of customer processing concerning the provision of identity theft protection products as well as vendor and risk management protocols concerning so-called \"add-on\" products.","res":"Order","sm":"Without admitting or denying the findings, Bank of America, National association and fia card services, national association consented to a civil monetary penalty of $25,000,000. Further, the consent order requires a restitution plan to be submitted to the OCC and, following approval, the provision of restitution to borrowers. In addition, the consent order requires the submission of enhanced vendor management policies; enhanced risk management policies and procedures; and enhanced internal audit reviews of add-on products to assess unfair, deceptive, or abusive acts or practices (\"UDAAP\") risk.","ab":"Bank of America, National","firms":[142558],"id":2142},{"d":"2014-03-31","di":"2012-10-09","dr":"2014-03-31","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services (DFS) District Attorney, New York County (Dany)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":60000000.0,"dk":"M 2012 0 00197126 (DANY)","al":"In 2009, alico and its outside counsel made certain representations in a letter to the New York state insurance department (the predecessor of DFS) concerning its operations in New York. It was alleged that contrary to these representations, alico and delam, subsidiaries of american international group (\"AIG\") until November 2010, and later of MetLife after November 2010, were doing insurance business in New York without a license. Further, it was alleged that, by conducting certain activities in New York, representatives on behalf of alico, delam, AIG and MetLife were soliciting insurance business without a license.","res":"Consent","sd":"$50,000,000 paid by MetLife, inc. to DFS [payment date - March 31, 2014] $10,000,000 paid by MetLife, inc. to dany [payment date - March 31, 2014]","sm":"Consent order with DFS, MetLife, alico and delam, effective March 31, 2014. Fine of $50,000,000 assessed against MetLife to be paid within seven days of effective date. Deferred prosecution agreement (the \"agreement\") signed by dany, MetLife, alico and delam on March 28, 2014. Payment of $10,000,000 to be made by MetLife. If compliance with the agreement for 24 months, the agreement shall expire and be of no further force and effect. As required by the consent order with DFS, representatives engaging in certain activities in New York must obtain an insurance license and an authorized insurer in New York must file certain information concerning issuance of coverage by insurers licensed outside the United States. MetLife, alico and delam are continuing to cooperate with a parallel investigation by the New York state office of the attorney general taxpayer protection bureau concerning alico and delam's New York state tax filings.","ab":"American Life Insurance","firms":[142463],"id":2143},{"d":"2014-03-26","di":"2014-03-26","dr":"2014-03-26","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":71380.17,"dk":"0273-SR-07/13","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2144},{"d":"2014-03-25","di":"2010-02-04","dr":"2014-03-25","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Bac agreed to pay the New York attorney general $15,000,000 (as costs of investigation and subsequent litigation) as well as","st":"Final","al":"The attorney general of the state of New York alleges that Bank of America corporation (\"BAC\"), its former CEO kenneth d. Lewis and its former CFO joseph l. Price engaged in acts and practices in connection with the merger (the \"merger\") between BAC and merrill lynch & co. inc. (\"merrill lynch\") that violated certain provisions of the New York general business law (the \"martin act\") and the New York executive law.","res":"Settled","ab":"Bank of America","firms":[142558],"id":2145},{"d":"2014-03-21","di":"2014-03-21","dr":"2014-03-21","k":"Regulatory Action","rg":"State regulator","reg":"State of South Dakota Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":46470.17,"dk":"N/A","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2146},{"d":"2014-03-17","di":"2012-08-02","dr":"2014-03-17","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000000.0,"al":"The New York State Department of Financial Services alleged that AXA Equitable Life insurance company violated New York insurance law section 4240(e) by filing plans of operation with respect to certain of its separate acccuonts with the New York state insurance department and New York State Department of Financial Services (collectively, the \"department\") without adequately informing and explaining to the department the significance of the implementation of the AXA tactical manager strategy.","res":"Consent","sd":"AXA Equitable Life insurance company consented to the imposition of a civil penalty on March 17, 2014 in the sum of $20,000,000, agreed to seek all necessary approvals with regard to New York insurance law section 4240(e) and agreed to provide departmentapproved communications to policyholders when AXA Equitable Life insurance company is revising fund choices in connection with the AXA tactical manager strategy and to comply with any other conditions placed on such approvals. AXA Equitable Life insurance company also agreed to issue a written report to the department concerning changes to the plan of operations for certain of its separate accounts on a quarterly basis for a period of five years from March 17, 2014.","sm":"The matter was settled on March 17, 2014, the date AXA Equitable Life insurance company entered into a consent order with the department consenting to the sanctions listed above. No information Filed","ab":"AXA Equitable Life","firms":[173027],"id":2147},{"d":"2014-02-27","di":"2014-02-27","dr":"2014-02-27","k":"Regulatory Action","rg":"Cboe","reg":"Business Conduct Committee of the Chicago Board Options Exchange, Incorporated (The \"Exchange\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"FILE NO. 13-0074","al":"In violation of CBOE exchange rule 3.6a, from January 21, 2012 through October 24, 2013, the applicant failed to properly register one associated person as a proprietary trader principal (TP) with the exchange in webcrd. In addition, from May 31, 2012 through October 10, 2012, the applicant failed to register its financial and operations principal as a financial and operations principal (FN) with the exchange in webcrd.","res":"Decision","sm":"Without admitting or denying that a violation of exchange rules had been committed, the applicant consented to a fine of $7,500 and a censure.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2148},{"d":"2014-02-27","di":"2013-12-11","dr":"2014-02-27","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Censure","os":"Fine","st":"Final","fine":20000.0,"dk":"13-0066","al":"Alleged non-registration of (1) a limited number of firm personnel in the categories of (a) proprietary trader, (b) proprietary trader principal and (c) proprietary trader compliance officer, and (2) the minimum number of individuals required to be registered as proprietary trader principal with the CBOE by November 5, 2011.","res":"Decision & Order of Offer of Settlement","sd":"Fine was $20,000 and it was paid on 3/20/14","sm":"Please see question 7.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2149},{"d":"2014-02-25","di":"2013-04-11","dr":"2014-02-25","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire, Department of State, Bureau of Securities Regulation","san":"Cease and Desist","os":"Monetary fine - see question 12.c.","st":"Final","fine":750000.0,"dk":"C-201200002","al":"The State of New Hampshire, Department of State, Bureau of Securities Regulation alleged that Edward jones violated N.H. Rsa 421- b:8, x, which requires Edward jones to comply with the rules of the Securities and Exchange Commission, FINRA, national and regional stock exchanges, and other self-regulating organizations which have jurisdiction over Edward jones. The alleged violations included that: 1) solicitation calls were being made in violation of applicable telephone solicitation rules; 2) Edward jones failed to properly train and supervise financial advisors in the area of telephone solicitation; and 3) Edward jones failed to establish a system and procedures reasonably designed to ensure compliance with applicable telephone solicitation rules.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2150},{"d":"2014-02-07","di":"2013-10-28","dr":"2014-02-07","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Disgorgement","st":"Final","fine":40000.0,"dk":"NYME 12-7457-BC","al":"On December 21, 2012, GMT Capital Corp. (\"GMT\") maintained an open futures equivalent position of 2,555 long January 2013 henry hub natural gas futures contracts which was 1,555 contracts (155.50%) over the standard expiration month limit in effect for trade dates December 24, 26, and 27, 2012. As a result, GMT was found to have violated rule 562.","res":"Settled","sd":"In accordance with the settlement offer, a panel of the NYMEX business conduct committee (the \"panel\") ordered GMT to pay a fine in the amount of $40,000 and to disgorge profits in the amount of $8,820, both of which were paid on February 21, 2014.","sm":"Pursuant to an offer of settlement GMT presented at a hearing on February 5, 2014, in which GMT neither admitted nor denied the rule violation upon which the penalty is based, the panel found that it had jurisdiction over GMT pursuant to NYMEX rule 418 and that on December 21, 2012, GMT maintained an open futures equivalent position of 2,555 long January 2013 henry hub natural gas futures contracts which was 1,555 contracts (155.50%) over the standard expiration month limit in effect for trade dates December 24, 26, and 27, 2012. GMT subsequently liquidated its overage position, resulting in profits of $8,820.00. The panel found that as a result, GMT violated rule 562. In accordance with the settlement offer, the panel ordered GMT to pay a fine to the exchange in the amount of $40,000 and to disgorge profits in the amount of $8,820. This action became final on February 5, 2014 and effective February 7, 2014. No information Filed","ab":"GMT Capital Corp.","self":true,"firms":[160404],"id":2151},{"d":"2014-01-31","di":"2014-01-03","dr":"2014-01-31","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2013-404B-57","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of December, 2013, Goldman Sachs international (\"GSI\") failed to submit seventy-two (72) single name end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against gsi in the amount of $10,000, which was billed in an ICE monthly clearing fee invoice dated January 31, 2014, and paid on February 20, 2014.","ab":"Goldman Sachs","firms":[361],"id":2152},{"d":"2014-01-31","di":"2014-01-03","dr":"2014-01-31","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"2013-404B-056","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of December, 2013, Goldman, Sachs & co. (the \"firm\") failed to submit two (2) index end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against the firm in the amount of $2,000, which was billed in an ICE monthly clearing fee invoice dated January 31, 2014, and paid on February 20, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2153},{"d":"2014-01-17","di":"2014-01-17","dr":"2014-01-17","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":45770.17,"dk":"2013-7-10","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2154},{"d":"2014-01-10","di":"2014-01-10","dr":"2014-01-10","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"2013-141/148","al":"In a notice of summary fine dated January 10, 2014, ICE Futures U.S., Inc. (\"ICE\") compliance department informed Goldman, Sachs & co. (the \"firm\") that on October 23, 2013, October 29, 2013, and November 20, 2013, certain block trades were reported late in alleged violation of ICE rule 4.07(c).","res":"Decision","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine in the amount of $1,500 which was paid by submission of a wire on February 3, 2014.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2155},{"d":"2014-01-10","di":"2014-01-10","dr":"2014-01-10","k":"Regulatory Action","rg":"Other","reg":"ICE Futures US","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":10000.0,"al":"A subcommittee of the exchange's business conduct committee determined that the firm may have violated exchange rule 27.21(b) by failing to expose one order for a minimum of five (5) seconds before entering the opposite order when executing a cross trade involving an exchange future contract.","res":"Settled","sm":"Without admitting or denying the violation of any exchange rules, the firm consented to a fine of $10,000 and to cease and desist from further violations of exchange rule 27.21(b).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2156},{"d":"2014-01-10","di":"2014-01-10","dr":"2014-01-10","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking","san":"Undertaking","st":"Final","fine":38925.17,"dk":"SB-CO-12-13","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2157},{"d":"2014-01-09","di":"2014-01-09","dr":"2014-01-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":200000.0,"dk":"2010022283702","al":"On January 9, 2014, FINRA alleged that Edward jones violated FINRA rule 2010 and NASD rules 2110, 2310, and 3010. FINRA alleged that, for almost a year and a half, Edward jones allowed its registered representatives to recommend nontraditional exchange traded funds (ETFS) to clients without first conducting reasonable due diligence concerning those products. FINRA also alleged that Edward jones did not train or adequately educate its registered representatives regarding nontraditional ETFS before permitting them to recommend them to clients and that Edward jones' registered representatives placed numerous nontraditional ETF transactions, at a combined value of approximately $164 million, in retail clients' accounts, during the period. FINRA alleged that certain Edward jones registered representatives recommended nontraditional ETFS to clients who had not indicated a desire to take aggressive risks with their accounts at Edward jones and that some of these clients held their nontraditional ETF positions for weeks or months at a time. FINRA asserted that nontraditional ETFS are typically not suitable for retail investors who plan to hold them for more than one trading session, particularly in volatile markets. FINRA alleged that Edward jones: (1) failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with applicable NASD or FINRA rules in connection with the sale of nontraditional ETFS; (2) failed to establish and maintain an adequate supervisory system to monitor transactions in nontraditional ETFS involving its retail clients; (3) did not exercise due diligence in investigating nontraditional ETFS; (4) did not ensure that its registered representatives obtained adequate information and instruction regarding nontraditional ETFS before recommending those products to clients; and (5) for the period, did not provide such information directly to registered representatives or require that they obtain it from other sources. FINRA also alleged that Edward jones' supervisory system was inadequate with respect to its oversight of nontraditional ETF transactions and until the time when FINRA issued regulatory notice 09-31, relied on its general supervisory procedures to oversee transactions in nontraditional ETFS. FINRA alleged that those procedures did not address the products' unique features and risks, E.G., Edward jones' sales-exception reports and other supervisory tools did not differentiate between exchanged-traded equity securities, traditional ETFS, and nontraditional ETFS. FINRA alleged that Edward jones' general supervisory procedures did not require it to monitor either the length of time clients held open positions in nontraditional ETFS or the effect of long holding periods on those positions.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2158},{"d":"2014-01-07","di":"2014-01-07","dr":"2014-01-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":45000.0,"dk":"2008014584702","al":"SEC rule 17A-3, NASD rule 3110 - Merrill Lynch, Pierce, Fenner & Smith's order memorandum for numerous transactions reflected only one order time. The firm maintained that the time stamp represented multiple order times (I.E., the order receipt, order entry and order execution times) because the decision to purchase the security, and the resultant execution, happened simultaneously or nearly simultaneously with one another. Because the order memoranda did not clearly identify that the time stamp represented multiple order events, FINRA determined that the firm failed to identify the order receipt, order entry and order execution times on brokerage order memoranda entered into its proprietary bond market order execution system to buy non- convertible preferred securities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $45,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2159},{"d":"2013-12-30","di":"2013-12-30","dr":"2013-12-30","k":"Regulatory Action","rg":"Other","reg":"The Singapore Stock Exchange","st":"Final","fine":1000.0,"dk":"N/A","al":"Alleged breach of Singapore exchange trade reporting rules.","res":"Decision","sd":"Fine was paid January 3, 2014","sm":"The Singapore exchange (SGX)alleged breaches of trade reporting rules for not reporting two off-market trades on June 12, 2013 and August 29, 2013 within 20 minutes of the opening on the next market day.","ab":"Instinet Singapore","firms":[7897],"id":2160},{"d":"2013-12-26","di":"2013-12-26","dr":"2013-12-26","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, civil and administrative penalty(IES)/fine(s)","st":"Final","fine":375000.0,"dk":"ADMINISTRATIVE PROCEEDING FILE NO. 3-15663","al":"On December 26, 2013, Instinet entered into a settlement, without admitting or denying any findings, with the U.S. Securities and Exchange Commission (\"SEC\"). The SEC found that Instinet, from January 2009 through July 2010, paid approximately $430,000 in client commission credits called \"soft dollars\" as requested by its customer, j.s oliver capital management, L.P. (\"JS oliver\"), a san diego-based investment adviser, for expenses that JS oliver had not properly disclosed to its clients. The SEC found that the improper payments included $329,365 to the ex-wife of JS oliver's president, ian o. Mausner; thirteen months of increased rent payments totaling $65,000 for JS oliver's offices at mausner's home; and two payments totaling $40,094.54 for upkeep on mausner's New York city timeshare.","res":"Settled","sd":"The settlement resulted in the SEC issuing an order instituting administrative and cease and desist proceedings pursuant to section 15(b) of the Securities Exchange Act of 1934 and section 203(k) of the Investment Advisers Act of 1940, making findings, and imposing remedial sanctions and a cease-and-desist order against Instinet on December 26, 2013 (the \"order\"). The order found that Instinet willfully aided and abetted and caused J.S. Oliver's violations of sections 206(2) and (4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder. Instinet was ordered to cease and desist from committing or causing any violations and any future violations of sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-8 thereunder and was censured. The order also required Instinet to pay disgorgement of $378,673.76, prejudgment interest of $59,607.66, and a civil money penalty in the amount of $375,000, which was paid on December 31, 2013. In addition, Instinet undertook to retain an independent consultant to (a) conduct a comprehensive review of Instinet's policies, procedures, and practices related to its payment of soft dollars as part of its client commission services (collectively, \"policies and procedures\"); and (b) make recommendations for changes in or improvements to the policies and procedures to prevent Instinet from aiding and abetting and causing an investment adviser's violations of sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-8 thereunder with respect to soft dollars.","sm":"In settlement of this action, Instinet, without admitting or denying any findings, consented to the SEC's entry of the order, the allegations, dispositions, findings and sanctions of which are described above in items 7 and 12.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2161},{"d":"2013-12-23","di":"2013-12-23","dr":"2013-12-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":20000.0,"dk":"2009020171701","al":"FINRA rule 2010, MSRB rules G-17, G-30(a) - Wells fargo advisors, LLC bought or sold municipal securities for its own account from customers and/or sold municipal securities to customers at an aggregate price (including any markup or markdown) that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer, or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer, or municipal securities is entitled to a profit, and the total dollar amount of the transaction. The firm sold agency bonds to its customers and failed to sell such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each at the time of the transaction, the expense involved, and that the firm was entitled to a profit.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2162},{"d":"2013-12-19","dr":"2013-12-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":95000.0,"dk":"2012032742901","al":"NYSE rules 123c, 132(a), 342(a) and (b), 2010, Wedbush Securities Inc. failed to comply with requirements governing the cancellation of market-on-close (MOC), limit- on-close (LOC) and closing offset (CO) orders on the NYSE, in that various direct market access and sponsored access (market access) customers to which the firm provided access to trade directly on the NYSE via a firm mnemonic had cancelled orders on the NYSE between 3:45 P.M. And 3:58 P.M. That were not the result of legitimate order errors. Firm market access customer trading via a firm mnemonic tested the connectivity of its electronic systems to the NYSE's systems in a manner inconsistent with established procedures by entering and sending to the NYSE LOC orders and cancellations, over different trade dates to purchase two stocks at a limit price of $.01, when the stocks had traded at $15 and $40, respectively; such orders were entered in the guise of actual orders without denoting each message as a test order or cancellation. By permitting its market access customer to test its electronic order routing systems' connectivity to the NYSE's systems in a manner inconsistent with established NYSE procedures, the firm failed to observe high standards of commercial honor and just and equitable principles of trade in the conduct of its business. The firm had no written supervisory procedures or systems, including a separate system of follow-up and review, reasonably designed to ensure compliance with NYSE rule 123c with respect to MOC, LOC and CO orders entered and cancelled by firm market access customers. The firm, through two market access customers which were non-member organizations unaffiliated with the firm, submitted for comparison or settlement numerous transactions via a firm mnemonic that were erroneously marked with a \"p\" account type indicator code, when such orders should have been marked with an \"a\" account type indicator code. The firm had no written supervisory procedures or systems, including a separate system of follow-up and review, reasonably designed to ensure compliance with NYSE rule 132 with respect to account type indicator codes on orders entered on the NYSE by firm market access customers.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $95,000 and required to revise its supervisory systems regarding a separate system of follow-up and review, reasonably designed to ensure compliance with NYSE rule 123c with respect to moc,loc and co orders entered and cancelled by firm market access customers and a separate system of follow-up and review, reasonably designed to ensure compliance with NYSE rule 132 with respect to account type indicator codes on orders entered on the NYSE by firm market access customers within 30 business days of acceptance of this AWC by FINRA's office of disciplinary affairs. Fine was paid January 14, 2014.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2163},{"d":"2013-12-12","di":"2013-12-12","dr":"2013-12-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure; disgorgement; prejudgment interest; civil money penalty","st":"Final","fine":56286000.0,"dk":"3-15642","al":"Pursuant to an offer of settlement made by Merrill lynch, fenner, pierce & smith incorporated (\"Merrill lynch\"), on December 12, 2013 the SEC issued an order (\"order\") stating that Merrill lynch violated the federal securities laws in connection with its structuring and marketing of a series of collateralized debt obligation transactions (\"CDOS\") in 2006 and 2007. According to the order, Merrill lynch failed to inform investors in two CDOS that a hedge fund firm that bought the equity in the transactions but whose interests were not necessarily the same as those of the CDOS' other investors, had undisclosed rights relating to, and exercised significant influence over, the selection of the CDOS' collateral. The order stated that, as a result of its conduct, Merrill lynch violated sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933 (\"Securities Act\") and section 17(a)(1) of the Securities Exchange Act of 1934 (\"Exchange Act\") and rule 17A-3(a)(2) thereunder. Merrill lynch consented to the entry of the order without admitting or denying the findings therein. The order is not binding on any person or entity other than Merrill lynch.","res":"Order","sm":"On December 12, 2013, the SEC issued the order, and included the allegations described above in item 7. Merrill lynch agreed to consent to the entry of the order, without admitting or denying the findings contained therein (other than those relating to jurisdiction and the subject matter of the proceedings). The payment was made on December 17, 2013. The sanctions imposed are explained above in item 12.c.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2164},{"d":"2013-11-20","di":"2010-06-23","dr":"2013-11-20","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"al":"The Nebraska department of banking and finance alleged that Edward jones: (1) failed to maintain true and accurate records; and (2) failed to maintain required books and records. The allegations stem from a single financial advisor's handling of her minor child's custodial account.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2165},{"d":"2013-11-18","di":"2011-08-11","dr":"2013-11-18","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Money damages","st":"Final","al":"The lawsuit alleges that The Bank of New York Mellon corporation (\"BNY mellon\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by BNY mellon. The registrant is not a defendant to this action.","res":"Dismissed","ab":"The Bank of New York Mellon","firms":[231],"id":2166},{"d":"2013-11-18","di":"2013-11-18","dr":"2013-11-18","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12500.0,"dk":"2009016999902","al":"Nasdaq rules 4611(a)(6), 4755 - Merrill Lynch, Pierce, Fenner & Smith Incorporated entered proprietary orders to sell short into the Nasdaq market center that incorrectly identified the orders as long. The firm entered one proprietary order to sell long into the Nasdaq market center that incorrectly identified the order as short. The firm entered orders into the Nasdaq market center that failed to indicate the correct capacity.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $12,500.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2167},{"d":"2013-11-18","di":"2013-11-18","dr":"2013-11-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":35000.0,"dk":"2009016999901","al":"SEC rules 200(g) of Regulation SHO, 605 of regulation NMS, FINRA rules 6182, 6624, 7450 - Merrill Lynch, Pierce, Fenner & Smith Incorporated executed short sale transactions for which it failed to report each of these transactions to the FINRA/Nasdaq trade reporting facility (FNTRF) with the correct symbols indicating that the transactions were sell short. The firm executed long sale transactions for which it failed to report each of these transactions to the over-thecounter (OTC) reporting facility with the correct symbols indicating that the transactions were proprietary long sales. The firm transmitted reports to the order audit trail system (OATS) that incorrectly submitted a special handling code; submitted an erroneous desk report; incorrectly submitted a customer instruction flag; incorrectly submitted a desk report and failed to submit a new order report; incorrectly submitted an execution to reflect the execution of an order; failed to submit OATS data for an order; and failed to submit routing reports to OATS to reflect the route of the order to outside market centers. The firm incorrectly classified an order as covered for purposes of SEC rule 605 order execution disclosure. For one month, the firm made available a report on the covered orders in national market system securities it received for execution from any person which included incorrect information as to the amount of market center executed shares and away executed shares for various order type/size categories. The firm's report erroneously stated that all of the shares were executed at the market center by the firm, when they were in fact executed by an outside market center. The firm executed short sale orders and failed to properly mark the orders as short and executed one long sale order and failed to properly mark the order as long.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $35,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2168},{"d":"2013-11-18","di":"2013-11-18","dr":"2013-11-18","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":5000.0,"dk":"2011028036801","al":"FINRA rule 2010, NASD interpretative material 2110-2 - Wells fargo advisors,LLC failed to contemporaneously execute customer limit orders in 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.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2169},{"d":"2013-11-11","di":"2013-11-11","dr":"2013-11-11","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"RSRH-13-1419-1480-1481","al":"CME Group, Inc. (\"CME\") market regulation found reporting infractions with respect to J. Aron & Company's (the \"company\") reporting of certain block trades, including: (I) late reporting of certain block trades to the chicago mercantile exchange during March and April, 2013; (II) entering trades into the CME clearport platform on one date as outright transactions where it appeared from audit trail documents they were spread transactions and with execution times not supported by such supporting documents; and (III) reporting a block transaction to the New York mercantile exchange (NYMEX) facilitation desk, while audit trail documents suggested that the order was executed in increments, each in alleged violation of CME rule 526.f.","res":"Consent","sm":"The CME imposed a fine in the amount of $2,500, which was paid by submission of a wire on November 19, 2013.","ab":"J. Aron & Company","firms":[361],"id":2170},{"d":"2013-11-06","di":"2013-11-06","dr":"2013-11-06","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"2013-404B-015","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of July 2013, Goldman, Sachs & co. (the \"firm\") failed to submit one (1) index end of day price in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Decision","sm":"ICE made a summary assessment against the firm of $1,000, which was made final on November 6, 2013. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on December 19, 2013.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2171},{"d":"2013-11-04","di":"2013-10-03","dr":"2013-11-04","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2013-404B-020","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of September, 2013, Goldman Sachs international (\"GSI\") failed to submit eighteen (18) single name end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against gsi of $10,000, which was made final on November 4, 2013. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on November 20, 2013.","ab":"Goldman Sachs","firms":[361],"id":2172},{"d":"2013-10-31","dr":"2013-10-31","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":34070.17,"dk":"LS-13-0732","al":"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.","res":"Order","sm":"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.","ab":"RBC Capital Markets, LLC","self":true,"firms":[31194],"id":2173},{"d":"2013-10-30","di":"2013-10-30","dr":"2013-10-30","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; undertaking","st":"Final","fine":500000.0,"dk":"2012-0113","al":"The Massachusetts Securities Division alleges that the applicant failed to reasonably supervise a former agent in violation of M.G.L. C. 110a, §204(a)(2)(j).","res":"Order","sm":"Without admitting or denying the alleged violations of law, the applicant consented to the entry of a consent order, paid a civil penalty of $500,000, agreed to offer reimbursement to five current or former clients, agreed to certify that it has reviewed its policies and procedures with regard to the monitoring of employee accounts, agreed to a censure, and agreed to cease and desist from violating M.G.L. C. 110a, §204(a)(2)(j).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2174},{"d":"2013-10-24","di":"2013-10-24","dr":"2013-10-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; restitution; undertaking","st":"Final","fine":85000.0,"dk":"2009020108201","al":"SEC rules 204(a)(1), SEC rule 200(g) of Regulation SHO, SEC rule 605 of regulation NMS, FINRA rules 2010, 7230a, 7450, NASD rules 2110, 3010, 3340, interpretive material 2110-2 - Merrill lynch effected securities transactions while a trading halt was in effect with respect to the securities. The firm transmitted reports to the order audit trail system (OATS) that contained an inaccurate originating department id, submitted erroneous desk reports, submitted reports with an incorrect special handling code, erroneous handling codes, incorrect order received time, incorrect limit price, submitted reports without a reporting exception code, incorrectly submitted a new order report and route reports, and failed to submit a route report. The firm made available a report on the covered orders in national market system securities it received for execution from any person which included incorrect information. The firm incorrectly classified a covered order as not covered and calculated and reported an incorrect amount of total covered orders, covered shares, and total cancelled shares. The firm failed to report to the FINRA/Nasdaq trade reporting facility (FNTRF) the correct symbol indicating the related market center in transactions in reportable securities. The firm failed to report the exercise of an over-the-counter (OTC) option. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules addressing quality of market topics. The firm's written supervisory procedures (WSPS) failed to provide for minimum requirements for adequate WSPS in trade reporting (use of trade modifiers, third party reporting); OATS (accuracy of data); and multiple market participant identifiers (approval of mpids). The firm had fail-to-deliver positions at a registered clearing agency in an equity security that resulted from a long sale, and did not close the fail-to-deliver positions by purchasing securities of like kind and quantity within the time frame prescribed by SEC rule 204(a)(1). The firm executed short sale orders and failed to properly mark the orders as short. The firm failed to contemporaneously or partially execute customer limit orders in a Nasdaq security after it traded each subject order for its own market-making account at a price that would have satisfied each customer's limit order. The firm failed to report complete and accurate data to the FNTRF in transactions in reportable securities. The firm incorrectly reported an agency cross transaction as a principal transaction with a blank contra party; failed to report the contra party broker-dealer on principal trades; reported an incorrect buy/sell indicator; failed to report the correct execution time; and failed to timely submit non-tape reports with the .RX modifier.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $85,000, required to pay $77.98, plus interest, in restitution and required to revise its WSPS regarding trade reporting (use of trade modifiers, third party reporting); OATS (accuracy of data); and multiple market participation identifiers (approval of mpids).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2175},{"d":"2013-10-24","di":"2013-10-24","dr":"2013-10-24","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade Business Conduct Committee","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":190000.0,"dk":"CBOT 09-06299-BC AND CBOT 10-7427-BC","al":"Between June 5, 2009 and May 17, 2012, applicant executed block trades for customers in CBOT interest rate futures contracts that were not reported to the Chicago board of trade (\"CBOT\") within the applicable time limit following execution. In addition, applicant misrepresented the true and accurate time of execution of block trades to the CBOT thereby violating legacy CBOT rules 526.f and 432.I. Further, applicant failed to maintain accurate written or electronic records of the block trade transactions (specifically, the order tickets and other records applicant employed to record block trades contained inaccurate timing information) and did not have accurate and reliable time-keeping mechanisms in place upon which to base the time of execution in violation of CBOT rule 536. By failing to diligently supervise its employees or agents in the conduct of applicant's business relating to the CBOT as outlined above, the applicant violated legacy CBOT rule 432.w.","res":"Decision","sm":"Without admitting or denying the rule violations, the applicant consented to the entry of the CBOT's decision and agreed to pay a fine of $190,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2176},{"d":"2013-10-24","di":"2013-10-24","dr":"2013-10-24","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange Business Conduct Committee","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":60000.0,"dk":"CME 10-7427-BC","al":"Between June 4, 2009 and August 8, 2011, applicant executed block trades for customers in the eurodollars futures market that were not reported to the Chicago mercantile exchange (\"CME\") within the applicable time limit following execution. In addition, applicant misrepresented the true and accurate time of execution of block trades to the CME thereby violating legacy CME rules 526.f and 432.I. Further, applicant failed to maintain accurate written or electronic records of the block trade transactions (specifically, the order tickets and other records applicant employed to record block trades contained inaccurate timing information) and did not have accurate and reliable time-keeping mechanisms in place upon which to base the time of execution in violation of CME rule 536. By failing to diligently supervise its employees or agents in the conduct of the applicant's business relating to the CME as outlined above, the applicant violated legacy CME rule 432.w.","res":"Decision","sm":"Without admitting or denying the rule violations, the applicant consented to the entry of the CME's decision and agreed to pay a fine of $60,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2177},{"d":"2013-10-22","di":"2013-10-22","dr":"2013-10-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"20110284031-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that (I) during the period of January 1, 2011 through March 31, 2011, Goldman, Sachs & co. (the \"firm\"): (I) failed to report to the trade reporting and compliance engine (\"TRACE\") the correct time of trade execution for certain P1 transactions in TRACE-eligible securities, in alleged violation of FINRA rule 6730(c)(8); (II) reported to TRACE certain P1 transactions in TRACE-eligible securities that it was not required to report, in alleged violation of FINRA rule 6730; (III) failed to show the correct time of execution on the memorandum of certain brokerage orders, in alleged violation of SEC rule 17A-3 and NASD rule 3110; and (IV) failed to report to TRACE the correct contra-party's identifier for certain transactions in TRACE-eligible securities, in alleged violation of FINRA rule 6730(c)(6).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on October 22, 2013, and on November 7, 2013, the firm submitted a wire in payment of a fine in the amount of $25,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2178},{"d":"2013-10-16","di":"2013-10-16","dr":"2013-10-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":95000.0,"dk":"2009018146101","al":"MSRB rules G-8, G-14, and G-27, FINRA rules 2010 and 2110(a), and NASD rule 2320: the firm failed to execute orders fully and promptly and in transactions for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter- dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. The firm failed to report information regarding purchase and sale transactions in municipal securities to the real-time transaction reporting system (RTRS) in the manner prescribed by rule G-14 RTRS procedures and the RTRS user's manual; the firm failed to report the correct time of trade to the RTRS in municipal securities transactions, and failed to report information the transactions within 15 minutes of time of trade to an RTRS portal. The firm failed to show the correct time of execution on the memorandum of municipal securities transactions for the account of the firm executed with another broker or dealer. The firm improperly reported information to the RTRS that it should not have; the firm improperly reported purchase and sale transactions in municipal securities to the RTRS, when the inter-dealer delivers were step outs and thus were not inter-dealer transactions reportable to the RTRS. The firm failed to enforce its written supervisory procedures, which specified that the firm would perform daily reviews of trades on the MSRB website for accuracy and timeliness and monthly reviews of the firm's MSRB reports cards.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore it is censured and fined $95,000 ($15,000 for violations of NASD rule 2320, FINRA rule 2010, and FINRA rule 2111(a), $67,500 for violations of MSRB rule G-14, $7,500 for violations of MSRB rule G-8, and $5,000 for violations of MSRB rule G-27).","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2179},{"d":"2013-10-07","di":"2013-09-27","dr":"2013-10-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":87500.0,"dk":"2009016641301","al":"FINRA rules 2010, 4560, 6380a(a), 6730(a), NASD rules 2110, 3010, 3360, NYSE rule 421 - Wedbush Securities Inc., during a two-year short interest review period, submitted inaccurate short interest position reports to FINRA and also failed to report short interest positions. During a two-year short interest review period, the firm submitted inaccurate short interest position reports to FINRA which included short interest positions for certain Nasdaq, NYSE, NYSE AMEX, NYSE ARCA, and over-the-counter (OTC) equity securities. During a trade reporting review period, the firm failed, within 90 seconds after execution, to transmit to the FINRA/Nasdaq trade reporting facility (FNTRF) last sale reports of transactions in national market system (NMS) securities. This conduct constitutes separate and distinct violations of FINRA rule 6380a(a) and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010. The firm failed to report to the trade reporting and compliance engine (TRACE) transactions in TRACE-eligible agency debt securities within 15 minutes of the execution time. This conduct constitutes separate and distinct violations of FINRA rule 6730(a) and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $87,500 and required to revise its written supervisory procedures regarding short interest position reports within 90 days of acceptance of this AWC by the nac.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2180},{"d":"2013-09-26","di":"2013-09-26","dr":"2013-09-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"2011025580202","al":"MSRB rule G-34: the firm made adjustments to its auction rate security system logic to conform to amendments to MSRB rule G-34 and G-8. As a result of an error in this process, the firm began misreporting to the SHORT term obligation rate transparency system (SHORT) that interest rates associated with various auction rate securities (ARS) committee on uniform security identification procedures (CUSIPS) were triggered by auction rather than by resets to the maximum interest rates associated with those CUSIPS. Out of the 451 reports the firm made to SHORT, 373 (82.7 percent) erroneously stated that the interest rates associated with the CUSIPS being reported were set by auction. In fact, no auction had occurred with respect to any of the 373 CUSIPS that were the subject of the erroneous reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore it is censured and fined $10,000 ($10,000 of which pertains to the violation of MSRB rule G-34).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2181},{"d":"2013-09-23","di":"2013-09-23","dr":"2013-09-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":325000.0,"dk":"2011027434101","al":"FINRA rule 2010 and NASD rules 2110 and 2711 and 2711(I): as a result of the acquisition of Merrill lynch & co., inc. by bank of america corporation, the research department of Merrill Lynch, Pierce, Fenner & Smith Incorporated (firm) was required to consider both entities' relationship with the companies that were the subject of the research report (covered companies) in determining which required disclosures to include in research reports issued by the firm. As a result of the compressed timeline of the acquisition, the firm still used separate systems from each entity after the acquisition, and research and technology teams from the two entities were required to aggregate information about the two entities' respective relationships with covered companies in order to generate complete and accurate required disclosures in research reports. However, errors occurred in this aggregation process that was not discovered by the firm for 18 months. An upstream company file that was used to match companies covered by the firm's research department with the company revenues and client relationships included inaccurate data, and the process designed to update that file failed. As a result, the company information used by the firm's research data repository to determine disclosures was stale and resulted in the omission of required disclosures in approximately 19,200 research reports. An additional disclosure deficiency began on an undetermined date through October 2010, when a third-party vendor provided incomplete data to the firm related to 22 covered companies. As a result of the incomplete data, an undetermined number of research reports relating to the 22 covered companies failed to disclose whether the firm had managed or co-managed a public offering of the covered company's securities in the past 12 months. The missing data was discovered and corrected, but it has not been determined when the disclosure deficiency began or how many research reports were impacted by it. A new third-party vendor began providing the firm with stock price information that contained incorrect data related to certain covered companies that had been impacted by a stock split. The data problem occurred in each monthly file that the firm received from the vendor since September 2008 through March 2011, and impacted as a many as 13,778 fundamental equity research reports. As a result of the data problem, an undetermined but significant number of these reports included a price chart that retroactively adjusted the historical stock price of the covered company to reflect a subsequent stock split but did not provide the same retroactive adjustment to the historical price targets included in the chart. As a result, impacted price charts showed a distorted relationship between the historical stock prices and the historical price target. These errors were also reflected on the firm's price charts website during this period. Although the firm's research department had policies, procedures, and testing practices (procedures) with respect to research disclosures and price charts during the time period of the violations, the procedures focused on the downstream aspects of the research report creation process. The procedures did not effectively evaluate the accuracy of the data provided by internal and external data sources to the research department through the research data repository, but rather were intended to ensure that the data was accurately and completely reflected on research reports. The procedures included separate steps for research analysts (who assembled","res":"Acceptance, Waiver & Consent(AWC)","sm":"(Continued from item 7.) And because the disclosure and price chart failures were caused by inaccuracies in underlying data, the procedures were ineffective in identifying the disclosures and price chart deficiencies. Because the procedures were not designated to evaluate the underlying accuracy of the data from internal and external data sources in the research data repository, and because the disclosure and price chart failures were caused by inaccuracies in underlying data, the procedures were ineffective in identifying the disclosures and price chart deficiencies. The firm also did not have procedures designed to ensure that third party pricing information used for price charts was accurate as it related to corporate actions affecting the price of stock and such adjusted prices were accurately reflected on the price chart. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore it is censured and fined $325,000. In determining the sanctions in this matter, FINRA took into consideration several factors: (1) the firm promptly self-reported all of the deficiencies set forth in this AWC: (2) the firm took significant remedial action to prevent the reoccurrence of these deficiencies: and (3) in early 2011, the firm engaged an independent consultant for a 22 month period to assist an internal task force with, among other things, introducing new technologies and processes designed to remedy the problems that had been caused by inaccurate upstream data.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2182},{"d":"2013-09-16","di":"2013-09-16","dr":"2013-09-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Disgorgement, prejudgment interest, civil monetary penalty.","st":"Final","fine":65000.0,"dk":"FILE NO. 3-15484","al":"Talkot Capital, LLC received a request for information from the SEC in June 2013 relating to compliance with rule 105 of Regulation M under the Securities Exchange Act of 1934. One inadvertent violation of rule 105 in 2010 was identified.","res":"Decision & Order of Offer of Settlement","sm":"The SEC entered an order on September 16, 2013, accepting an offer of settlement by Talkot Capital, LLC. the firm made payments due on September 18, 2013. No fund or other client of Talkot Capital, LLC bore any portion of such payments or any costs resolving the matter. No information Filed","ab":"Talkot Capital, LLC","self":true,"firms":[164231],"id":2183},{"d":"2013-09-12","di":"2013-09-12","dr":"2013-09-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":150000.0,"dk":"2012031047501","al":"FINRA rule 2010, NASD rules 3010 and 3012(a)(2)(b)(I): Wells fargo's supervisory control system failed to include a policy or procedure requiring a review to detect or prevent multiple transmittals of funds from multiple customers going to the same third party accounts. The firm's system also failed to include exception reports that would have identified multiple customer wires going to the same third party account. Consequently, Wells fargo failed to detect that a registered representative had initiated fund transfers, totaling approximately $258,000, out of two customer accounts, to bank accounts that she or her family member apparently controlled. Wells fargo failed to establish, maintain and enforce a supervisory system that was reasonably designed to adequately review and monitor the transmittals of funds from the accounts of customers to third party accounts and outside entities.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2184},{"d":"2013-09-10","di":"2013-09-10","dr":"2013-09-10","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance, Securities and Banking (The \"Department\")","san":"Cease and Desist","st":"Final","fine":15000.0,"dk":"SB-05-13","al":"An agent of the applicant failed to furnish a client material information that the client was entitled to on a timely basis in violation of 26 DCMR b 119.2(u). As a result of the agent's conduct, the applicant violated just and equitable standards of conduct (FINRA rule 2010), in violation of 26 DCMR b 119.2 (BB).","res":"Settled","sm":"Without admitting or denying the statement of facts and conclusions of law, the applicant consented to the entry of the administrative settlement agreement, paid $15,000 to the District of Columbia's general fund, and shall cease and desist from violating 26 DCMR b 119.2 (BB).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2185},{"d":"2013-08-20","di":"2012-12-21","dr":"2013-08-20","k":"Regulatory Action","rg":"Other","reg":"Consob","st":"Final","fine":163979.61,"dk":"N/A","al":"Alleged breach of italian short sale regulation","res":"Decision","sd":"Fine was paid 9/24/13 (120,000.00 euro)","sm":"Consob alleged breaches of italian short sale regulations in connection with the untimely settlement of transactions between January 9, 2012 and January 20, 2012 by an indirect client of iel.","ab":"Instinet Europe Limited","firms":[7897],"id":2186},{"d":"2013-08-05","di":"2013-08-05","dr":"2013-08-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17000.0,"dk":"2012032501601","al":"FINRA rule 6760(c): the firm, as managing underwriter (under the \"bofa\" MPID and \"mlco\" MPID), failed to timely report new issue offerings in trade reporting and compliance engine® (TRACE®)­eligible securities to FINRA in accordance with the requirements of FINRA rule 6760(c). The 89 new issue offerings constituted 70 percent of the 127 new issue offerings in TRACE-eligible securities under the \"bofa\" MPID and the 28 new issue offerings constituted 11 percent of the 260 new issue offerings in TRACE- eligible securities under the \"mlco\" MPID that the firm had an obligation to provide to FINRA pursuant to FINRA rule 6760.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore the firm is censured and fined $17,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2187},{"d":"2013-07-31","di":"2013-07-31","dr":"2013-07-31","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division of the Office of the Secretary of State (\"Division\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":500000.0,"dk":"AP-13-14","al":"The division found Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPF&s\") failed to supervise a Missouri-registered agent employed by MLPF&s who engaged in dishonest and unethical practices in violation of section 409.4-212(d)(13), rsmo. (Cum. Supp. 2011). MLPF&s is subject to discipline for failing to reasonably supervise the registered agent's activities pursuant to section 409.4-412(d)(9) rsmo. (Cum. Supp. 2011).","res":"Consent","sm":"Without admitting or denying the allegations made by the division, MLPF&s is censured. In addition MLPF&s shall compensate clients for any funds improperly withdrawn or transferred from any MLPF&s client accounts by the registered agent; shall not seek to collect on any client lma balance that was incurred as a result of the registered agent's fraudulent activities; and shall pay the sum of $500,000 to the Missouri secretary of state's investor education and protection fund within 10 days of effective date of the consent order. As of July 12, 2013, MLPF&s has compensated $89,055.67 to MLPF&s client accounts and has written off lma balances for the MLPF&s client accounts totaling approximately $1,532,524. This matter was self-reported to the division by MLPF&s.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2188},{"d":"2013-07-11","di":"2013-07-11","dr":"2013-07-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii - Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":894556.11,"dk":"SEU-2008-016, SEU-2008-55, SEU-2008-071","al":"The commissioner of securities of the state of Hawaii (commissioner) alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated's (MLPFS) conduct in connection with the marketing and sale of auction rate securities (ARS) to retail and other customers violated Hawaii revised statutes (HRS) section 485-15(7) solely to the extent that it concerns dishonest or unethical practices and HRS section 485-15(10) for failure to supervise.","res":"Settled","sm":"Under the terms of the settlement, MLPFS agreed to undertakings designed to provide liquidity to eligible investors. MLPFS has offered to purchase at par from eligible investors certain ars that have failed at auction. MLPFS has also agreed to pay those eligible investors that MLPFS can reasonably identify who sold certain ars below par, the difference between par and the price at which they sold such securities. MLPFS has also agreed to participate in a special arbitration process for the purpose of arbitrating any eligible investor's consequential damages claim arising from their inability to sell certain ars. Furthermore, MLPFS agreed to refund refinancing fees to certain municipal issuers that issued and refinanced certain ars through MLPFS. MLPFS will also endeavor to work with issuers and other interested parties to provide liquidity solutions for institutional investors that purchased certain ars from MLPFS but are not considered \"eligible investors\" and are not entitled to participate in the ars buyback under the terms of the settlement.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2189},{"d":"2013-07-03","di":"2013-06-06","dr":"2013-07-03","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2013-404B-008","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of may, 2013, Goldman Sachs international (\"GSI\") failed to submit nine (9) single name end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against gsi of $10,000, which was made final on July 3, 2013. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid on July 17, 2013.","ab":"Goldman Sachs","firms":[361],"id":2190},{"d":"2013-07-02","di":"2013-07-02","dr":"2013-07-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":35000.0,"dk":"2011026083001","al":"Wells fargo advisors, LLC is the successor of Wells fargo investments. The allegations relate soley to Wells fargo investments, LLC (CRD-10582)and transactions affected by it, prior to January 2011, when it ceased doing business. FINRA rule 2010: in 25 transactions, the firm purchased agency securities for its own account from a customer and/or sold agency securities for its own account to a customer in the course of its business at an aggregate price that was not fair and reasonable, and in so doing failed to observe high standards of commercial honor and just and equitable principles of trade.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2191},{"d":"2013-06-25","di":"2012-03-30","dr":"2013-06-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":750000.0,"dk":"20070077690","al":"OATS non-reporting,late reporting and supervision NASD rule 6955/FINRA rule 7450, NASD rule 2110 and 3010/FINRA rule 2010, NASD rule 1021 and 1031 failure to register an individual as a general securities principal.","res":"Decision & Order of Offer of Settlement","sd":"Without admitting or denying the allegations, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $750,000 and required to retain within 30 days of the order accepting the offer of settlement, an independent consultant (IC) to conduct a comprehensive review of the firm's policies, systems, controls, procedures (written and otherwise), and training related to OATS reporting and the firm's supervision of OATS reporting. At the conclusion of the review which shall be no more than 120 days after the date of the order, the IC shall submit an initial report to the firm and FINRA which shall include recommendations relating to OATS reporting and the firm's supervision of OATS reporting. Within 60 days after delivery of the initial report, the firm shall adopt and implement the IC's recommendations or propose alternative procedures. Within 30 days, the IC shall evaluate the alternative procedures and provide the firm and FINRA with a written decision reflecting his/her determination. The firm will abide by the IC's ultimate determination, adopt and implement all recommendations. Within 30 days, the firm shall provide FINRA with a written implementation report, certified by a firm officer. The IC shall conduct a follow-up review and submit a written final report no later than one year from the date of the order. Within 30 days of receipt of the IC's final report, the firm shall adopt and implement the final report's recommendations.","sm":"The firm submitted an offer of settlement without admitting or denying the alleagtions on May 2, 2013. The offer was accepted by the hearing board and the FINRA nac on June 25, 2013.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2192},{"d":"2013-06-25","di":"2013-06-25","dr":"2013-06-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":72500.0,"dk":"2009017002603","al":"SEC rules 10B-10, 17A-3, SEC rule 605 of regulation NMS, SEC rule 200(g) of Regulation SHO, FINRA rules 2010, 6182, NASD rules 3010, 3110 Wedbush Securities Inc. failed to provide written notification disclosing to its customers its correct capacity in transactions and the reported price. The firm made available reports on the covered orders in national market system (NMS) securities it received for execution from any person. The reports included incorrect information as to order type and size categories. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and/or FINRA rules addressing quality of market topics. The firm's written supervisory procedures (WSPS) failed to provide for minimum requirements for adequate WSPS in order handling (disclosure of order routing information); trade reporting (riskless principal trades reporting on firm's behalf, accurate reporting by third party); sales transactions (determining and marking sales as long or short)(prompt delivery of sales transactions by settlement); (pre- borrowing in aged fails, accepting short sale orders after an aged fail occurs, naked short selling antifraud rule, reporting short sale indicators, reporting sales as long or short); prompt delivery of sales transactions by settlement; and other rules (books and records). The firm failed to provide evidence of supervisory review for trade reporting (riskless principal trades, riskless principal trades reporting on firm's behalf) (order entry into Nasdaq) (accurate reporting by third party); and other rules (books and records). The firm failed to provide written notification disclosing to its customers its correct capacity in transactions and the correct price and the average price details. The firm failed to properly mark sell orders as short and, as a result, failed to report transactions in reportable securities to the trade reporting facility with a short sale indicator. The firm failed to show the correct order entry time and the correct long/short sale indicator in its proprietary trading ledger.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $72,500 and required to revise its WSPS regarding order handling (disclosure of order routing information); trade reporting (riskless principal trades reporting on firm's behalf, accurate reporting by third party); sales transactions (determining and marking sales as long or short)(prompt delivery of sales transactions by settlement); (pre-borrowing in aged fails, accepting short sale orders after an aged fail occurs, naked short selling antifraud rule, reporting short sale indicators, reporting sales as long or short); prompt delivery of sales transactions by settlement; and other rules (books and records) within 30 business days of acceptance of this AWC by the nac.","sm":"The firm signed the proposed AWC on May 30 2013 and it was accepted by FINRA on June 25 2013.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2193},{"d":"2013-06-19","di":"2012-08-24","dr":"2013-06-19","k":"Regulatory Action","rg":"CME Group","reg":"The CME Group Market Regulation Department Initiated an Action Before the Chicago Board of Trade Business Conduct Committee.","san":"Disgorgement","os":"On November 27, 2012, fortress appeared before the chicago board of trade business conduct committee (\"CBOT BCC\") and was","st":"Final","fine":90000.0,"dk":"CBOT 10-07789-BC FORTRESS INVESTMENT GROUP","al":"In late October 2010, the CME group market regulation department (\"CME\") notified fortress that it was approaching a single month speculative position limit of the chicago board of trade (\"CBOT\"), a designated contract market of the CME, in wheat futures contracts. Upon receiving that notification, the firm immediately reviewed its position, and after concluding that it had in fact exceeded the speculative position limit, quickly reduced the excess position and brought the position back into compliance with the applicable limit. On August 24, 2012, the CME initiated an action before the CBOT business conduct committee (\"BCC\") based on the violation that occurred in October 2010, seeking penalties and disgorgement of approximately $350,000 in profits resulting from the excess position. The October 2010 violation involved an unintentional overage of approximately 7%, which was corrected within approximately three regular trading hours. Fortress chose to defend the action rather than settling it, arguing that, based on applicable rules, the appropriate sanction was only a warning letter. This was fortress' first ever violation of any CBOT, CME or CFTC rule. Prior to the violation, fortress was in the process of implementing an automated system to monitor applicable limits across client accounts. Shortly after the violation, fortress completed the implementation, and there have been no subsequent position limit violations. On November 27, 2012, fortress appeared before the BCC in a contested hearing and was fined $90,000 and ordered to pay disgorgement of approximately $350,000. On January 28, 2013, fortress appealed the BCC ruling, and the appellate panel of the CME affirmed the BCC decision on June 19, 2013.","res":"Decision","ab":"Fig LLC","self":true,"firms":[129612],"id":2194},{"d":"2013-06-14","di":"2012-07-16","dr":"2013-06-14","k":"Regulatory Action","rg":"Other","reg":"Monetary Authority of Singapore (\"MAS\")","san":"Censure","os":"Adopt certain measures to address deficiencies, report progress on quarterly basis, conduct independent reviews, and increase","st":"Final","dk":"N/A","al":"The MAS took administrative action against Bank of America, National association (Singapore branch) (\"bana Singapore\") and eighteen other banks in the market for deficiencies in governance, risk management, internal controls, and surveillance systems from 2007 to 2011 related to the submission processes for Singapore dollar interest rate benchmarks - specifically, sibor and sor - and foreign exchange spot benchmarks in four emerging market asian currencies. In addition, the MAS determined bana Singapore personnel engaged in electronic communications in which they initiated, received, acknowledged, or relayed requests to improperly influence submissions for certain of the above-referenced ABS benchmarks. The MAS stated it had not made the finding that the ABS benchmarks had been manipulated by any of the nineteen banks subject to its order, but found that the action of the bana Singapore (and other banks') personnel reflected a lack of professional conduct and integrity.","res":"Other","sm":"On June 13, 2013, the MAS sent bana Singapore a letter setting forth: (I) certain conclusions regarding the deficiencies the ams identified in the review reports and related documentation bana Singapore had submitted to the MAS regarding the ABS reference rates; (II) directing bana Singapore, pursuant to section 49(2) of the Singapore banking act, to take certain measures to address governance and control deficiencies; and (III) directing bana Singapore, pursuant to section 38(1) of the Singapore banking act, to maintain an additional statutory reserve of 700 million Singapore dollars (approximately US$551 million) with the MAS for a period of one year. On June 14, 2013, the MAS made a public announcement regarding the conclusion of its inquiry into the ABS benchmarks and provided market-wide findings with respect to communications deemed to demonstrate a lack of professional conduct and integrity. Bana Singapore has completed the actions required by MAS, including completing the enhancements to its submission practices with the MAS.","ab":"Bank of America, National","firms":[142558],"id":2195},{"d":"2013-06-11","di":"2013-06-11","dr":"2013-06-11","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"13-7524","al":"Pursuant to a pit, globex and negotiated trades-CTR audit conducted by the Chicago Mercantile Exchange (\"CME\"), the designated self-regulatory organization for the futures commission merchant business, the applicant was found to have violated CME rule 536.f when trade data reviewed for the trade dates of April 15 and 16, 2013 reflected an unacceptable CTR error rate of 30.30%.","res":"Settled","sm":"Without admitting or denying the findings, the applicant agreed to settle the matter with the payment of a fine in accordance with the automatic fine schedule.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2196},{"d":"2013-06-07","di":"2013-06-07","dr":"2013-06-07","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":160000.0,"dk":"2009018103101","al":"On June 7, 2013, FINRA alleged that Edward jones violated MSRB rules G-17 and G-30(a) by purchasing municipal securities for its own account from customers and/or selling municipal securities for its own account to customers at an aggregate price (including any markdown or markup) that was not fair and reasonable, taking into consideration all relevant facts, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer, or municipal securities dealer is entitled to a profit, and the total amount of the transaction. On June 7, 2013, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent in which Edward jones was censured and ordered to pay a fine of $160,000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2197},{"d":"2013-06-07","di":"2013-06-07","dr":"2013-06-07","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"2011026097801","al":"Nasdaq rule 4755 - Merrill Lynch, Pierce, Fenner & Smith Incorporated entered orders into the Nasdaq market center that failed to correctly indicate whether the orders were a buy, short sale or long sale.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $10,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2198},{"d":"2013-06-04","di":"2013-06-03","dr":"2013-06-04","k":"Regulatory Action","rg":"Other","reg":"New Hampshire Bureau of Securities Regulation (The \"Bureau\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; costs of investigation","st":"Final","fine":7500.0,"dk":"C-2010-008","al":"As the result of a customer complaint received by the bureau in August 2010, a registered representative of Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"Merrill lynch\") located in the portsmouth, New Hampshire branch was place on heightened supervision. In January 2011, the bureau conducted an on-site examination of Merrill lynch's portsmouth, New Hampshire branch. As a result of this examination, the bureau alleged that Merrill lynch failed to properly supervise the registered representative and that, during the relevant time period, Merrill lynch either ignored or failed to identify certain red flags in the customer's account that should have led Merrill lynch's supervisors to take action against their registered representative sooner than they ultimately did.","res":"Order","sm":"Without admitting or denying the allegations and findings, Merrill lynch consented to a consent order for censure; therefore, Merrill lynch is censured, fined $7,500, and ordered to pay the costs of the investigation.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2199},{"d":"2013-06-04","di":"2013-06-04","dr":"2013-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"NA","st":"Final","fine":1250000.0,"dk":"2008014350501","al":"This action relates to conduct that occurred at Wells fargo investments, LLC (CRD #10582). Wells fargo advisors, LLC was not affiliated with Wells fargo investments during the relevant period and is named as a respondent solely as successor in liability for Wells fargo investments, LLC. FINRA rule 2010, NASD rules 2110, 2310, 3010: between January 1, 2007 and December 31, 2008 Wells fargo investments registered representatives made recommendations to customers to purchase floating rate loan funds that were unsuitable for those customers in light of their financial situations and needs. In particular, Wells fargo investments made numerous recommendations to customers whose risk tolerances and investment objectives were inconsistent with the risks and features of floating rate loan funds. The floating rate loan funds sold by Wells fargo investments were subject to significant credit and liquidity risks. Accordingly, the funds were not typically suitable for investors with an investment objective of income and a conservative risk tolerance or those customers who were seeking to preserve principal, particularly when those customers' purchases constituted a large percentage of their investible assets or liquid net worth. Moreover, floating rate loan funds, particularly those with restrictive redemption policies, were not typically suitable for investors with short investment time horizons. Between 2007 and early 2009, the net asset value of the typical floating rate loan funds declined substantially and since that time has partially recovered. However, many Wells fargo investments customers for whom a floating rate loan fund was unsuitable sold their holdings in floating rate loan funds and incurred net losses. Wells fargo investments also failed to establish and maintain a system for supervising its sales of floating rate loan funds that was reasonably designed to achieve compliance with the suitability requirements of NASD and FINRA rules. Even after potential concerns were raised internally, Wells fargo investments failed to provide sufficient guidance or training to registered representatives or supervisors to determine whether floating rate loan funds were suitable for its clients and the credit and liquidity risks associated with floating rate funds.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2200},{"d":"2013-06-03","di":"2013-06-03","dr":"2013-06-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; restitution","st":"Final","fine":900000.0,"dk":"2008014763601","al":"This action relates to conduct that occurred at banc of america investment services, inc. (CRD #16361). Merrill Lynch, Pierce, Fenner & Smith Incorporated is named as a respondent solely as successor in liability for banc of america investment services, inc. (\"BAIS\"). FINRA rule 2010, NASD rules 2110, 2310, 3010: BAIS registered representatives made recommendations that customers purchase floating rate loan funds that were unsuitable for those customers in light of their financial situations and needs. In particular, BAIS made numerous recommendations to purchase floating rate loan funds to customers whose risk tolerances, other assets, and investment objectives were inconsistent with the risks and features of floating rate loan funds. The floating rate loan funds sold by BAIS were subject to significant credit and liquidity risks. Consequently, these funds were not typically suitable for investors with conservative risk tolerances or those customers who were seeking to preserve principal, particularly when those customers' purchases constituted a large percentage of their investable assets or liquid net worth. Moreover, floating rate loan funds, particularly those with restrictive redemption policies, were not typically suitable for investors with short time horizons. In spite of these features of floating rate funds, BAIS representatives recommended floating rate fund investments to numerous customers for whom the investments were unsuitable in light of the customers' financial situations, risk tolerances, and investment objectives. Between late 2007 and early 2009, the net asset value of the typical floating rate loan funds declined substantially. Since that time, the net asset value of the typical floating rate loan fund has partially recovered. However, many BAIS customers for whom the floating rate loan fund investment was unsuitable sold their holdings in floating rate loan funds and incurred losses. As a result, BAIS customers suffered losses in the total amount of $1,095,680.83 caused by the unsuitable transactions in floating rate loan funds recommended by the firm. BAIS did not establish and maintain a system for supervising its sales of floating rate loan funds that was reasonably designed to achieve compliance with the suitability requirements of NASD and FINRA rules. BAIS failed to implement procedures reasonably designed to ensure that its sales of floating rate loan funds were suitable for its customers, even as the market for floating rate loan funds changed significantly. In addition, BAIS failed to ensure that it implemented appropriate systems to flag potentially unsuitable transactions in floating rate loan funds. BAIS also failed to provide sufficient guidance about floating rate loan funds to registered representatives and their supervisors. BAIS failed to adequately train its registered persons about the credit and liquidity risks associated with floating rate funds, or the customers for whom such funds would be suitable.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore it is censured, fined $900,000 and must pay restitution to customers in the amount of $1,095,680.83. A registered principal on behalf of the firm shall submit satisfactory proof of payment of restitution or of reasonable and documented efforts undertaken to effect restitution to FINRA no later than 120 days after acceptance of the AWC. If for any reason the firm cannot locate any of the customers receiving restitution after reasonable and documented efforts within 120 days from the date the AWC is accepted, or such additional period agreed to by FINRA, the firm shall forward any undistributed restitution and interest to the appropriate escheat, unclaimed property or abandoned property fund for the state in which the customer is last known to have resided. The firm shall provide satisfactory proof of such action to FINRA within 14 days of forwarding the undistributed restitution and interest to the appropriate state authority.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2201},{"d":"2013-05-31","di":"2013-05-31","dr":"2013-05-31","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":875000.0,"dk":"CBOT 09-03091-BC","al":"A Chicago Board of Trade (\"CBOT\") business conduct committee (\"BCC\") panel (the \"panel\") alleged that: (I) in December 2008, CME group inc. market regulation department (\"market regulation\") was in regular contact with Goldman, Sachs & co. (the \"firm\") regarding a large position held by the firm in a Treasury futures contract which was set to expire (the \"contract\"), and that the firm did not adequately relay certain market regulation concerns to certain firm traders; and (II) during the final minute prior to expiration of the contract, a firm trader executed a market order, and then submitted a limit order, which was only partially filled as a result of illiquidity in the market, and that during the course of these orders and subsequent fills, the market traded up resulting in the final price of the contract settling above what was indicated by the December-March calendar spread, in alleged violation of CBOT rule 432.w.","res":"Consent","sm":"Without admitting or denying the allegations, the firm submitted a settlement offer to the panel. On June 29, 2013, the panel accepted the settlement offer and issued a decision effective on May 31, 2013. On June 12, 2013, the firm submitted a wire in payment of the fine in the amount of $875,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2202},{"d":"2013-05-28","di":"2013-05-28","dr":"2013-05-28","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Massachusetts, Division of Insurance","san":"Cease and Desist","st":"Final","dk":"SIU NO 7511","al":"The Massachusetts division of insurance alleges Janney Montgomery Scott failed to accurately answer a background question on its 2010 license application in violation of M.G.L. C.175 162r(a)(1).","res":"Decision & Order of Offer of Settlement","sd":"Cease and desist from the alleged conduct.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2203},{"d":"2013-05-15","di":"2013-05-15","dr":"2013-05-15","k":"Regulatory Action","rg":"CME Group","reg":"CME Group, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"13-9246","al":"CME Group, Inc. (\"CME\") market regulation alleged that Goldman, Sachs & co. (the \"firm\") netted down 25 January 2013 comex copper futures contracts on January 9, 2013, in alleged violation of CME rule 854.b.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to the imposition of a fine by CME in the amount of $1,000, which was paid by submission of a check on May 9, 2013.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2204},{"d":"2013-05-14","di":"2012-05-07","dr":"2013-05-14","k":"Regulatory Action","rg":"Other","reg":"Federal Department of Finance (\"FDF\") of the Swiss Financial Market Supervisory Authority (\"Finma\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Finma assessed a fine in the amount of CHF 9,000 and procedural costs of CHF 1,570.","st":"Final","fine":9315.0,"dk":"CASE FILE FDF 442.2-052","al":"The swiss financial market supervisory authority (\"FINMA\") found William blair to have negligently failed to comply with swiss securities regulations due to William blair's late filing of shareholding reports in two instances.","res":"Decision","sd":"William blair was assessed a fine in the amount of CHF 9,000, which was approximately $9,315 (USD) at exchange rates current at the time the fine was assessed. This amount corresponds to 0.9% of the maximum fine of CHF 1,000,000. William blair was also assessed procedural costs of CHF 1,570, which was approximately $1,625 (USD) at exchange rates current at the time the costs were assessed.","sm":"A penal DECREE dated May 14, 2013 (\"DECREE\") by the Federal Department of Finance (\"FDF\") of the Swiss Financial Market Supervisory Authority (\"Finma\") found William blair to have negligently failed to comply with swiss securities regulations due to William blair's late filing of shareholding reports in two instances. Swiss regulations require that a person who acquires or sells shares of a company incorporated in Switzerland whose equity securities are listed in whole or in part in Switzerland and thereby attains, falls below or exceeds the threshold percentages of voting rights send notifications to FINMA and the company. Such notifications must be received by FINMA and the company within four trading days. In this case, William blair exceeded the 3% threshold (the lowest threshold for reporting purposes) in two separate instances and reported such transactions three calendar days after the deadline. FINMA deemed these matters to be simple negligence. However, William blair was assessed a fine in the amount of CHF 9,000, which was approximately $9,315 (USD) at exchange rates current at the time the fine was assessed. This amount corresponds to 0.9% of the maximum fine of CHF 1,000,000. William blair was also assessed procedural costs of CHF 1,570, which was approximately $1,625 (USD) at exchange rates current at the time the costs were assessed.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2205},{"d":"2013-04-09","di":"2013-04-09","dr":"2013-04-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":50000.0,"dk":"2010022380001","al":"FINRA by-laws article v, section 2; FINRA rules 1122, 2010; NASD rules 2110, 3010, 3070, caused violations of FINRA rule 3240(a), NASD rule 2370(a): Wells fargo permitted certain customers to borrow money from the member firm by withdrawing more funds than were available in the customers' accounts, through the use of among other things, online payments, checks, and debit cards. The registered representatives assigned to the accounts, with the concurrence of the branch managers and the firm's credit and margin department, determined whether to allow these types of withdrawals to go through. If the overdrafts were allowed to occur, the customers were responsible for satisfying the overdraft through a same day deposit of funds, wire transfer, or collateral or sale of securities. According to the firm's policy, if a customer did not satisfy an overdraft on the same day, the debit would not be honored. However, during the time period at issue, the firm allowed exceptions to this policy on an occasional, though not frequent, basis and permitted overdrafts in situations where customers did not cover the debit on the same day, thereby loaning money to those customers. In those instances, in accordance with the firm's policies and procedures, if the overdraft was not repaid after a period of time, the unsecured debit was charged against the registered representative's production. Once an overdraft was charged against a registered representative's production, the registered representative could request that the debt be sent to collections, through the firm, for recovery from the customer. Amounts recovered from the customer were paid to the registered representative, minus any collections expenses. By transferring responsibility for the loan to registered representatives and allowing registered representatives to obtain repayment from the customers, the firm caused registered representatives to loan money to customers. The firm also allowed the loans to occur without any system or procedure in place to determine whether the loans met the conditions of FINRA rule 3240(a) and NASD rule 2370(a). Therefore it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA and NASD rules. Two customers alleged in writing that a registered representative had made journal transfers of funds to other customers without their authorization. The firm settled one complaint for $16,500 while the other was resolved without a monetary settlement. The firm never reported either of these complaints on the registered representative's Form U4, and never disclosed the settlement of the second complaint for more than $15,000. The customer complaints alleged misappropriation of funds which requires disclosure under NASD rule 3070 within ten days. One complaint was not reported until three and one-half months after it was received while to other was never reported.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2206},{"d":"2013-04-08","di":"2013-04-08","dr":"2013-04-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":65000.0,"dk":"2011026254401","al":"Section 10 of the Securities Exchange Act of 1934, rule 10B-10(a)(2) thereunder, FINRA rule 2010 and NASD rule 2230: following a system migration, the firm's systems were not properly configured to pass execution capacity downstream to customer confirmations, in certain limited situations. While extensive pre-implementation testing was completed, due to the limited nature of the configuration issue, the problem was not discovered and reported until post-migration. The configuration problem resulted in 22 institutional customers receiving confirmations related to 13,231 non-dollar, agency block equity trades which did not specify the capacity. The total confirmations affected were 39,256.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore it is censured and fined $65,000","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2207},{"d":"2013-04-02","di":"2013-04-02","dr":"2013-04-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":47500.0,"dk":"2010025148901","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\") failed: (I) from May 1 to August 31, 2010, to report to the FINRA/Nasdaq trade reporting facility by 8:00 P.M. Eastern time certain transactions that required a .ro, .ra or .RX modifier, in alleged violation of FINRA rule 7230a(g); (II) from September 1 to December 31, 2010, to transmit to the OTC reporting facility within 30 seconds after execution certain last sale reports of transactions in OTC equity securities, in alleged violation of FINRA rules 6622(a) and 2010, and to report to the OTC reporting facility the correct time of execution for certain transactions in reportable securities, in alleged violation of FINRA rule 7330(d)(4); and (III) from January 1 to April 30, 2011, to accept or decline in the FINRA/Nasdaq trade reporting facility certain transactions in reportable securities within 20 minutes after execution, in alleged violation of FINRA rules 7230a(b) and 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on April 2, 2013, and on April 18, 2013, the firm submitted a wire in payment of a fine in the amount of $47,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2208},{"d":"2013-04-02","di":"2013-04-02","dr":"2013-04-02","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","st":"Final","fine":12500.0,"dk":"2009017002602","al":"Nasdaq rules 2110, 3010, 4755 - Wedbush Securities, inc.'s supervisory system and written supervisory procedures were not reasonably designed to achieve compliance with applicable securities laws, regulations and Nasdaq rules concerning the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints. The firm failed to correctly indicate whether orders were a buy, short sale or long sale for some orders entered into the Nasdaq market center.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; Wedbush was censured, fined $12,500 and required to revise its written supervisory procedures regarding the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints within 30 business days of acceptance of this AWC by the national review counsel.","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; Wedbush was censured, fined $12,500 and required to revise its written supervisory procedures regarding the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints within 30 business days of acceptance of this AWC by the national review counsel and which was accepted on April 2 2013.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2209},{"d":"2013-04-02","di":"2013-04-02","dr":"2013-04-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution censure","st":"Final","fine":1050000.0,"dk":"2008014584701","al":"FINRA rule 2010, NASD rules 2110, 2320, 3010 - Merrill Lynch, Pierce, Fenner & Smith's proprietary bond market order execution system had a flawed pricing logic, with respect to non-convertible preferred securities, that only incorporated the quotations from the two primary exchanges where the securities were listed. As a result, in instances where there was a better price on a market other than the primary listing exchange, the firm systematically executed transactions in non-convertible preferred securities with its customer on its proprietary order execution system at prices inferior to the national best bid or offer (NBBO). In 12,259 transactions for or with a customer, the firm thus failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. The firm failed to establish and maintain a supervisory system, including written supervisory procedures (WSPS) reasonably designed to ensure compliance with the firm's best execution obligations for transactions in non-convertible preferred securities executed on its order execution system. The firm's supervisory system was deficient in that it failed to perform any post execution review of non-convertible preferred transactions executed on its system to ensure compliance with its best execution obligations despite the fact it received several inquiry letters from FINRA regarding the relevant conduct. Although the firm took some remedial measures intended to address issues raised by FINRA, it failed to identify the flawed pricing logic until a later date. Approximately 2,200 transactions were identified on FINRA's best execution report cards available to the firm for over three years. Despite these red flags, the firm failed to perform any meaningful supervisory review for best execution of non-convertible preferred transactions executed on its proprietary system. The firm's WSPS were not adequate for almost three years in that they did not describe the supervisory steps to be taken by the person responsible for a best execution supervisory review of non-convertible preferred transactions executed on its proprietary system. For two years, the firm's WSPS did not provide for the person or persons responsible for ensuring compliance with the applicable rules; a statement of the supervisory steps to be taken by that person; a statement as to how often such person should take such steps; and a statement as to how the completion of supervisory reviews should be documented.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $1,050,000.00, required to revise its WSPS regarding supervisory procedures to be followed by the person responsible for best execution of non-convertible preferred transactions executed on it proprietary order execution system within 30 business days of acceptance of this AWC by the nac, and to pay restitution of $323,950.04, plus interest, in connection with the 12,259 transactions.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2210},{"d":"2013-03-20","di":"2013-03-20","dr":"2013-03-20","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"12-08956","al":"The Chicago Mercantile Exchange Inc. (\"CME\") market regulation department alleged that Goldman, Sachs & co. (the \"firm\") trade data for the trade dates of August 1, 2012 through October 5, 2012 reflected an unacceptable computerized trade reconstruction (CTR) error rate, in alleged violation of CME rule 536.f.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to the imposition of a fine by CME in the amount of $2,500, which was paid by submission of a check on March 19, 2013.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2211},{"d":"2013-03-15","di":"2013-03-15","dr":"2013-03-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"2009017007402","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period of September 16-17, 2009, transmitted to the order audit trail system (OATS) 13 reports that contained certain inaccurate, incomplete, or improperly formatted data, in alleged violation of FINRA rule 7450, and (II) during the period of July 13-14, 2010, erroneously submitted a duplicate non-tape report with the .RX modifier to the FINRA/Nasdaq trade reporting facility, in alleged violation of FINRA rule 7230a.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on March 15, 2013, and on April 4, 2013, the firm submitted a wire in payment of a fine in the amount of $20,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2212},{"d":"2013-03-15","di":"2013-03-15","dr":"2013-03-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":39000.0,"dk":"2011026827001","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\") failed: (I) during the period of July 1 to September 30, 2010, to report to the trade reporting and compliance engine (\"TRACE\") the correct contra-party's identifier for certain S1 transactions in TRACE-eligible securities, in alleged violation of FINRA rule 6730(c), and (II) during the period of April 1 to June 30, 2011, to report to TRACE the correct time of trade execution for certain P1 transactions in TRACE-eligible agency debt securities, and to show the correct time of execution on the memorandum of certain brokerage orders, in alleged violation of FINRA rule 6730(c)8 and SEC rule 17A-3, respectively.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on March 15, 2013, and on April 4, 2013, the firm submitted a wire in payment of a fine in the amount of $39,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2213},{"d":"2013-03-12","dr":"2013-03-12","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"2009017007401","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of market regulation, on behalf of The Nasdaq Stock Market LLC (\"NASDAQ\"), alleged that during the period of September 16-17, 2009, Goldman, Sachs & co. (the \"firm\") entered 10 orders into the NASDAQ/singlebook system that failed to correctly indicate whether the orders were a buy, short sale, or long sale, in alleged violation of NASDAQ rule 4755, and 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 NASDAQ, in alleged violation of NASDAQ rules 3010 and 2110.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure, fine and undertaking and entered into a letter of acceptance, waiver and consent (\"AWC\"), which was accepted by FINRA on behalf of Nasdaq on March 12, 2013, and on April 11, 2013, the firm submitted a wire in payment of a fine in the amount of $17,500. In the undertaking, the firm consented to revise and implement applicable written supervisory procedures and, within 90 business days of the acceptance of the AWC, to provide a representation to FINRA that the applicable written supervisory procedures have been revised and implemented.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2214},{"d":"2013-03-12","di":"2013-03-08","dr":"2013-03-12","k":"Regulatory Action","rg":"Other","reg":"Bats Y-Exchange, Inc.","st":"Final","fine":12500.0,"dk":"2009017002601","al":"Bats rules 5.1, 11.19 - Wedbush Securities, inc.'s supervisory system and written supervisory procedures (WSPS) were not reasonably designed to achieve compliance with applicable securities laws, regulations and Bats rules concerning the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints and short sale order entry on the Bats exchange. The firm failed to correctly indicate whether two orders were a buy, short sale or long sale in some transactions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings. Wedbush was censured, fined $12,500, and required to revise it WSP's regarding the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints and short sale order entry on the Bats exchange within 30 business days of acceptance of this AWC by the appeals committee.","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $12,500, and required to revise it WSPS regarding the prevention of erroneous orders and transactions and non-meritorious clearly erroneous transaction complaints and short sale order entry on the Bats exchange within 30 business days of acceptance of this AWC by the appeals committee which did accept the AWC on March 8, 2013.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2215},{"d":"2013-03-12","di":"2013-03-12","dr":"2013-03-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":7500.0,"dk":"20110261103-01","al":"Alleged violations of NASD rule 6130 and FINRA 7230a by reporting incorrect capacity codes, counterparties, and buy/sell codes to FINRA/Nasdaq trade reporting facility for certain transactions between April 2008 and September 2010.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying findings , the firm consented to the imposition of a censure and paid a fine of $7,500 on March 27, 2013","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2216},{"d":"2013-03-08","di":"2012-11-13","dr":"2013-03-08","k":"Regulatory Action","rg":"State regulator","reg":"NY State Department of Financial Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2012-0174-S","al":"On June 20, 2007 and July 31, 2009 the firm failed to include the administrative actions on CRD on the NY insurance license application.","res":"Stipulation and Consent","sd":"The firm paid a fine of $10,000 which was sent with the proposed stipulation on November 13, 2012.","sm":"The firm sent a signed copy of the stipulation admitting the firm had not provided information regarding the administrative actions on the 2007 and 2009 applications along with the check to pay the $10,000 penalty. NY signed the stipulation and sent the firm a copy on March 8 2013.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2217},{"d":"2013-03-04","di":"2013-03-04","dr":"2013-03-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"2008014636301","al":"FINRA rules 2010, 6380a, 6622(b), 6730, 7230a, 7230a(b), 7450, NASD rules 6130, 6230, 6620(b), 6955, 6955(a) - Merrill lynch transmitted reportable order events (ROES) to the order audit trail system (OATS) that were rejected by OATS for content or syntax errors and were repairable but the firm failed to repair some of the rejected ROES so that it failed to transmit them during the review period. The firm transmitted execution or combined order/execution reports to OATS that contained inaccurate reporting exception codes; failed to report execution or combined order/execution reports; and transmitted execution or combined order/execution reports to OATS it was not required to report. Because of the inaccurate, missing or improperly formatted data in a reporting exception code, OATS was unable to link the execution reports to the related trade reports in a FINRA trade reporting system. The firm transmitted reports to OATS that did not include the special handling code NH for not held limit orders. The firm failed to transmit all of its ROES to OATS on 380 business days for a secondary market participant identifier (MPID). The firm failed, within 90 seconds after execution, to transmit numerous last sale reports of transactions in designated securities to the FINRA/Nasdaq trade reporting facility (FNTRF). This conduct constitutes separate and distinct violations of FINRA rule 6380a and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010. The firm failed to accept or decline in the FNTRF transactions in reportable securities within 20 minutes after execution, approximately 49% of all transactions the firm had an obligation to accept or decline during the time period. This conduct constitutes separate and distinct violations of FINRA rule 7230a(b) and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010. The firm failed to timely report to the FNTRF by 8:00 P.M. Eastern time transactions that required a .RX modifier and also failed to report transactions with a .RX modifier it was required to report. The firm incorrectly reported itself as a market maker in last sale reports of transactions to the OTC reporting facility. The firm failed to report to the trade reporting and compliance engine (TRACE) transactions in TRACE-eligible securities it was required to report and also reported transactions it was not required to report.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $150,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2218},{"d":"2013-02-28","di":"2011-09-01","dr":"2013-02-28","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Disgorgement; restitution","st":"Final","dk":"11-112-B-HC/SM","al":"The Board of Governors of the Federal Reserve System (the \"Federal Reserve\") alleged that, prior to September 1, 2011, The Goldman Sachs Group, inc. (\"GS group\") and Goldman Sachs bank USA (\"GS bank\") engaged in a pattern of misconduct and negligence ( ) ( ) relating to deficient practices in residential mortgage loan servicing and foreclosure processing involving LITTON loan servicing LP (\"LITTON\"), a former subsidiary.","res":"Consent","sm":"Without admitting or denying the allegations, GS group, GS bank and the Federal Reserve entered into the amended consent, which provides for the termination of the independent foreclosure review under the consent and calls for GS group and GS bank, in coordination with the 12 other financial institutions with mortgage loan servicing operations that have also agreed to amend their respective orders, to ensure that the fund is established, from which payments will be made pursuant to a distribution plan developed by the regulators. The amended consent provides for GS group and GS bank to: (I) make a cash payment that collectively totals $135 million into the fund for distribution by the regulators in their discretion to certain eligible borrowers whose residential mortgage loan on their primary residence was serviced by GS bank, through litton, and who were subject to a foreclosure action or proceeding that was pending or completed any time from January 1, 2009 to December 31, 2010; (II) collectively provide certain loss mitigation or other foreclosure prevention that collectively totals $195 million, with preference given to activities designed to keep borrowers in their homes through affordable, sustainable and meaningful home preservation actions; and (III) as applicable, submit policies and procedures acceptable to the Federal Reserve and submit certain reports to the Federal Reserve within the applicable time periods set forth in the amended consent. On March 11, 2013, GS group and GS bank made a cash payment into the fund, as provided in the amended consent, by submission of a wire in the amount of $135 million.","ab":"The Goldman Sachs Group,","firms":[361],"id":2219},{"d":"2013-02-27","di":"2013-02-27","dr":"2013-02-27","k":"Regulatory Action","rg":"Other","reg":"New York Department of Financial Services","san":"Other","os":"Stipulation","st":"Final","fine":50000.0,"dk":"2012-0184-S","al":"The New York state department of financial services alleged that during the approximate period of January 2007 through December 2010 Wells fargo advisors, LLC, an unlicensed entity, accepted insurance commissions from Wells fargo advisors insurance agency LLC, in violation of New York insurance law. The department further alleged that both Wells fargo advisors LLC and Wells fargo advisors financial network LLC provided materially incomplete information in their respective insurance license applications submitted to the state on or about January 27, 2012.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2220},{"d":"2013-02-26","di":"2013-02-26","dr":"2013-02-26","k":"Regulatory Action","rg":"State regulator","reg":"New York State Department of Financial Services","san":"Other","os":"Stipulation","st":"Final","fine":50000.0,"dk":"2012-0184-S","al":"The New York State Department of Financial Services alleged that during the approximate period of January 2007 through December 2010 Wells fargo advisors, LLC, an unlicensed entity, accepted insurance commissions from Wells fargo advisors insurance agency LLC, in violation of New York insurance law. The department further alleged that both Wells fargo advisors LLC and Wells Fargo Advisors Financial Network LLC provided materially incomplete information in their respective insurance license applications submitted to the state on or about January 27, 2012.","res":"Stipulation and Consent","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2221},{"d":"2013-02-15","di":"2013-02-15","dr":"2013-02-15","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"13-9273","al":"The Chicago Board of Trade (\"CBT\") alleged that during a review of Goldman, Sachs & co. (the \"firm\") position reporting during December 2012, the firm failed to accurately submit certain long positions eligible for delivery, in alleged violation of CBT rule 807.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to the imposition of a fine by CBT in the amount of $2,500, which was paid by submission of a check on February 13, 2013.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2222},{"d":"2013-02-12","di":"2013-02-12","dr":"2013-02-12","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation (\"Ofr\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30000.0,"dk":"0672-S-9/12","al":"On December 15, 2010, Wells fargo, a federally covered investment adviser, informed the office by letter that an anomaly in its automated systems had caused a number of individuals to engage in investment advisory business in Florida without benefit of investment adviser representative registration. In early 2012, Wells fargo advisors, LLC notified the office that it had additional financial advisors, including two other registered associates, that potentially needed investment adviser representative registration in Florida. The registered associataed are properly registered with the office to sell securities. On March 16,2012, the office issued a letter to determine if they had engaged in investment advisory business from offices in Florida. In response to the office's inquiry, a registered associate indicated that he had engaged in business for three months out of the year since 2008, and another registered associate indicated that he had engaged in business for two to four months per year since 2009, prior to them each obtaining proper registration in Florida.","res":"Order","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2223},{"d":"2013-01-14","di":"2012-12-21","dr":"2013-01-14","k":"Regulatory Action","rg":"Other","reg":"Borsa Italia","st":"Final","fine":68369.46,"dk":"N/A","al":"Alleged breach of italian short sale regulation","res":"Decision","sd":"Fine was paid 5/31/13. 50,000.00 euro.","sm":"Consob alleged breaches of italian short sale regulations in connection with the untimely settlement of transactions between January 9, 2012 and January 20, 2012 by an indirect client of iel.","ab":"Instinet Europe Limited","firms":[7897],"id":2224},{"d":"2013-01-02","di":"2012-11-30","dr":"2013-01-02","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA Inc.","st":"Final","fine":25000.0,"dk":"20110275603","al":"**11/30/12** offer of settlement and consent filed by FINRA market regulation, legal section and pending. For the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings referred to herein, Wedbush Securities, inc. stipulated that from on or about July 30, 2009 to on or about May 21, 2010 it: 1.violated NYSE ARCA options rule 6.67(b) by failing to comply with the order format requirements of the exchange by submitting orders with incorrect information as to whether such transaction was an opening or closing transaction. 2.violated NYSE ARCA options rule 6.14 by making adjustments to positions at the options clearing corporation that were not for the purpose of correcting a bona fide error. 3. Violated NYSE ARCA options rule 11.18 by failing to establish and maintain a system to supervise the activities of its associated persons and the operation of its business reasonably designed to ensure compliance with NYSE ARCA options rule 6.14. Stipulated sanction: 1. Censure; and 2. Fine in the amount of $25,000.","res":"Decision & Order of Offer of Settlement","sd":"NYSE ARCA hearing board decision issued January 2, 2013 wherein in accordance with the offer of settlement and consent, the firm is censured and fined $25,000.","sm":"On novemebr 25, 2012 Wedbush signed an offer of settlement whcih was signed by counsel for FINRA market regulation on November 30, 2013. The hearing board accepted the offer of settlement and issued the decision on January 2, 2013 of a censure and fine of $25,000.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2225},{"d":"2012-12-27","di":"2012-12-27","dr":"2012-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; restitution; undertaking","st":"Final","fine":568000.0,"dk":"2010022049803","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of enforcement alleged that during the period between February 2006 and December 2010, Goldman, Sachs & co. (the \"firm\") unfairly requested and received reimbursements for certain California public securities association (cal psa) underwriting assessments, in alleged violation of municipal securities rulemaking board (\"MSRB\") rule G-17, and failed to adopt, maintain and enforce written supervisory procedures reasonably designed to ensure compliance with MSRB rule G-17, in alleged violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on December 27, 2012, and on January 10, 2013, the firm submitted a check in payment of the fine in the amount of $568,000. The firm consented to pay restitution in the amount of $115,997.50 and to submit satisfactory proof of payment of restitution or of reasonable documented efforts to effect restitution to the applicable issuers in California to which the firm has not yet provided restitution, and within 180 days of the issuance of the AWC, to certify with FINRA that it has completed a review of relevant written supervisory procedures and systems and implemented necessary revisions to such procedures and systems in order to ensure that the procedures and systems are in compliance with MSRB rule G-27.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2226},{"d":"2012-12-27","di":"2012-12-27","dr":"2012-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure restitution","st":"Final","fine":787000.0,"dk":"2010022049801","al":"MSRB rules G-17, G-27 - Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPF&s\") and banc of america securities LLC, which was consolidated into MLPF&s, were members of a municipal securities association which requested that its members make underwriting assessment payments of $0.01 per bond, and later $0.02 per bond, when they participated in bond issuances in California of more than $2 million in issue size with more than two years to maturity. The municipal securities association's mission was to keep its members informed of legislative and regulatory developments affecting the municipal securities industry and to provide a forum through which the municipal securities industry could review and respond to these developments. The association billed its members on the per-bond basis, regardless of whether there was any direct relationship between that bond issuance and the association's activities, and regardless of whether the association provided any services required for the underwriting. The firms paid the association a total of $387,455.62 for participating in the underwriting of approximately 252 applicable transactions. The firm obtained reimbursement for the voluntary payments from the proceeds of municipal and state bond offerings which was unfair. The assessments did not have a direct relationship to any activities conducted with respect to each bond offering. The firm was not required by any statute or regulations to be a member of the association yet treated its assessments as an expense of each transaction and requested and received reimbursement of the payments from the proceeds of each bond offering. The firm listed the underwriting assessments as expenses of the underwriting but its requests for reimbursement were not fair because they were not accompanied by adequate disclosure to issuers. The firm's practices resulted in the expenditure of the proceeds of municipal and state bond offerings to an organization engaged in political activities. In response to a request from the treasurer of the state of California, the firms have returned $100,255.58 to multiple issuers as a refund for the underwriting assessments reimbursed from offering proceeds. The firms failed to adopt, maintain and enforce written supervisory procedures (WSPS) reasonably designed to ensure compliance with MSRB rule G-17 as it relates to the conduct described here. The firms failed to establish reasonable procedures for reviewing and disclosing expenses for municipal securities associations for which it requested reimbursement from the proceeds of municipal and state offerings, and for ensuring that those requests were fair and adquate. The firms also failed to adopt, maintain and enforce adequate systems and WSPS reasonably designed to monitor how the municipal securities associations to which it belonged used the funds that the firm provided. Adequate policies and procedures were especially necessary in light of one association's engagement in political activities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, MLPF&s consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $787,000 for MSRB rule violations and ordered to pay $287,200.04 in restitution and to submit satisfactory proof of payment of restitution or of reasonable documented efforts to effect restitution to the issuers located in California to which the firm has not yet provided restitution.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2227},{"d":"2012-12-17","di":"2012-12-17","dr":"2012-12-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":35000.0,"dk":"2010025367601","al":"On July 13, 2012, FINRA alleged that Edward jones' payroll department periodically received garnishments from judgment creditors, tax levies from federal and state taxing authorities, and/or bankruptcy wage withholding orders involving Edward jones financial advisors. FINRA alleged that Edward jones did not establish and maintain written supervisory procedures to ensure that financial advisors' uniform applications for securities industry registration or transfer (forms U4) were updated to reflect disclosures of which the firm's payroll department was on notice and did not timely file Form U4 amendments, in violation of article v, section 2(c) of the FINRA by-laws, FINRA rule 2010, and NASD rules 2110 and 3010(b). On December 17, 2012, Edward jones, without admitting or denying the findings, entered into a letter of acceptance, waiver and consent in which Edward jones was censured and ordered to pay a fine of $35,000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2228},{"d":"2012-12-12","di":"2012-12-12","dr":"2012-12-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"2010023688101","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that during the periods of July 1 to September 30, 2009, and April 1 to June 30, 2010, Goldman, Sachs & co. (the \"firm\") improperly transmitted certain execution or combined order/execution reports with a reporting exception code (REC) of \"p\" to the order audit trail system (OATS) that were required to be matched to a related trade report in a FINRA trade reporting system, in alleged violation of FINRA rule 7450.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on December 12, 2012, and on December 24, 2012, the firm submitted a wire in payment of the fine in the amount of $15,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2229},{"d":"2012-12-12","di":"2012-12-12","dr":"2012-12-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":45000.0,"dk":"2009020223601","al":"FINRA alleged the firm did not close out fail-to-deliver positions by purchasing securities of like kind and quantity within the time frame prescribed by reg sho and rule 204 and 204t. Further, the firm did not properly transmit reportable order events (ROES) to the order audit trail system (OATS) within the appropriate time period due to context or syntax errors. The firm also did not properly repair or resubmit certain inaccurate ROES within the appropriate time period as prescribed by FINRA rule 7450 . Finally, as required by MSRB rule G-17 and G-30(a), the firm did not reasonably price certain municipal securities that were purchased in the aggregate from customer accounts.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings. The firm was also censured, fined $45,000, ordered to pay $5,758.36 in restitution to customers relating to the municipal securities pricing, and required to revise its written supervisory procedures regarding OATS.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2230},{"d":"2012-12-12","di":"2012-12-12","dr":"2012-12-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":265000.0,"dk":"2008013213201","al":"FINRA rules 2010, 6182, 7230a(d)(6), NASD rules 2110, 3010, 6130(d)(6). - Merrill Lynch, Pierce, Fenner & Smith Incorporated executed cross transactions that were also short sales but reported these trades to the FNTRF without a short sale modifier. The firm executed over eight million cross transactions that were also short sales, but reported these trades to the FINRA/Nasdaq trade reporting facility (FNTRF)without a short sale modifier. The firm failed to have adequate written supervisory procedures reasonably designed to ensure compliance with FINRA rules 6182, 7230a(d)(6) and NASD rule 6130(d)(6).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $265,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2231},{"d":"2012-12-07","di":"2012-12-07","dr":"2012-12-07","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertakings","st":"Final","fine":1500000.0,"dk":"13-08","al":"The Commodity Futures Trading Commission (\"CFTC\"), in an order, set forth findings and conclusions to which Goldman, Sachs & co. (the \"firm\") consented, without admitting or denying them, as part of an offer of settlement that was accepted by the CFTC and became effective on December 7, 2012 (the \"order\"). In its findings in the order, the CFTC asserted that the firm failed for several months, including at least November and December 2007, to ensure that certain aspects of its risk management, compliance, and supervision programs comported with its obligations to supervise diligently its business as a CFTC registrant. During November and December 2007, the firm further failed to supervise diligently the trading activities of an associated person, whose trading activities on seven days in mid-November and mid-December 2007 in the e-mini s&p 500 futures contract, traded on the chicago mercantile exchange's globex platform, resulted in a substantial loss to the firm ($118 million). As a result, the CFTC alleged that the firm failed to have policies or procedures reasonably designed to detect and prevent the manual entry of fabricated futures trades into its front office systems, which aggregated manually entered and electronically executed trades in the same product, in alleged violation of CFTC regulation 166.3.","res":"Order","sm":"Without admitting or denying any of the findings or conclusions therein, the firm made an offer of settlement and consented to the entry of an order instituting proceedings pursuant to sections 6(c) and 6(d) of the Commodity Exchange Act, as amended, making findings and imposing remedial sanctions that was accepted by the CFTC and became effective on December 7, 2012 (the \"order\"). The order orders the firm to cease and desist from violating CFTC regulation 166.3 and imposes a civil monetary penalty in the amount of $1,500,000, which was paid by the submission of a wire to the CFTC on December 14, 2012. In addition, the order included undertakings by the firm. In settling the matter, the CFTC took into account the cooperation of the firm and the corrective action the firm undertook after the trader's activities were discovered.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2232},{"d":"2012-12-03","di":"2012-09-07","dr":"2012-12-03","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Service of Korea & Financial Services Commission of Korea.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":46974.83,"dk":"N/A","al":"Alleged breaches of korean short sale regulation","res":"Decision","sd":"$50,000,000 (usd$46,974.83) fine. Paid 12/18/2012","sm":"Financial supervisory service (FSS) of korea alleged breaches of koran short sale regulations. Financial services commission (FSC) of korea found breaches of local short sale rules in connection with the execution of to customer odd lot trades between January 2, 2010 and May 31, 2012.","ab":"Instinet Pacific Ltd.","firms":[7897],"id":2233},{"d":"2012-11-28","di":"2012-11-28","dr":"2012-11-28","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina Department of the Secretary of State - Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":3193552.24,"dk":"FILE NO. 09SEC052","al":"The North Carolina department of the secretary of state, securities division (administrator) alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated's (MLPFS) conduct in connection with the marketing and sale of auction rate securities (ARS) to retail and other customers was grounds for enforcement action by the administrator under N.C.G.S. §§ 78a­39(a)(2)(g) and 78a­ 39(A1)(2)(a).","res":"Settled","sm":"Under the terms of the settlement, MLPFS agreed to undertakings designed to provide liquidity to eligible investors. MLPFS has offered to purchase at par from eligible investors certain ars that have failed at auction. MLPFS has also agreed to pay those eligible investors that MLPFS can reasonably identify who sold certain ars below par, the difference between par and the price at which they sold such securities. MLPFS has also agreed to participate in a special arbitration process for the purpose of arbitrating any eligible investor's consequential damages claim arising from their inability to sell certain ars. Furthermore, MLPFS agreed to refund refinancing fees to certain municipal issuers that issued and refinanced certain ars through MLPFS. MLPFS will also endeavor to work with issuers and other interested parties to provide liquidity solutions for institutional investors that purchased certain ars from MLPFS but are not considered \"eligible investors\" and are not entitled to participate in the ars buyback under the terms of the settlement.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2234},{"d":"2012-11-21","di":"2012-11-21","dr":"2012-11-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"20100235665-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that during the period of January 19, 2010 through March 18, 2011, Goldman, Sachs & co. (the \"firm\") failed to report and/or inaccurately reported, in certain instances, the contra party for certain reportable options positions, in alleged violation of FINRA rule 2360(b)(5).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on November 21, 2012, and on December 11, 2012, the firm submitted a wire in payment of the fine in the amount of $50,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2235},{"d":"2012-11-21","di":"2012-11-21","dr":"2012-11-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":35000.0,"dk":"2008015084501","al":"Section 12(k)(2) of the sea of 1934 - Wedbush Securities failed in several instances to prohibit executions in short sales subject to the SEC emergency order by non-broker-dealer sponsored access clients of the firm.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings. The firm was censured and fined $35,000","sm":"The firm was censured and fined $35,000 11/21/2012.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2236},{"d":"2012-11-12","di":"2012-11-12","dr":"2012-11-12","k":"Regulatory Action","rg":"CME Group","reg":"CME Group","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"COMEX 11-08603-BC","al":"Pursuant to an offer of settlement that Nomura Securities Co., Ltd. (\"Nomura\") presented at a hearing, two traders employed by Nomura prearranged five trades totaling 600 lots of December 2011 gold futures contracts for the purpose of transferring positions between two proprietary accounts with common beneficial ownership as part of Nomura's migration of its commodities business, including positions used for hedging, from its fixed income department to its equities department. The panel also found that the trades were executed on globex with the buy and sell orders being entered less than 5 seconds apart. The panel also found that Nomura failed to diligently supervise its traders in a manner sufficient to ensure that they were familiar with exchange rules such as through appropriate compliance training. The panel found that as a result of the foregoing, Nomura violated exchange rules 432.w., 534 and 539.a. And c.","res":"Settled","sd":"Without admitting or denying the rule violations, Nomura paid the $50,000 fine on 11/20/2012","ab":"Nomura Securities Co., Ltd","firms":[7897],"id":2237},{"d":"2012-11-09","di":"2011-08-11","dr":"2012-11-09","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"None","st":"Final","al":"The lawsuit alleges that The Bank of New York Mellon corporation (\"BNY mellon\") improperly charged and reported prices for standing instruction foreign exchange (\"FX\") transactions executed in connection with custody services provided by BNY mellon. The registrant is not a defendant to this action.","res":"Dismissed","sd":"Not applicable","ab":"The Bank of New York Mellon","firms":[231],"id":2238},{"d":"2012-10-31","di":"2012-10-31","dr":"2012-10-31","k":"Regulatory Action","rg":"Other","reg":"Osaka Securities Exchange","san":"Other","st":"Final","fine":200000.0,"dk":"N/A","al":"Disciplinary action pursuant to rule 42(1)(IX) of the regulations for transaction particpants, in connection with a failure to take necessary and appropriate measures to prevent illegal trading by taking sufficient measures to protect confidential information relating to the public offering of new shares.","res":"Consent","sd":"Nomura Securities Co., Ltd. was fined 16 million yen (approx $200,000)","ab":"Nomura Securities Co., Ltd","firms":[7897],"id":2239},{"d":"2012-10-31","di":"2012-10-31","dr":"2012-10-31","k":"Regulatory Action","rg":"Other","reg":"Tokyo Stock Exchange","san":"Other","st":"Final","fine":2400000.0,"dk":"N/A","al":"Disciplinary action pursuant to rule 34, paragraph 2 of the trading partcipant regulations, in connection with a failure to take necessary and appropriate measures to prevent illegal trading by taking sufficient measures to protect confidential information relating to the public offering of new shares.","res":"Consent","sd":"Nomura Securities Co., Ltd. was fined 200 million yen (approx $2,400,000).","ab":"Nomura Securities Co., Ltd","firms":[7897],"id":2240},{"d":"2012-10-16","di":"2012-10-16","dr":"2012-10-16","k":"Regulatory Action","rg":"Other","reg":"The Japanese Securities Dealers Association","san":"Other","st":"Final","fine":3800000.0,"dk":"N/A","al":"Violations of article 28, paragraph 1, of the association's articles of incorporation and recommendation based on article 29 of the articles of incorporation, in connection with a failure to take necessary and appropriate measures to prevent illegal trading by taking sufficient measures to protect confidential information relating to the public offering of new shares.","res":"Consent","sd":"Nomura Securities Co., Ltd. was fined 300 million yen (approx $3,800,000)and admonished by the japanese financial services agency in a related action.","ab":"Nomura Securities Co., Ltd","firms":[7897],"id":2241},{"d":"2012-10-15","di":"2012-07-03","dr":"2012-10-15","k":"Regulatory Action","rg":"NYSE","reg":"NYSE MKT LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":443700.0,"dk":"12-NYSE MKT-6","al":"The legal section of the market regulation department at the Financial Industry Regulatory Authority, on behalf of NYSE regulation, inc., alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between January 2004 and June 2011, mismarked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of NYSE AMEX LLC (\"NYSE AMEX\") rules 16, 324, 956NY(a) and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of NYSE AMEX rule 320.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into a stipulation of facts and consent to penalty with NYSE regulation, inc., which was approved by the NYSE MKT LLC (successor to NYSE AMEX) hearing board on September 20, 2012 and became final on October 15, 2012. On October 19, 2012, the firm submitted a wire to FINRA in payment of the fine in the amount of $443,700. The stipulation of facts and consent to penalty was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) BATS exchange, inc. (BATS); (III) boston options exchange LLC (BOX); (IV) the Nasdaq options market (NOM); (v) Nasdaq omx PHLX, inc. (PHLX): (VI) international securities exchange, LLC (ISE); and (VII) NYSE ARCA, inc. (NYSE ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2242},{"d":"2012-10-09","di":"2012-08-29","dr":"2012-10-09","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":150000.0,"dk":"12-NYSE-7","al":"**8/29/12** stipulation of facts and consent to penalty filed by FINRA market regulation, legal section and pending. New York Stock Exchange LLC: for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings, the firm stipulated that: 1) during the period April 2007 through June 2011, the firm violated NYSE rule 92(a) on twenty- four occasions and NYSE rule 401/2010 on eleven occasions; 2) during the period of February 2008 through June 2012, the firm entered or cancelled 456 market-on-close (\"MOC\") or limit-on- close (\"LOC\") orders in violation of NYSE rule 123c; and, 3) during the period of July 2011 through April 2012, the firm violated NYSE rule 342 in that it failed to employ reasonable supervisory controls and systems with regard to the cancellation of MOC/LOC orders. Stipulated sanction: censure and fine in the amount of $150,000. Orders. Stipulated sanction: censure and fine in the amount of $150,000.","res":"Decision","sm":"**9/13/12** unless a review has been requested by any person or body authorized by NYSE rule 476(g), this decision will become final 25 calendar days after notice of the hearing board's determination has been served upon the respondents. **10/12/12** since a review of the decision of the hearing board was not requested, that decision became final as of the close of business on October 9, 2012.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2243},{"d":"2012-09-27","di":"2012-09-27","dr":"2012-09-27","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; disgorgement","st":"Final","fine":3750000.0,"dk":"3-15048","al":"Starting in July 2008, neil M.M. MORRISON (\"MORRISON\") was employed by Goldman, Sachs & co. (the \"firm\") to solicit municipal underwriting business from, among others, the commonwealth of Massachusetts treasurer's office. From November 2008 to October 2010, MORRISON was also substantially engaged in the political campaigns, including the November 2010 Massachusetts gubernatorial campaign, for timothy p. CAHILL (\"CAHILL\"), the then-treasurer of Massachusetts. MORRISON worked on CAHILL's campaign during work hours using firm resources. MORRISON also made a secret, undisclosed cash campaign contribution to CAHILL. Within two years of MORRISON's contributions, the firm engaged in municipal securities business with issuers associated with CAHILL as treasurer and as a candidate for governor. The Securities and Exchange Commission (the \"commission\") alleged that the firm's engagement in municipal securities business with these issuers violated section 15b(c)(1) of the Exchange Act and MSRB rule G-37(b), and that the firm's failure to maintain records of and to report in regulatory filings the contributions and campaign work, and to take steps to ensure that the attributed contributions, or campaign work or the conflicts of interest raised by them were disclosed in bond offering documents, violated MSRB rules G-8, G-9, G-17, G-27 and G-37. Without admitting or denying the violations (except as to the commission's jurisdiction over it and the subject matter of the proceedings), the firm consented to the entry of the order.","res":"Order","sm":"The firm agrees to cease and desist from committing or causing any violations and any future violations of section 15b(c)(1) of the Exchange Act, MSRB rule g 37(b), MSRB rule G-17, MSRB rule G-27, MSRB rule G-37(e), MSRB rule G-8 and MSRB rule G-9. The firm is censured and will pay disgorgement of $7,558,942 and prejudgment interest of $670,033. Of the $7,558,942 in disgorgement, $2,120,547 will be deemed satisfied by respondent's payment of $1,512,902 to the commonwealth of Massachusetts and $607,645 to the Massachusetts water pollution abatement trust in a related action by the commonwealth of Massachusetts. The remaining $5,438,395 and prejudgment interest of $670,033 will be paid to the commission for remittance to the United States Treasury. Finally, the order requires the firm to pay a civil money penalty in the amount of $3,750,000 to the commission, of which $1,875,000 will be transferred to the MSRB in accordance with section 15b(c)(9)(a) of the Exchange Act, and of which the remaining $1,875,000 will be transferred to the United States Treasury. The disgorgement, prejudgment interest and civil money penalty were paid in full by submission of a wire to the commission on October 3, 2012, and by submission of checks to the commonwealth of Massachusetts and the Massachusetts water pollution abatement trust on October 4, 2012.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2244},{"d":"2012-09-25","di":"2012-09-25","dr":"2012-09-25","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx PHLX, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":448459.0,"dk":"2012-09","al":"Nasdaq Omx PHLX, LLC. (\"PHLX\") alleged that Goldman, Sachs & co. (the \"firm\"), during the period between January 2004 and May 2010 (the \"relevant period\"): (I) improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of PHLX rules 707, 760 and 785, and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to remediate certain coding deficiencies until after the relevant period, and to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, each in alleged violation of PHLX rule 748(g).","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into an offer of settlement, stipulation of facts and consent to sanctions with the PHLX business conduct committee on September 25, 2012, and on October 22, 2012, the firm submitted a check to PHLX in payment of the fine in the amount of $448,459. The offer of settlement, stipulation of facts and consent to sanctions was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) BATS exchange, inc. (BATS); (III) boston options exchange LLC (BOX); (IV) the Nasdaq options market (NOM); (v) international securities exchange, LLC (ISE); (VI) NYSE AMEX LLC (NYSE AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2245},{"d":"2012-09-24","di":"2012-09-24","dr":"2012-09-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":500000.0,"dk":"2009020356301","al":"Article v, sections 2(a) and 2(c), 3(a), 3(b) of the FINRA by-laws, FINRA rule 2010, 3010, NASD rules 2110, 3010, 3070(f), NYSE rules 351(a), 351(d), 401a, FINRA incorporated NYSE rules 351(a), 351(d), 401a - Merrill lynch detected approximately 1,524 backlog complaints when various firm departments and another member firm began to be consolidated into a combined compliance department. The firm had failed to comply and/or timely comply with its obligation to make certain required filings and acknowledgments relative to the backlog compliants. Of the 1,524 backlog complaints, 77 customer complaints required the firm to file a report pursuant to NYSE rule 351(a)(2) or (a)(8) but 35 of the 77 backlog complaints were never made and 14 of the 77 backlog complaints were made late. Most of the late filings were at least six months late and as much as one year late. The firm's failures continued after the period of the backlog complaints. Of 172 post backlog complaints requiring a NYSE rule 351(a) filing, 26 were never made and 10 filings were not timely made. Most untimely complaints were less than 90 days late. Of the 1,524 backlog complaints, 1,157 were required to be included in the firm's quarterly filings of statistical information. Of the firm's violative filings: 26 were never included in the firm's quarterly filings and 248 of the 1,157 were not timely included in the firm's quarterly filings. Most of the untimely filings were 90 days late or less. Of the 1,524 backlog complaints, 1,085 required the firm to acknowledge the customer's complaint within 15 days of receipt; of the 1,085, required acknowledgments for 163 were never made and required acknowledgments for 117 were made late. Most of the untimely acknowledgments were 90 days late or less. Of the 1,524 backlog complaints, 310 customer complaints required the firm to file a Form U4. Of the 310: 12 Form U4 filings were never made and 80 were made late. About one-half of the untimely forms U4 were filed more than 90 days late. Of the 1,524 backlog complaints, the firm was required to file a Form U5 in 162 instances; 45 of the 162 required filings were made late. Nearly two- thirds of the untimely forms U5 were filed more than 90 days late. During the post backlog period, 344 customer complaints required the filing of a Form U5. Of these, the firm failed to make, or timely make, 35 filings. About one-third of the untimely forms U5 were more than 90 days late. The firm failed to file copies of all non-NASD/FINRA arbitrations and civil and criminal complaints received during a two-year period and a subsequent four-month period. As with the backlog compliant, the firm detected when various firm departments and another firm began consolidations. During these two periods, approximatley 214 events required an NASD rule 3070(f) filing and the firm failed to make 100% of the required filings. Between the first and second periods, for a span of approximately six months, the firm experienced reporting failures. The firm failed to file required documents for 80 artbitrations and/or civil litigations; the firm failed to file the required documents for four of the 80 litigations and made late filings for an additional 14 litigations. During a more than three-year period, the firm failed to file, or timely file, forms U4 and U5 related to the arbitrations and civil litigations. The firm failed to make and/or timely make Form U4 filings for 28% of arbitrations and civil litigations and 60% of litigations requiring reporting. Personnel in the firm's intake group, office of general counsel were not adequately trained and/or supervised in performing assigned functions with respect","res":"Acceptance, Waiver & Consent(AWC)","sm":"Allegations continued: the firm's complaint tracking system was ineffective as it failed to identify the high volume of customer complaints not being acknowledged or reported as required. The firm's procedures broke down due to human error and the repeated failure to identify the failures and the required filings. Moreover, no one department of the firm was monitoring for compliance with the reportng and FINRA rules. Brief summary of details: the firm self-reported the backlog compliants to FINRA in November 2009. Following the January 1, 2009 Merrill lynch acquisition and subsequent consolidations of broker-dealers in 2009 and 2010 as described above, the firm restructured and enhanced its policies and procedures relative to customer compliant reporting. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $500,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2246},{"d":"2012-09-20","di":"2012-07-03","dr":"2012-09-20","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":671305.0,"dk":"12-ARCA-8","al":"The legal section of the market regulation department at the Financial Industry Regulatory Authority, on behalf of NYSE regulation, inc., alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between January 2004 and June 2011, improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of NYSE ARCA, Inc. (\"NYSE ARCA\") options rules 6.68, 11.1(b) and 11.16(a), and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of NYSE ARCA options rule 11.18.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into an offer of settlement and consent with NYSE regulation, inc., which was approved by the NYSE ARCA hearing board on September 20, 2012 and on October 2, 2012, the firm submitted a wire in payment of the fine in the amount of $671,305. The offer of settlement and consent is conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) BATS exchange, inc. (BATS); (III) boston options exchange LLC (box - a facility of Nasdaq omx BX); (IV) the Nasdaq options market (NOM); (v) Nasdaq omx PHLX, inc. (PHLX): (VI) international securities exchange, LLC (ISE); and (VII) NYSE AMEX LLC (NYSE AMEX).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2247},{"d":"2012-09-20","di":"2012-09-20","dr":"2012-09-20","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange, Incorporated","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":3750000.0,"dk":"12-0008","al":"The Chicago Board Options Exchange, Incorporated (\"CBOE\") alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the approximate period from in or about January 2004 through in or about May 2010, mismarked certain options orders with an improper origin code resulting in the execution of orders and crosses, some of which may have been afforded priority to which they were not entitled, in alleged violation of CBOE rules 4.1, 4.2, 4.22, 6.51, 6.74, 15.1 and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to maintain supervisory systems and controls that were reasonably designed to achieve compliance with CBOE rules relating to order entry, in alleged violation of CBOE rule 4.2.","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into a letter of consent which was approved by the CBOE business conduct committee on September 20, 2012 and on September 27, 2012, the firm submitted a wire in payment of the fine in the amount of $3,750,000. The letter of consent is conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges (I) BATS exchange, inc. (BATS); (II) boston options exchange regulation, LLC (BOXR); (III) international securities exchange, LLC (ISE); (IV) the Nasdaq options market (NOM); (v) Nasdaq omx PHLX, inc. (PHLX): (VI) NYSE AMEX LLC (AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2248},{"d":"2012-09-20","di":"2012-09-20","dr":"2012-09-20","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1074788.0,"dk":"20100235041","al":"International Securities Exchange, LLC (\"ISE\") alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between January 2004 and May 2010, improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of ISE rules 400, 712(a), and 1400(a), and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of ISE rule 401.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine and censure and entered into a letter of acceptance, waiver and consent (\"AWC\"), which was approved by ise business conduct committee and a summary of which was published by ise on September 20, 2012, and on October 19, 2012, the firm submitted a wire to ise in payment of the fine in the amount of $1,074,788. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) BATS exchange, inc. (BATS); (III) BOX options exchange, LLC (BOX); (IV) the Nasdaq options market (NOM); (v) Nasdaq omx PHLX, inc. (PHLX); (VI) NYSE AMEX LLC (AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2249},{"d":"2012-09-20","dr":"2012-09-20","k":"Civil Judicial Action","san":"Injunction","os":"Monetary damages; pre-judgment interest on monetary damages; and a civil penalty","st":"Final","fine":175000000.0,"al":"The complaint alleges that, during and between 2004 and 2009, the referenced control affiliate engaged in a pattern or practice of discrimination on the basis of race and national origin in residential mortgage lending by allowing employees to make decisions about the type of loan product offered and the loan price in a manner disconnected from objective criteria like credit risk, that policies set up financial incentives for employees and mortgage broker's to impose unfavorable terms, and that the policies lacked safeguards to prevent and remedy racial and ethnic disparities.","res":"Consent","sd":"The referenced control affiliate agreed to pay at least $125 million to compensate borrowers who were allegedly aggrieved. The referenced control affiliate also agreed to pay $50 million to provide down-payment assistance to low- income borrowers in select metropolitan areas. The control affiliate deposited funds in escrow accounts for the agreed payments by September 24, 2012. Wells fargo will maintain its policies that disconnect compensation from a loan's terms and conditions (implemented after the events in the alleged complaint), provide training and assure compliance, through monitoring and regular reporting to the United States.","ab":"Wells Fargo Bank, NA","firms":[11025,19616],"id":2250},{"d":"2012-09-14","di":"2012-09-14","dr":"2012-09-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx BX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":297428.0,"dk":"2010023504101","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between January 2004 and May 2010, improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of Nasdaq Omx BX, Inc. (\"BOX\") trading rules chapter v, sections 1 and 15, and chapter VIII, section 1; and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of BOX trading rules chapter III, sections 1 and 2, and chapter v, section 1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine and censure and entered into a letter of acceptance, waiver and consent (\"AWC\"), which was approved by FINRA on September 14, 2012 and on October 16, 2012, the firm submitted a wire to box in payment of the fine in the amount of $297,428. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) Nasdaq omx PHLX, inc. (PHLX); (III) the Nasdaq options market (NOM); (IV) BATS exchange, inc. (BATS); (v) international securities exchange, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2251},{"d":"2012-09-14","di":"2012-09-14","dr":"2012-09-14","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Options Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":63507.0,"dk":"2010023504102","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of market regulation alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between March 2008 and May 2010, improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of Nasdaq Options Market, LLC (\"NOM\") rules chapter v, sections 1(b)(III) and section 7(a), and chapter IX, section 1; and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of NOM rules chapter III, sections 1 and 2(a)(I).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine and censure and entered into a letter of acceptance, waiver and consent (\"AWC\"), which was approved by FINRA on September 14, 2012, and on October 22, 2012, the firm submitted a check to nom in payment of the fine in the amount of $63,507. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) Nasdaq omx PHLX, inc. (PHLX); (III) boston options exchange LLC (BOX); (IV) BATS exchange, inc. (BATS); (v) international securities exchange, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2252},{"d":"2012-09-10","di":"2011-02-02","dr":"2012-09-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":375000.0,"dk":"2008012738002","al":"The firm failed to establish and maintain a supervisory sytem reasonably designed to achieve compliance with applicable laws rules and regulations concerning variable annuities and general sales practice even though this was never noted as an issue in any annual examination conducted by the NYSE, NASD or FINRA and the firm did have WSP'S. The firm failed to maintain records it did not know existed on a reps personal email account or were mailed by a rep in violation of the firms policies. FINRA alleges a failure to adequately supervise two reps. These allegations include violations of section 17 of the Securities Exchange Act of 1934, SEC rules 17A-3, 17A-4, FINRA rule 2010, NASD rules 2110, 3010, 3010(a), 3010(b), 3010(c), 3010(d), 3010(e), 3110","res":"Decision & Order of Offer of Settlement","sd":"The firm was censured and fined $360,000 plus joint and several liability for $15,000.","sm":"The firm settled the case without admitting or denying the allegations on September 10, 2012 for a fine of $360,000 plus $15,000 joint and several with two employees.","ab":"Lanni, Richard Anthony","firms":[877],"id":2253},{"d":"2012-09-05","di":"2012-09-05","dr":"2012-09-05","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvannia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":221331.78,"dk":"2010-07-13","al":"Various state regulators, including the Pennsylvania securities commission, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative proceeding, findings of fact, conclusions of law and order, the Pennsylvania securities commission alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an adminsitrative proceeding, findings of fact, conclusions of law and order with the Pennsylvania securities commission on September 5, 2012 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $221,331.78 to the Pennsylvania securities commission, which amount was paid on September 17, 2012.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2254},{"d":"2012-08-29","di":"2012-08-29","dr":"2012-08-29","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure disgorgement restitution","st":"Final","fine":400000.0,"dk":"2009018601702","al":"FINRA rule 2010,NASD rules 2110, 2310, 3010(a) and (b): a former broker of the firm recommended his customers engage in a pattern of unsuitable short-term closed-end funds (CEF) and unit investment trusts (UIT) trading. Most of the broker's short-term transactions involved closed-end funds purchased at initial public offering, with the sales charges to the customer built into the offering price. Even though cefs and uits generally were intended as longer-term investments, the broker recommended that some of these customers sell their entire positions as soon as two months after purchase. Most of the short-term CEF transactions involved switching, whereby the broker generated funds to purchase one CEF or UIT by selling another CEF, with the customer gaining little or no economic benefit from the exchange. The firm, through the broker, made these recommendations to purchase and sell cefs and uits on a short-term basis without having reasonable grounds for believing the recommendations were suitable in view of the frequency and size of the transactions and each customer's investment objectives, financial situation, and needs. The firm, through the broker, made unsuitable recommendations, inconsistent with the customers' investment objectives, to seven customers that they open margin accounts and use margin to buy and sell securities. These customers paid in aggregate over $70,000 in margin interest. The firm failed to detect that the broker was engaging in a pattern of unsuitable short-term trading of cefs and uits and suitable transactions on margin. The firm approved each of the broker's short-term CEF and UIT transactions, failing to identify the transactions as unsuitable. In addition, the firm failed to respond adequately to exception reports and information suggesting that the broker was engaged in a pattern of unsuitable use of margin in trade securities and did not speak with any of the customers about the short-term trading or margin activity until the customers began to complain. In some cases the firm relied upon the broker's self-serving explanations for the transactions without conducting further investigation. The firm lacked adequate supervisory systems and procedures to supervise UIT transactions, including systems and procedures to monitor short-term UIT transactions and switches. While the firm had a supervisory system for certain short-term CEF liquidations, it did not have a similar system for UIT redemptions. The firm's written supervisory procedures for uits were also deficient, by failing to provide guidance to registered representatives or principals on suitability factors to consider in purchasing, selling, or switching uits.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore, the firm is censured, fined $400,000, which includes disgorgement of commission received of $47,190.03 and required to pay $130,718, plus interest, in restitution to customers on or before the date this AWC is accepted by FINRA. By letter dated August 14, 2012, the firm provided documentation establishing that it paid $130,718 in restitution, plus $21,174.11 in interest, consistent with the terms of the AWC.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2255},{"d":"2012-08-22","dr":"2012-08-22","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":25000.0,"dk":"2011-070","al":"The business conduct committee of ICE Futures U.S., Inc. determined that applicant may have violated exchange rule 6.13(a) on February 2 and 3, 2011 by maintaining a short position in cotton no. 2 for a corporate affiliate which exceeded the net 5,000 futures equivalent all months position limit.","res":"Settled","sm":"Without admitting or denying the violation of any exchange rules, the applicant agreed to pay a fine of $25,000 and to cease and desist from future violations of exchange rule 6.13(a).","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2256},{"d":"2012-08-21","di":"2012-08-21","dr":"2012-08-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":37500.0,"dk":"2008012898601","al":"SEC rule 611(a)(1) of regulation NMS, NASD rule 4632(a): the firm failed to enforce its written policies and procedures that were reasonably designed to prevent trade-throughs of protected quotations in NMS stocks that do not fall within any applicable exception, and if relying on an exception, are reasonably designed to assure compliance with the terms of the exception. The firm incorrectly reported approximately 400 orders-represented by 14,706 trades-to act as trade-through exempt when the trades did not qualify for an exemption from SEC rule 611 of regulation NMS.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore it is censured and fined $37,500.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2257},{"d":"2012-08-08","di":"2012-08-08","dr":"2012-08-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Civil and administrative penalty/fine","st":"Final","fine":52500.0,"dk":"2011028261501","al":"In connection with a settlement of matters arising out of an examination for the 2009-2010 period, FINRA alleged the firm violated reg sho rules 204(a) and 204(b) by failing to close out fails to deliver resulting from sale transactions in certain proprietary accounts and as a result not determining securities should have been restricted from further short sales, failing to comply with the close-out requirements in certain customer accounts and failing to maintain and apply certain corresponding written supervisory procedures as required by FINRA rule 3010, 3010(a) and (b). FINRA also alleged the firm violated MSRB rules in connection with certain offerings during the period by filing Form G-32 with the municipal securities rulemaking board (MSRB) containing an incorrect date for three offerings and late to emma for ten offerings, failing to timely send the final settlement letters to accomplish final settlement required by G-11 for two offerings, and amending by one day late the official statement with MSRB required by G-36 in three offerings. Finally FINRA alleged the firm violated rule 3010 and MSRB G-27 by failing to enforce its written policies and procedures pertaining to deposits of low-priced securities that traded on the otcbb by accepting a certificate for 5 million shares in one branch office without obtaining an exception as required and executing four retail variable rate demand obligation (VRDO) securities trades without updating its written supervisory procedures (WSPS) to address the disclosure of all material information to customers in connection with such transactions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings. The firm was censured and fined $52,500 ($5,000 of which pertains to the MSRB rule violations).","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2258},{"d":"2012-08-07","di":"2012-08-07","dr":"2012-08-07","k":"Regulatory Action","rg":"Other","reg":"Capital Market Authority of Saudi Arabia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":23999.04,"dk":"7/4498","al":"In a letter dated August 7, 2012 to Goldman Sachs Saudi arabia (\"GSSA\") from the kingdom of saudi arabia capital market authority (the \"cma\"), with reference to the periodic inspection visit paid to GSSA by cma between January 7, 2012 to January 25, 2012, cma informed GSSA of a board of cma resolution (the \"resolution\"), alleging: (a) a lack of a compliance officer at GSSA from August 14, 2010 to February 13, 2011; (b) the lack of a bank account with a local bank for the purpose of keeping the funds of cma clients; (c) non-disclosure to a cma client of certain fees and commissions charged before providing certain securities services to the client; (d) not including in the custodian's agreement signed with certain branches of GSSA certain conditions stated in the paragraph referred to; and (e) not setting appropriate measures to maintain a clear and appropriate division of responsibilities among the members of the board of directors, partners or senior management of cma, in alleged violation of articles 20(b)(3), 10(c), 46, 89(a) and 53(a), respectively, of the cma authorized persons regulations.","res":"Consent","sm":"Without admitting or denying the allegations, gssa agreed to the payment of a financial penalty to the cma in the amount of 90,000 saudi riyals (SR), which was paid by submission of a wire on August 29, 2012. The resolution stipulated it is necessary to discuss the matter of violations at the next meeting of the board of directors of gssa to set the measures and mechanisms required to prevent reoccurrence in the future.","ab":"Goldman Sachs Saudi","firms":[361],"id":2259},{"d":"2012-08-03","di":"2012-08-03","dr":"2012-08-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":450000.0,"dk":"2010022652202","al":"FINRA rule 2010, NASD rules 2110, 3010, 3012(a)(2)(b)(I) - Merrill lynch's supervisory control system failed to include a policy or procedure requiring a review to detect or prevent multiple transmittals of funds from multiple customers going to the same third party accounts. The firm's system failed to include exception reports that would have identified multiple customer wires going to the same third party account. Consequently, the firm failed to detect that a registered representative had initiated fund transfers totaling approximately $887,931 out of customer accounts to bank accounts he apparently controlled. The registered representative has been barred from association with any FINRA member in any capacity.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $450,000. The firm has repaid all the affected customers.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2260},{"d":"2012-07-09","di":"2012-07-09","dr":"2012-07-09","k":"Regulatory Action","rg":"Other","reg":"Bats Z-Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":813.0,"dk":"20100826","al":"Financial Industry Regulatory Authority, inc. (\"FINRA\") department of market regulation, on behalf of Bats Z-Exchange, Inc. (\"Bats\"), alleged that Goldman, Sachs & co. (the \"firm\"): (I) during the period between February 2010 and May 2010, improperly marked certain options orders on the exchange as \"customer\" through various proprietary order entry systems employed by the firm to send options orders to the exchange, in alleged violation of Bats rules chapter III, rule 3.1, chapter IV, rule 4.1, and chapter xxiv, rules 24.1 and 24.4(a); and section 17(a) of the Securities Exchange Act of 1934 and rule 17A-3 promulgated thereunder and (II) failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the exchange's origin code requirements, in alleged violation of Bats rules chapter v, rules 5.1 and 5.2, and chapter xviii, rule 18.1.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a fine and censure and entered into a letter of acceptance, waiver and consent (\"AWC\"), which was accepted and which was published by Bats on September 21, 2012, and on October 22, 2012, the firm submitted a check to Bats in payment of the fine in the amount of $813.00. The AWC was conditioned upon acceptance of parallel settlement agreements in related matters between the firm and the following options exchanges: (I) the chicago board options exchange, inc. (CBOE); (II) Nasdaq omx PHLX, inc. (PHLX); (III) boston options exchange LLC (BOX); (IV) the Nasdaq options market (\"NOM\"); (v) international securities exchange, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); and (VII) NYSE ARCA, inc. (ARCA).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2261},{"d":"2012-07-02","di":"2010-02-08","dr":"2012-07-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":95000.0,"dk":"2010021566902","al":"FINRA alleges that Edward jones violated NASD conduct rules 2110 and 3010(b) and FINRA rule 2010. FINRA alleges that Edward jones failed to adequately review a customer account that was under heightened scrutiny, and failed to respond to red flags that would have alerted it to the activities of an associate who converted money from the account. The associate was able to convert $167,249 from the customer's account by using forged letters of authorization to effect 51 wire transfers out of the account without permission or authority.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2262},{"d":"2012-06-21","di":"2012-06-21","dr":"2012-06-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":2800000.0,"dk":"2008014187701","al":"Sections 10, 17(a) of the Securities Exchange Act, SEC rules 10B-10(a), 10B-10(a)(2), 17A-3, 17A-4, FINRA rules 2010, 2251(a), 2264, 4370, NASD rules 2110, 2230, 2260(a), 2341, 3010, 3510(e) - Merrill Lynch, Pierce, Fenner & Smith Incorporated, contrary to applicable customer disclosures or applicable program investment guidelines, relied on improperly coded data in its securities master database, which caused it to charge fees on certain ineligible securities which typically were securities affiliated with the firm so it overcharged customers a total of $9,460,351. When calculating the remediation for the three investment advisory programs, it discovered that its billing system for two of them did not properly identify accounts holding 100% fixed income securities to ensure that the lower fixed income fee schedule was applied and for the third, the fee schedule was determined by the chosen investment strategy at the time of customer enrollment and did not monitor changes in investment strategy to determine whether the more favorable fixed income fee should apply. The firm overcharged customers in the programs $6,782,576 by not billing at the applicable fixed income fee schedule. The billing process for one program erroneously allowed for flat rate billing to exceed the maximum tiered fee rate so that it overcharged customers $3,486,846. The firm offered no-load mutual funds for customer retirement accounts in several investment programs but its rebating process did not take into account that load funds and no-load funds were treated differently when collecting subaccounting and 12B-1 fees from the mutual fund companies. The firm did not rebate $1,987,752 in sub-accounting fees on no-load fund transactions for customer accounts. For some programs, the contract and disclosure documents stated that the fee rate applied would be based on the aggregate value of the assets in all the customer's program accounts but the firm did not always automatically update the accounts' asset values which resulted in customers not receiving the appropriate fee discount. The firm overcharged customer accounts, resulting in excess fees of $8,061,426. The firm allowed a new account to be aggregated with an existing group of accounts and have a flat rate apply based on total asset levels but the firm's system erroneously applied the same flat rate. The firm overcharged customer accounts a total of $565,372. New customer accounts in one program were opened using documents reflecting a lower fee schedule but were placed in a higher fee schedule so the customers were improperly charged $1,123,386 in higher fees. In one program, customers were charged an estimated $706,660 in wire transfer fees even though documents had not adequately disclosed such charges. As a result of these supervisory failures, the firm charged customer accounts unwarranted fees totaling at least $32,174,369. The firm has completed remediation with interest of affected customers. For over four years, the firm failed to deliver trade confirmations for over 10 million transactions to customer accounts as required under the Exchange Act and failed to send trade confirmations to customers because of coding errors and other deficiencies that were not promptly remedied and lasted over several years. For approximately nine years, the firm failed to state, or inaccurately stated, in trade confirmations or account statements that it sent for at least seven million transactions, whether it acted as an agent, dual agent, or a principal for the transaction. [Continued in comment section]","res":"Acceptance, Waiver & Consent(AWC)","sm":"Allegations continued: the firm failed to deliver certain proxies and voting materials in accordance with customer directives. It failed to enforce its procedures requiring the processing of a proxy mismatch report and the correction of information identified in the report. The firm improperly aggregated proxies and a third-party vendor caused proxies to be misdirected because it relied on outdated and incorrect proxy-delivery designations. The firm failed to send margin risk disclosure statements to customers because a coding issue incorrectly blocked the delivery of its welcome kit to customers. The firm identified over 16,000 customers on the money manager platform who did not receive its business continuity plan because the welcome kit was suppressed. In determining the appropriate sanctions, FINRA considered the firm's internal review through which it self-identified these violations, the remedial measures it took to correct its system and procedures, and its efforts to provide remediation to customers. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $2,800,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2263},{"d":"2012-06-21","di":"2012-06-21","dr":"2012-06-21","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"2008014187702","al":"Sections 10B-10(a) of the Securities Exchange Act and NASD rules 2230 and 2110 - between May 2003 and June 2006, banc of america investment services, inc. (\"BAIS\") (which merged into Merrill Lynch, Pierce, Fenner & Smith Incorporated on October 23, 2009) failed to send contemporaneous trade confirmations to customers enrolled in one of its investment programs. Specifically, BAIS failed to send immediate trade confirmations to approximately 2,702 customer accounts in the advised version (non- discretionary) of its consulting services fund strategies program, which affected approximately 23,450 transactions and approximately $323,475,815 dollars in assets. Accordingly, BAIS violated Exchange Act 10B-10(a) and NASD rules 2230 and 2110 by failing to deliver required trade confirmations to certain customers.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm (as successor by merger to bais) consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $50,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2264},{"d":"2012-06-11","di":"2012-06-11","dr":"2012-06-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":450000.0,"dk":"2010022011901","al":"FINRA rule 2010, NASD rules 2110, 3010 - Merrill Lynch, Pierce, Fenner & Smith Incorporated offered a wide range of structured products to retail customers. For more than three years, firm customers effected approximately 650,000 structured-product purchases, of which greater than 50 percent involved structured-product offerings issued by the firm's parent company. The firm relied on automated exception-based reporting systems to flag transactions and/or accounts that met certain pre-defined criteria. The various reporting systems employed by the firm are utilized by dedicated review units or teams charged with follow-up investigation of exceptions reported. Of the several exception-based reporting systems utilized by the firm, none, prior to March 1, 2009, specifically monitored for potentially unsuitable concentration levels in structured products in customer accounts.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $450,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2265},{"d":"2012-06-01","di":"2012-06-01","dr":"2012-06-01","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12500.0,"dk":"2009018958801","al":"Nasdaq rules 4613(e), 4755(a)(4) - Merrill Lynch, Pierce, Fenner & Smith Incorporated failed to reasonably avoid displaying and engaged in a pattern or practice of displaying quotations that locked or crossed a protected quotation, in that, it entered intermarket sweep orders into the Nasdaq single book execution system that locked or crossed a quotation previously disseminated pursuant to an effective national market system plan and failed to simultaneously route an intermarket sweep order to execute against the full displayed size of the locked or crossed quote.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $12,500.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2266},{"d":"2012-05-24","di":"2012-05-24","dr":"2012-05-24","k":"Regulatory Action","rg":"Other","reg":"ComisiÓN Nacional de Valores","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27500.0,"al":"It was asserted that Wachovia Securities (ARGENTINA), LLC, had engaged in unauthorized offering of regulated securities/investment services to the public of ARGENTINA by listing the address and phone number of its argentine branch office location on the \"global office locator page\" of the public website of its parent, Wachovia Securities, LLC.","res":"Other","sm":"It was asserted that Wachovia Securities (ARGENTINA), LLC, had engaged in unauthorized offering of regulated securities/investment services to the public of ARGENTINA by listing the address and phone number of its argentine branch office location on the \"global office locator page\" of the public website of its parent, Wachovia Securities, llc.civil and administrative penalties and fines. Paid August 2012.","ab":"Wachovia Securities","firms":[19616],"id":2267},{"d":"2012-05-23","di":"2012-05-23","dr":"2012-05-23","k":"Regulatory Action","rg":"Other","reg":"Illinois Department of Financial and Professional Regulation, Division of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Denial; refusal to renew license","st":"Final","fine":4500.0,"dk":"2012-MBR-11","al":"The state of Illinois Department of Financial and Professional Regulation, Division of Banking (the \"department\"), alleged that: (I) in its application to renew its residential mortgage license for 2011 and 2012, MTGLQ Investors, L.P. (\"MTGLQ\") submitted deficient financial statements, and (II) MTGLQ did not respond to notices from the department notifying MTGLQ of these deficiencies and certain additional deficiencies, nor did it otherwise remedy the noted deficiencies. As a result the department alleged that MTGLQ violated sections 2-2, 2-4(d) & (t), 2-6, 3-2, 3-5, and 4-5(I)(11) & (17) of the Illinois residential mortgage license act of 1987 (the \"act\") and sections 1050.320 and 1050.430 of the rules promulgated under the act.","res":"Order","sm":"MTGLQ has not conducted any activity requiring the Illinois license since May 23, 2012 and has requested the department to rescind the order and renew its license.","ab":"MTGLQ Investors, L.P.","firms":[361],"id":2268},{"d":"2012-05-22","di":"2011-06-23","dr":"2012-05-22","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange (\"NYMEX\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"NYMEX CASE 11-08386-BC","al":"NYMEX alleged that dbag violated NYMEX rule 562 (position limit violations). In that on June 23, 2011, Deutsche bank held a position of 5,761.25 short July 2011 henry hub natural gas lookalike last day financial futures (\"JUL11 natgas\") contracts, which was 1,261.25 contracts or 28.0% over its exchange approved expiration month hedge exemption level of 4,500 contracts in JUL11 natgas. Furthermore, on June 24, 2011, Deutsche bank increased its JUL11 natgas position to 6,011.25 short JUL11 natgas contracts or 33.6% over its exchange approved expiration month hedge exemption level.","res":"Settled","sm":"Without admitting or denying the allegations, dbag agreed to the settlement and fine of $40,000.00.","ab":"Deutsche Bank AG","firms":[300838],"id":2269},{"d":"2012-05-21","di":"2012-04-13","dr":"2012-05-21","k":"Regulatory Action","rg":"Other","reg":"ICE Clear Credit LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40000.0,"dk":"2012-404B-017","al":"ICE Clear Credit, LLC (\"ICE\") alleged that during the month of March, 2012, Goldman Sachs international (\"GSI\") failed to submit seventy-two single name end of day prices in accordance with ICE rules and procedures, in alleged violation of ICE rule 404(b).","res":"Consent","sm":"ICE made a summary assessment against gsi of $40,000, which was made final on May 21, 2012. The assessment amount was billed in an ICE monthly clearing fee invoice, and was paid by submission of a wire on June 7, 2012.","ab":"Goldman Sachs","firms":[361],"id":2270},{"d":"2012-05-16","di":"2012-05-16","dr":"2012-05-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution; censure","st":"Final","fine":17500.0,"dk":"2008014732601","al":"MSRB rules G-17, G-30(a) - Merrill Lynch, Pierce, Fenner & Smith Incorporated sold municipal securities for its own account to customers at an aggregate price that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer, or municipal securities dealer is entitled to a profit, and the total dollar amount of the transaction.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured, fined $17,500 for MSRB rule violations and ordered to pay $7,425.35, plus interest, in restitution to customers. A registered firm principal shall submit satisfactory proof of payment of the restitution, or of reasonable and documented efforts undertaken to effect restitution to FINRA no later than 120 days after acceptance of this AWC. Any undistributed restitution and interest shall be forwarded to the appropriate escheat, unclaimed property or abandoned property fund for the state in which the customer last resided.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2271},{"d":"2012-05-09","di":"2012-05-09","dr":"2012-05-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"20080123505-01","al":"SEC rule 611(c) of regulation NMS - Merrill Lynch, Pierce, Fenner & Smith Incorporated, due to a coding error in its smart order routing technology, improperly rounded protected market sub-penny quotes priced to three or more decimal places, causing the firm to improperly route intermarket sweep orders (ISOS) on a number of occasions and, in some instances, trade through protected quotes. As a result, the firm failed to take reasonable steps to establish that the intermarket sweep orders it routed in sub-penny quotes met the definitional requirements set forth in rule 600(b)(30) of regulation NMS.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $10,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2272},{"d":"2012-05-02","di":"2012-05-02","dr":"2012-05-02","k":"Regulatory Action","rg":"State regulator","reg":"State of New York Office of the Attorney General","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking; reimbursement of cost of investigation.","st":"Final","fine":875670.0,"dk":"AOD #12-011","al":"The State of New York Office of the Attorney General (NYAG) alleged that in connection with the sale of securities in New York by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in New York, MLPFS failed to establish an adequate system to monitor the registration status of CAS accepting client orders, failed to have adequate written procedures and to enforce its established procedures reasonably designed to prevent and detect violations of the law, and sold securities in New York through unregistered salesmen.","res":"Settled","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the nyag describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2273},{"d":"2012-05-02","di":"2011-03-03","dr":"2012-05-02","k":"Regulatory Action","rg":"Other","reg":"Swiss Financial Market Supervisory Authority (\"Finma\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"N/A","al":"Finma alleged dbag filed late disclosures on shareholdings in adecco SA on March 26, March 30, and April 13, 2010, and late disclosure of shareholdings in peach property group on November 25, 2010, in violation of art. 20 of stock Exchange Act.","res":"Settled","sm":"The fine of 50,000 Swiss francs was paid.","ab":"Deutsche Bank AG","firms":[300838],"id":2274},{"d":"2012-05-01","di":"2012-05-01","dr":"2012-05-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure restitution","st":"Final","fine":2100000.0,"dk":"2009019113901","al":"FINRA rule 2010, NASD rules 2110, 2310, 3010 - Wells fargo advisors, financial network, LLC failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with NASD and FINRA rules in connection with the sale of non-traditional exchange-traded funds (ETFS) in accounts where the firm provided brokerage services to certain retail customers and the firm failed to provide adequate formal training and guidance to its registered representatives and supervisors regarding non-traditional ETFS. The firm allowed its registered representatives to recommend a non-traditional ETF to customers without performing reasonable diligence to understand the risks and features associated with it. Certain firm registered representatives made unsuitable recommendation of non-traditional ETFS to certain customers with conservative income or conservative growth & income investment objectives and/or risk tolerances.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2275},{"d":"2012-05-01","di":"2012-05-01","dr":"2012-05-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure restitution","st":"Final","fine":2100000.0,"dk":"20090191139","al":"FINRA rule 2010, NASD rules 2110, 2310, 3010 - Wells fargo advisors, LLC failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with NASD and FINRA rules in connection with the sale of non-traditional exchange-traded funds (ETFS) in accounts where the firm provided brokerage services to certain retail customers and the firm failed to provide adequate formal training and guidance to its registered representatives and supervisors regarding non-traditional ETFS. The firm allowed its registered representatives to recommend a non-traditional ETF to customers without performing reasonable diligence to understand the risks and features associated with it. Certain firm registered representatives made unsuitable recommendation of non-traditional ETFS to certain customers with conservative income or conservative growth & income investment objectives and/or risk tolerances.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2276},{"d":"2012-04-29","di":"2012-02-16","dr":"2012-04-29","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":85000.0,"dk":"12-NYSE-3","al":"The legal section of the market regulation department at the Financial Industry Regulatory Authority, on behalf of NYSE regulation, inc., alleged that Goldman, Sachs & co. (the \"firm\") in its capacity as a NYSE supplemental liquidity provider (SLP) during the period between January 2009 and at least September 2011, failed to maintain supervisory procedures, including a system of follow-up and review, that were reasonably designed to detect and prevent potentially violative wash trading activity, in alleged violation of NYSE rule 342.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into a stipulation of facts and consent to penalty with NYSE regulation, inc., which was approved by the NYSE hearing board on April 4, 2012 and became final on April 29, 2012. On April 16, 2012, the firm submitted a wire in payment of the fine in the amount of $85,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2277},{"d":"2012-04-25","di":"2012-02-17","dr":"2012-04-25","k":"Regulatory Action","rg":"Other","reg":"American Stock Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":50000.0,"dk":"12-AMEX-2","al":"Stipulation of facts and consent to penalty filed by the legal section of the market regulation department at FINRA and pending NYSE AMEX: consented to findings: for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated stipulated that it: 1. Violated Regulation SHO rule 203 (b)(3) during the period of January 2006 through June 2008, by failing to close out 22 fail to deliver positions in four separate securities, that existed between 14 days to 50 days. 2. Violated AMEX rule 324, during the period of November 19, 2007 through December 27, 2007, by incorrectly booking a trade, which caused the firm to maintain inaccurate records and report inaccurate information to the national securities clearing corporation. 3. Violated AMEX rule 320 during the period of January 2006 through June 2008, by failing to implement and maintain adequate procedures of supervision and control, including a separate system follow-up and review, reasonably designed for compliance with reg sho rule 203(b)(3). Stipulated sanction: censure and fine in the amount of $50,000","res":"Decision","sm":"**3/29/12** a review of this decision may be requested only by a member of the NYSE entities identified in NYSE rule 476(g) within 25 days from the date of this letter. If a review of the decision is requested, you will be promptly notified. If no review is requested, the decision will become final at the close of business on April 25, 2012. 04/27/2012**decision became final as of the close of business, April 25, 2012.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2278},{"d":"2012-04-24","di":"2012-02-08","dr":"2012-04-24","k":"Regulatory Action","rg":"Other","reg":"Hong Kong Stock Exchange","san":"Censure","st":"Final","al":"In a letter to Goldman Sachs Structured products (ASIA) limited (\"GSSPA\") dated February 8, 2012, the stock exchange of Hong Kong limited (\"HKEX\") listing division (the \"division\") informed GSSPA that, having reviewed certain facts and circumstances regarding four nikkei linked warrants issued by GSSPA on February 17, 2011 (the \"warrants\"), the division was of the view that GSSPA had breached certain provisions in the listing agreement between GSSPA and HKEX (the \"listing agreement\") and the HKEX listing rules due to errors in the listing documentation and for not requesting a trade suspension of the warrants as soon as reasonably practicable on March 31, 2011.","res":"Settled","sm":"The division's assertions were referred to the committee. Without admitting or contesting the division's assertions, gsspa entered into a settlement agreement with hkex, which was endorsed by the committee on April 24, 2012, in which hkex censured gsspa for having breached certain provisions in the listing agreement. In considering the overall sanction to be imposed on gsspa, the committee took into account that: (I) this was an isolated incident, there being no record of an earlier failure of this nature by gsspa; (II) the errors appeared to result from human error rather than a systemic failure; (III) the warrants had, despite certain errors, traded in accordance with their intended economics for a period of approximately six weeks from their issuance prior to March 31, 2011 with no unusual price movements; (IV) gsspa notified hkex of the errors promptly and prior to the opening of the market on March 31, 2011, and thereafter maintained a frequent and candid dialogue with hkex; (v) gsspa cooperated with hkex, including agreeing to a trading suspension when the suggestion was made by hkex on March 31, 2011; (VI) there was no precedent for requesting a suspension from trading of Hong Kong listed warrants in these circumstances; (VII) the trading activity that resulted in unusual price movement on March 31, 2011 did not involve gsspa as liquidity provider or in any other capacity; (VIII) gsspa offered compensation to all affected investors through a buyback program; (IX) gsspa had certain internal controls in place for document review at the relevant time and has since implemented remedial measures addressing hkex's regulatory concerns; (x) gsspa has been a very active participant in the warrants industry working group formed to consider issues, including the standardization of documentation, so as to ensure the continuing success and high standards of the Hong Kong warrants market; (XI) gsspa voluntarily withdrew from issuing new warrants from April to November 2011 and focused on resolving this incident; and (XII) gsspa fully cooperated with the division throughout its investigation and has a clean disciplinary record.","ab":"Goldman Sachs Structured","firms":[361],"id":2279},{"d":"2012-04-24","di":"2012-04-24","dr":"2012-04-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":55000.0,"dk":"2009020826501","al":"FINRA rule 2010, 6380a, 6182, 7450; NASD rule 2111(a), 2320, 3010; SEC rule 17A-3, 17A-4, 200(g), and rule 611(a)(1). In the third quarter of 2009 in certain instances the firm failed to execute orders fully and promptly and failed to use reasonable diligence to ascertain the best interdealer market available. Additionally in December 2009 in certain instances the firm incorrectly marked its ledger as long when the firms position was short, failed to maintain customer confirmations, failed to accurately document proprietary positions, failed to show correct order entry and failed to provide order memoranda. The firm also incorrectly reported the second leg of certain riskless principal transactions and transmitted inaccurate formatted orders to OATS. The firm executed short sale transactions and failed to append a short sale modifier to TRF and executed short sale orders and failed to mark the order as short. Additionally the firm's written supervisory procedures failed to provide for the minimum requirements with respect to the rules of FINRA and the SEC in the following subject areas: order handling; best execution; anti-intimidation; trade reporting; sale transactions; trade halts; errors; soft dollar accounts; OATS; sub-penny rules; electronic communication; trade throughs of protected quotations in NMS stocks; backing away; and information barriers.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings the firm consented to a censure, a fine in the amount of $55,000 and an undertaking to revise its WSPS with respect to order handling; best execution; anti-intimidation; trade reporting; sale transactions; trade halts; errors; soft dollar accounts; OATS; sub-penny rules; electronic communication; trade throughs of protected quotations in NMS stocks; backing away; and information barriers.","sm":"Without admitting or denying the findings, Janney entered into an AWC consenting to a censure and fine of $55,000 related to NASD and FINRA rule violations stemming from a market order timeliness(\"MOT\") sweep for the 3RD quarter of 2009 as well as findings related to the trading and market making surveillance (\"TMMS\") examination of the firm in January 2010. The firm has updated its written supervisory procedures to address these findings.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2280},{"d":"2012-04-24","di":"2012-04-24","dr":"2012-04-24","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Stock Market","san":"Censure","os":"Censure and fine","st":"Final","fine":10000.0,"dk":"20090208265-02","al":"Nasdaq rules 4755, 2110, and 3010: during December 2009 the firm entered 29 orders to the Nasdaq market that failed to correctly indicate whether the orders were a buy, long sale or short sale. In addition the firm's written supervisory procedures failed to provide for the minimum requirements with respect to the rules of Nasdaq in the following subject areas: accuracy of Nasdaq order entry information; refraining from locking or crossing an existing quote on Nasdaq; and clearly erroneous transactions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings the firm consented to a censure, a fine in the amount of $10,000 and an undertaking to revise its WSPS with respect to Nasdaq order entry information, quote surveillance and clearly erroneous transactions.","sm":"Without admitting or denying the findings, Janney entered into an AWC with Nasdaq consenting to a censure and fine of $10,000 for violations of Nasdaq rules 4755, 2110, and 3010. These violations relating to findings from the firm's January 2010 trading and market making surveillance (\"TMMS\") examination. The firm has updated it written supervisory procedures to address these findings.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2281},{"d":"2012-04-12","di":"2012-04-12","dr":"2012-04-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; censure; undertaking","st":"Final","fine":22000000.0,"dk":"3-14845","al":"The U.S. Securities and Exchange Commission (the \"SEC\") has alleged that the huddles program of Goldman, Sachs & co. (the \"firm\") -a practice where the firm's equity research analysts allegedly provided their best trading ideas to firm traders and a select group of the firm's top clients-created a serious and substantial risk that analysts would share material nonpublic information concerning their published research with asymmetric service initiative (\"ASI\") clients and firm traders. The SEC alleged that the firm willfully violated section 15(g) of the Exchange Act by failing establish, maintain, and enforce adequate policies and procedures to prevent such misuse in light of the risks arising from the huddles and ASI.","res":"Order","sm":"Without admitting or denying the violations, the firm consented to the entry of an order instituting administrative and cease- and-desist proceedings pursuant to sections 15(b) and 21c of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease and desist order on April 12, 2012 (the \"order\") by the SEC pursuant to which firm (I) shall cease and desist from committing or causing any violations and any future violations of section 15(g) of the Exchange Act; (II) is censured; (III) paid a total civil money penalty of $22 million on April 19, 2012, $11 million of which was paid to the Financial Industry Regulatory Authority in a related proceeding, and $11 million of which was paid to the SEC, and (IV) shall comply with certain other undertakings, including a comprehensive review, including recommendations, of the policies, procedures and practices maintained and implemented by the firm pursuant to section 15(g) of the Exchange Act that relate to the findings of the order.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2282},{"d":"2012-04-12","di":"2012-04-12","dr":"2012-04-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; undertaking","st":"Final","fine":22000000.0,"dk":"2009019301201","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") has alleged that a formalized business process at Goldman, Sachs & co. (the \"firm\") known as trading huddles as well its asymmetric service initiative (\"ASI\") created a substantial risk that material non- public information concerning research analysts' published research could be disclosed to certain priority clients. FINRA further alleged that the firm violated (I) NASD rules 3010 and 2110 and FINRA rule 2010 by institutionalizing trading huddles and ASI without establishing adequate policies, procedures and controls; (II) NASD rules 3010 and 2110 and FINRA rule 2010 by failing to establish, maintain and enforce reasonable systems and procedures to supervise research analyst communications to prevent and detect the previewing of material non-public changes to an analyst's published research by equity research analysts and to monitor for possible trading in advance of published research or conviction list changes; and (III) FINRA rules 5280 and 2010 by failing to establish and maintain policies and procedures reasonably designed to prevent trading ahead of research reports.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the violations, the firm entered into a letter of acceptance, waiver and consent on April 12, 2012 (the \"AWC\") with FINRA pursuant to which the firm consented to (I) a censure; (II) a fine in the amount of $22 million, which was paid on April 19, 2012, of which $11 million was paid according to an administrative order issued by the U.S. Securities and Exchange Commission relating to its investigation of the firm's trading huddles; and (III) undertake a comprehensive review of the firm's supervisory and compliance policies and procedures concerning the allegedly violative conduct addressed in the AWC.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2283},{"d":"2012-04-12","di":"2012-04-12","dr":"2012-04-12","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Bureau of Securities Regulation (\"Bureau\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":447039.74,"dk":"I-2009000004","al":"The bureau alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated (as successor by merger to banc of america securities LLC and banc of america investment services, inc.) (collectively, \"respondents\") inappropriately marketed and sold auction rate securities (\"ARS\") without adequately informing certain of their customers of the increased risks of illiquidity associated with ARS. The bureau alleged that, through this conduct, the respondents engaged in dishonest and unethical practices in the offer and sale of securities and failed to supervise their agents.","res":"Settled","sm":"Without admitting or denying the allegations, the respondents agreed to a series of undertakings designed to provide relief to eligible investors. The respondents, through their affiliate blue ridge, have offered to purchase at par plus accrued and unpaid interest or dividends from eligible investors certain ars that have failed at auction. The respondents have also agreed to use reasonable efforts to identify eligible investors who sold certain ars below par, and to pay such investors the difference between par and the price at which they sold the securities. In addition, the respondents are endeavoring to identify eligible investors who took out certain loans from the respondents that were secured by ars that were not successfully auctioning at the time of the loan, and reimburse them to the extent that the interest rate on the loans exceeded the interest paid on the ars. The respondents have also agreed to participate in a special arbitration process for the purpose of arbitrating any eligible investor's consequential damages claim arising from the inability to sell certain ars. Furthermore, the respondents agreed to refund certain refinancing fees to municipal auction rate issuers that issued such ars through the respondents. The respondents have also undertaken to make their best efforts to work with issuers and other interested parties to seek to provide liquidity solutions for institutional investors that are not considered \"eligible investors.\"","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2284},{"d":"2012-04-10","di":"2007-09-21","dr":"2012-04-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine; restitution","st":"Final","fine":55000.0,"dk":"2006005438901","al":"FINRA rule 4560, NASD rules 2110, 2320, 3010, 3360, MSRB rules G-17, G-30(a) - FINRA alleged that: 1. In 31 corporate fixed income transactions for or with a customer, Edward D. Jones & Co., L.P. failed to use reasonable diligence to ascertain the best inter- dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. 2. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and NASD rules concerning best execution of corporate fixed income transactions. 3. In 10 transactions, the firm purchased municipal securities for its own account from a customer and/or sold municipal securities for its own account to a customer at an aggregate price (including any markdown or markup) that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transactions, the expense involved in effecting the transaction, the fact that the broker, dealer or municipal securities dealer was entitled to a profit, and the total dollar amount of the transaction. 4. The firm submitted inaccurate short interest position reports to NASD or FINRA.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2285},{"d":"2012-04-05","di":"2012-04-05","dr":"2012-04-05","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"The total amount of the settlement is $10,956,615,075.00, and consists of the three components as further described in 13.c.","st":"Final","al":"On March 12, 2012, the Department of Justice and the attorneys general of 49 states and the District of Columbia filed a complaint (\"complaint\") and consent judgment against Bank of America corporation, Bank of America, N.A., bac home loans servicing, LP f/k/a Countrywide home loans servicing, LP, Countrywide home loans, inc., Countrywide Financial corporation, Countrywide mortgage ventures, LLC, and/or Countrywide bank, FSB (together, \"Bank of America\") and other major mortgage servicers to settle a number of related investigations into residential loan servicing and origination practices (the \"settlement\"). The complaint alleged the defendant's misconduct related to its origination and servicing of single family residential mortgages caused the defendants to have violated, among other laws, the unfair and deceptive acts and practices laws of the plaintiff states, the false claims act, the financial institutions reform, recovery, and enforcement act of 1989, the servicemembers civil relief act, and the bankruptcy code and federal rules of bankruptcy procedure.","res":"Settled","sd":"Bank of America corporation and/or its affiliated entities shall pay or cause to be paid into an interest bearing escrow account to be established for this purpose the sum of $2,382,415,075, which sum shall be added to funds being paid by other institutions resolving claims in this matter and according to certain criteria established in the settlement. Up to $120 million of this amount may be treated as a civil penalty. In addition, Bank of America shall provide $7,626,200,000 of relief to consumers who meet certain eligibility criteria relating to servicing of loans. The additional servicing and origination standards include the development of new or enhanced programs to provide borrower assistance, the development of proprietary programs to provide expanded mortgage modification solutions, including the broader use of principal reductions if permitted by the mortgage investor, enhanced programs for unemployed, military service members and other customers with identified special situations, enhanced facilitation of short sales, and the offer of other assistance programs, such as deed-in-lieu of foreclosure and funds for families transitioning out of home ownership. Also, Bank of America shall provide $948,000,000 to a new refinancing program for current consumers who meet other eligibility criteria. The refinancing program is intended to expand refinancing opportunities or lower interest rates on Bank of America owned mortgages to provide reduced payments for many homeowners who are current on their payments but owe more than the current value of their homes. Following finalization of the settlement terms, Bank of America will finalize its program enhancements and provide additional details of eligibility requirements.","ab":"Bank of America; Bank of America, N.A.; Countrywide Financial","firms":[7691,142558],"id":2286},{"d":"2012-03-22","di":"2012-03-22","dr":"2012-03-22","k":"Regulatory Action","rg":"State regulator","reg":"Utah Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":88007.05,"dk":"SD-12-0023","al":"Various state regulators, including the Utah Division of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the stipulation and consent order, the Utah Division of Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a stipulation and consent order with the Utah Division of Securities on March 22, 2012, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $88,007.05 to the Utah Division of Securities, which amount was paid on April 6, 2012.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2287},{"d":"2012-03-20","di":"2012-03-20","dr":"2012-03-20","k":"Regulatory Action","rg":"Other","reg":"Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":188128.55,"dk":"10-082","al":"Various state regulators, including the Oklahoma Department of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Oklahoma Department of Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Oklahoma Department of Securities on March 20, 2012, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $188,128.55 to the Oklahoma Department of Securities, which amount was paid April 2, 2012.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2288},{"d":"2012-03-12","di":"2012-03-12","dr":"2012-03-12","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Payment of compensatory damages","st":"Final","al":"The complaint alleges that the referenced affiliates violated the Oklahoma consumer protection act by failing to take required action and by taking certain prohibited actions in connection with residential mortgage loans.","res":"Consent","sd":"Compensatory damages in the amount of $3,769,569.70","ab":"Wells Fargo & Company","firms":[11025,19616],"id":2289},{"d":"2012-03-12","di":"2012-03-12","dr":"2012-03-12","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","os":"Compliance with servicing standards and payment of monetary amounts","st":"Final","al":"The complaint alleges that the referenced affiliates: engaged in unfair and deceptive consumer practices with respect to loan servicing, foreclosure proceedings and loan originations; violated the false claims act, the financial institutions reform and recovery act of 1989 and the servicemembers civil relief act; and engaged in bankruptcy misconduct.","res":"Consent","sd":"Monetary payments consist of $1,005,233,716 direct payment settlement amount; $1,489,813,925 borrow payment amount; $3,434,000,000 eligible consumer relief, and $903,000,000 eligible refinancing relief.","ab":"Wells Fargo & Company","firms":[11025,19616],"id":2290},{"d":"2012-03-12","di":"2012-03-12","dr":"2012-03-12","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland Attorney General - Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000.0,"dk":"2011-0312 (AMENDED)","al":"In amended consent order, docket no. 2011-0312, in the matter of Wells fargo advisors, LLC, the Maryland division of securities alleged that Wells fargo advisors, LLC employed eight investment adviser representatives who provided investment advisory services to clients prior to being registered with the securities division as investment adviser representatives pursuant to section 11-402 of the Maryland Securities Act. The division also alleged that the firm failed to timely amend the forms U4 of two of its agents to reflect the change in their employment address pursuant to section 11-411(d) of the Maryland Securities Act and regulation 02.02.02.07 of the code of Maryland regulations. The firm was ordered to pay a fine of $50,000 to the Maryland securities division, less the $5,000 fine the firm paid to the division in August 2011 pursuant to the original consent order issued in this matter. The firm was also ordered to follow the compliance policies and procedures provided to the division in connection with the matter, and comply fully with the Maryland Securities Act and rules and regulations promulgated thereunder.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2291},{"d":"2012-02-22","di":"2012-02-22","dr":"2012-02-22","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist undertaking","st":"Final","fine":83000000.0,"dk":"2012-042","al":"Wells Fargo Bank, N.A. engaged in unsafe or unsound banking practices in connection with residential mortgage foreclosures.","res":"Stipulation and Consent","ab":"Wells Fargo Bank, N.A.","firms":[11025,19616],"id":2292},{"d":"2012-02-15","di":"2012-02-15","dr":"2012-02-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":35000.0,"dk":"2009018644401","al":"MSRB rules G-8, G-14 - Merrill Lynch, Pierce, Fenner & Smith Incorporated failed to report information regarding purchase and sale transactions effected in municipal securities to the real-time transaction reporting system (RTRS) in the manner prescribed by rule G-14 RTRS procedures and the RTRS users manual; the firm failed to report the correct trade time to the RTRS in municipal securities transaction reports and failed to report information for the transactions within 15 minutes of trade time to an RTRS portal. The firm failed to show the correct execution time on the memorandum of transactions in municipal securities for the account of the firm executed with another broker-dealer.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $35,000 for MSRB rule violations.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2293},{"d":"2012-02-15","di":"2012-02-15","dr":"2012-02-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":50000.0,"dk":"2009017180301","al":"FINRA alleged that the firm failed to prohibit executions in short sales subject to the SEC emergency order pursuant to section 12(k)(2) of the securities and Exchange Act of 1934 on certain dates during September 2008.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the imposition of a censure and paid a fine of $50,000 on February 22, 2012.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2294},{"d":"2012-02-10","di":"2012-02-10","dr":"2012-02-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"20090170380-01","al":"During the period from September 1, 2008 through December 31, 2008 (the \"review period\"), FINRA alleged that banc of america securities LLC (which merged into Merrill Lynch, Pierce, Fenner & Smith Incorporated) on November 1, 2010) failed within 90 seconds after execution, to transmit to the FINRA/Nasdaq trade reporting facility (\"FINRA/Nasdaq TRF\") 3,075 late sale reports of transactions in designated securities. The conduct described constitutes separate and distinct violations of NASD rule 4632(a) (for conduct prior to December 15, 2008) and FINRA rule 6380(a) (for conduct on or after December 15, 2008) and a pattern or practice of late reporting without exceptional circumstances in violation of NASD rule 2110 (for conduct prior to December 15, 2008) and FINRA rule 2110 (for conduct on or after December 15, 2008).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, Merrill Lynch, Pierce, Fenner & Smith Incorporated (as successor to banc of america securities LLC) entered into a letter of acceptance, waiver and consent with FINRA in which it agreed to a censure and a fine of $25,000.00.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2295},{"d":"2012-02-10","di":"2012-01-30","dr":"2012-02-10","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois, Secretary of State, Securities Department","san":"Restitution","os":"Reimbursement of cost of investigation.","st":"Final","dk":"FILE NO. 0900049","al":"The State of Illinois, Secretary of State, Securities Department (the \"department\") alleged that, pursuant to the Illinois securities law of 1953 (the \"act\"), section 8.E.1(m), Merrill Lynch, Pierce, Fenner & Smith Incorporated (\"MLPFS\") was subject to suspension and revocation of its registration as a dealer, allegedly for failing reasonably to supervise a former employee pursuant to section 8.E.1(e)(I) and (IV) of the act, resulting in that former employee's alleged violations of section 12.a, f and I of the act.","res":"Consent","sm":"Without admitting or denying the findings of fact or conclusions of law, MLPFS entered into a settlement resulting in a consent order in which it agreed to pay $25,900,000 in restitution and $30,000 in repayment of expenses.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2296},{"d":"2012-02-09","di":"2012-02-09","dr":"2012-02-09","k":"Regulatory Action","rg":"Federal Reserve","reg":"Federal Reserve","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":87000000.0,"dk":"12-010-CMP-HC","al":"Federal Reserve consent order re: bank's mortgage foreclosure practices.","res":"Consent","ab":"Wells Fargo and Company","firms":[11025,19616],"id":2297},{"d":"2012-02-08","di":"2012-02-08","dr":"2012-02-08","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"11-06316","al":"In a routine examination of Goldman, Sachs & co. (the \"firm\"), CME group market regulation (\"CME\") made findings that, from September 29, 2011 through November 25, 2011, certain firm trading documents contained at least one data entry error, in alleged violation of Chicago Mercantile Exchange Inc. rule 536.f.","res":"Consent","sm":"On February 8, 2012, CME fined the firm $5,000 for alleged violations of rule 536.f, and on February 7, 2012, the firm submitted a wire in payment of the fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2298},{"d":"2012-02-08","di":"2012-02-08","dr":"2012-02-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":90000.0,"dk":"20100229121","al":"Schedule a, section 1, of the NASD and FINRA by-laws, FINRA rule 2010 NASD rule 2110: until the end of calendar year 2009, the firm reported revenue on its focus reports net of its payout to its financial advisors, rather than as gross revenue, having determined - based partly on the emerging issues task force (EITF) 99-19 - that its net-basis revenue reporting complied with generally accepted accounting principles (GAAP). The firm had followed this accounting protocol since at least 2001, and had alluded to it in its audited financial statements. At the beginning of 2009, a company acquired the firm as part of the company's acquisition of another company, and thereafter proceeded to evaluate the firm's business practices in relation to a separate existing member firm that the acquiring company owned. As a result of that process, the firm changed its practices to reflect and report its revenue on a gross basis. The firm contacted FINRA in November 2009 to advise that the firm's upcoming audited annual financial statement and focus report would reflect a significant change in revenues for calendar year 2009. These year- end 2009 reports reflected approximately $200 million in additional revenues and expenses for the year. For each calendar year from 2001 through 2008, FINRA sent the firm an invoice for the firm's gross income assessment, which FINRA member firms are required to pay pursuant to schedule a, section 1 of FINRA's by-laws. During that period, NASD and FINRA calculated the firm's gross income assessments (GIA) according to the revenue that the firm reported for the previous year in its focus filings. The firm paid these invoices in full. After learning of the firm's history of reporting its revenue on a net basis, FINRA determined that the firm had underpaid its gross income assessments by a total of $595,301.84 between 2001 and 2008. The firm has since paid that amount in full.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2299},{"d":"2012-02-03","di":"2011-12-14","dr":"2012-02-03","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"12-NYSE-1","al":"The legal section of the market regulation department at the Financial Industry Regulatory Authority, on behalf of NYSE regulation, inc, alleged that Goldman, Sachs & co. (the \"firm\") failed : (I) (I) on five occasions between November 14, 2008 and August 5, 2009, to timely submit the Regulation M trading notice to the NYSE in connection with distributions on an NYSE-listed company in which the firm acted as an underwriter or manager and (II) to notify the NYSE of the firm's intention to engage in certain syndicate covering transactions on April 27-28, 2010 and May 18, 2010, prior to engaging in the transactions, in connection with an offering of a security for which the firm was lead manager, each in alleged violation of NYSE rule 5190; (II) on two occasions between June 4, 2009 and March 5, 2010, to timely notify the NYSE of its participation in a distribution for which its affiliated designated market-maker (DMM) was registered, in alleged violation of NYSE rule 460.30; and (III) to reasonably supervise compliance with NYSE rules 5190 and 460.30, by failing to have a reasonable system of follow-up and review to determine if its reporting policies and procedures with respect to such rules were followed, in alleged violation of NYSE rule 342.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into a stipulation of facts and consent to penalty with NYSE regulation, inc., which was approved by the NYSE hearing board on January 9, 2012 and became final on February 3, 2012. On January 26, 2012, the firm submitted a wire in payment of the fine in the amount of $10,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2300},{"d":"2012-02-03","di":"2012-02-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":55000.0,"dk":"2009018104101","al":"MSRB rules G-17, G-30(a) - banc of america investment services, inc. (which was merged with and into Merrill Lynch, Pierce, Fenner & Smith Incorporated on October 23, 2009) purchased municipal securities for its own account from a customer and/or sold municipal securities for its own account to a customer at an aggregate price (including any markdown or markup) that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer or municipal securities dealer is entitled to a profit, and the total dollar amount of the transaction.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $55,000 for MSRB rule violations. The firm has already paid restitution to the customers involved with the transactions.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2301},{"d":"2012-01-30","di":"2012-01-30","dr":"2012-01-30","k":"Regulatory Action","rg":"Other","reg":"Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":295450.0,"dk":"ORDER NO. 11-000815-01-S","al":"The Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities (division), alleged that in connection with the sale of securities in Alaska by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in Alaska, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a violation of as 45.55.05(k), failed to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures and failure to reasonably supervise its agents in violation of as 45.55.060(b)(1), violated the agent registration provisions of as 45.55.030(a) and (b), and sold securities in Alaska through unregistered CAS in violation of as 45.55.030 (a) and (b).","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the division describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2302},{"d":"2012-01-25","di":"2012-01-25","dr":"2012-01-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1000000.0,"dk":"2009020188101","al":"FINRA rules 2010, 13200(a): in January 2009, the firm implemented advisor transition program (ATP) to retain high producing registered representatives during the period when the firm was acquired by bank of america corporation. The firm structured the ATP program to allow it to avoid complying with its obligation to arbitrate disputes with its associated persons concerning ATP payments. The ATP payments were documented so that the promissory notes stated that the loans were being made to the registered representatives by a non-registered affiliate of the firm. However, the funding for the ATP loans was actually provided to the firm by its parent company, and not by the non-registered affiliate of the firm. The funds were provided by the parent company to an account at the firm in the name of the firm's affiliate, which in turn made a payable entry on its books for the amount of the ATP funding. The loans were serviced by the firm. Each of the registered representatives who received an ATP loan was required to sign a promissory note. In the promissory note, the registered representative agreed to repay the balance due on the loan to the firm's affiliate when the registered representative's employment with the firm terminated. The promissory notes were drafted by the firm and stated that any actions regarding the note, including actions to recover amounts due under the note, shall be brought solely in the Supreme Court of the state of New York in New York county. The notes also required registered representatives to consent to the jurisdiction of the New York state courts for any action or proceeding relating to the note. Other than the promissory note, the firm's registered representatives had no relationship with the affiliate of the firm. The language described was included in the promissory notes so the firm could pursue collections of amounts due under the loans through the firm's affiliate in expedited proceedings in New York state court. New York law specifically provides for such proceedings for non-payment of money amounts due and greatly limits defendants' ability to assert counterclaims in such actions. In 2009, a number of registered representatives who had received ATP loans left the firm, or were terminated by the firm, and failed to repay amounts due under the ATP. To pursue collection of outstanding ATP loan balances from those registered representatives, the firm filed summary collection proceedings in New York state court in the name of the firm's affiliate. Between January 2009 and November 2009, the firm filed over 90 such actions in New York state court. These proceedings involved disputes between the firm and the registered representatives relating to the business activities of both the firm and the representatives. As such, rule 13200(a) of FINRA's code of arbitration procedure required that the proceedings be brought as arbitration proceedings, and not as expedited proceedings in New York state court. The firm designed the ATP program to avoid instituting arbitration proceedings to collect amounts due from registered representatives who had left the firm. The firm structured the program so it appeared that the funds for the ATP loans came from an affiliate of the firm, a non-registered affiliate, and not from the firm itself. (Continued in section 13 below)","res":"Acceptance, Waiver & Consent(AWC)","sm":"(Continued from section 7. Above) the firm also placed language in the promissory notes used in the atp program that stated that actions to recover amounts due under the notes could be brought only in New York state court. In these ways, the firm designed the atp program to allow it to pursue recovery of amounts due from the atp loans through its affiliate in expedited proceedings in New York court, and thus to avoid the firm's requirement to arbitrate disputes with its associated persons.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2303},{"d":"2012-01-25","di":"2012-01-25","dr":"2012-01-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12500.0,"dk":"2008016382201","al":"NASD rules 6230(b), 6230(c)(6) - Merrill lynch failed to report to the trade reporting and compliance engine (TRACE) transactions in TRACE-eligible securities that it was required to report, and the firm failed to report to TRACE the correct contra-party's identifier for transactions in TRACE-eligible securities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore, the firm is censured and fined $12,500.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2304},{"d":"2012-01-20","di":"2012-01-20","dr":"2012-01-20","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":352050.0,"dk":"2011-7-17","al":"The Idaho Department of Finance (department), alleged that in connection with the sale of securities in Idaho by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in Idaho, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a failure to establish, maintain, and enforce written supervisory procedures as required by idapa 12.01.08.105.01, and failed to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures in violation of idapa 12.01.08.105.03.","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the department describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2305},{"d":"2012-01-10","di":"2012-01-10","dr":"2012-01-10","k":"Regulatory Action","rg":"State regulator","reg":"Illinois Securities Department (\"Department\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":1578320.87,"dk":"08-00204","al":"The department alleged that Merrill Lynch, Pierce, Fenner & Smith Incorporated (as successor by merger to banc of america securities LLC and banc of america investment services, inc.) (collectively, \"respondents\") inappropriately marketed and sold auction rate securities (\"ARS\") without adequately informing certain of their customers of the increased risks of illiquidity associated with ARS. The department alleged that, through this conduct, the respondents engaged in dishonest and unethical practices in the offer and sale of securities and failed to supervise their agents.","res":"Settled","sm":"Without admitting or denying the allegations, the respondents agreed to a series of undertakings designed to provide relief to eligible investors. The respondents, through their affiliate blue ridge, have offered to purchase at par plus accrued and unpaid interest or dividends from eligible investors certain ars that have failed at auction. The respondents have also agreed to use reasonable efforts to identify eligible investors who sold certain ars below par, and to pay such investors the difference between par and the price at which they sold the securities. In addition, the respondents are endeavoring to identify eligible investors who took out certain loans from the respondents that were secured by ars that were not successfully auctioning at the time of the loan, and reimburse them to the extent that the interest rate on the loans exceeded the interest paid on the ars. The respondents have also agreed to participate in a special arbitration process for the purpose of arbitrating any eligible investor's consequential damages claim arising from the inability to sell certain ars. Furthermore, the respondents agreed to refund certain refinancing fees to municipal auction rate issuers that issued such ars through the respondents. The respondents have also undertaken to make their best efforts to work with issuers and other interested parties to seek to provide liquidity solutions for institutional investors that are not considered \"eligible investors.\"","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2306},{"d":"2012-01-09","di":"2011-12-14","dr":"2012-01-09","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"12-ARCA-1","al":"The legal section of the market regulation department at the Financial Industry Regulatory Authority, on behalf of NYSE regulation, inc., alleged that, due to the inadvertent introduction of a programming error into a surveillance report designed to detect potential violations of rule 105 of Regulation M, and which has since been corrected, Goldman, Sachs & co. (the \"firm\"), from in or about October 2007 through August 2008, did not maintain an adequate supervisory system reasonably designed to detect potential violations of rule 105 of Regulation M, in alleged violation of NYSE ARCA equities rule 6.18(b).","res":"Decision & Order of Offer of Settlement","sm":"Without admitting or denying the allegations, the firm consented to a fine and censure and entered into an offer of settlement and consent with NYSE regulation, inc., on behalf of NYSE ARCA, Inc., which was accepted by the NYSE ARCA hearing board on January 9, 2012, and on January 26, 2012, the firm submitted a wire in payment of the fine in the amount of $40,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2307},{"d":"2012-01-03","di":"2012-01-03","dr":"2012-01-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"20090191679-01","al":"During the period from April 1, 2009 through June 30, 2009 (the \"review period\"), FINRA alleged that banc of america securities LLC (which merged into applicant on November 1, 2010) failed to report to TRACE 4,429 transactions in TRACE-eligible securities within 15 minutes of the time of execution. These late transactions constituted 5.31% of the transactions in TRACE-eligible securities that banc of america securities LLC reported to TRACE during the review period (83,335). FINRA alleged the conduct described in this item 7 constituted separate and distinct violations of FINRA rule 6730 and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, banc of america securities LLC entered into a letter of acceptance, waiver and consent with FINRA in which it agreed to a censure and a fine of $10,000.00.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2308},{"d":"2011-12-27","di":"2011-12-27","dr":"2011-12-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Suspension","os":"Principals of the firm were suspensed in principal capacity for ten business days.","st":"Final","fine":15000.0,"dk":"2009018524501","al":"NASD rules 2110, 3010, 3040(c): mcadams, his member firm, and lee, failed to reasonably supervise the participation of one of the firm's registered representatives in private securities transactions that the firm had received prior written notice of and approved, and failed to record these transactions on the firm's books and records. Mcadams is the chairman and sole owner of the firm. Mcadams was the person designated with the ultimate authority to determine whether a registered representative at the firm could engage in private securities transactions. Mcadams, on behalf of the firm, entered into a stock purchase agreement with a business entity, owned by a registered representative associated with the firm, for the sale of 100% of the stock of the firm. In connection with this agreement, the registered representative informed mcadams and another principal, in writing and orally, that the representative needed to raise funds to operate the branch office of the firm where the representative was working, and in order to finance the purchase of the firm. After the execution of the agreement, mcadams and the principal, acting on behalf of the firm, approved of the representative's participation in private securities transactions to raise money through the representative's business entity through the issuance of promissory notes. The representative raised $980,000 from the sale of promissory notes issued by the representative's business entity to some individuals. Mcadams, his firm and the principal, failed to supervise the representative's participation in the private securities transactions as if they were transactions of the firm or in a manner reasonably designed to achieve compliance with the laws, rules and regulations that applied to the representative's private securities sales away from the firm. Moreover, mcadams, his firm, and the principal, failed to ensure that the representative's private securities transactions were recorded on the books of the firm.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Principals of the firm were suspensed in principal capacity for ten business days.","sm":"The case is closed.","ab":"Lee, Faith","firms":[29037],"id":2309},{"d":"2011-12-19","di":"2011-12-19","dr":"2011-12-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"20110260449-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of enforcement alleged that during the period of April 1, 2007 through September 30, 2010, Goldman, Sachs & co. (the \"firm\") failed to comply with municipal securities rulemaking board (\"MSRB\") rules G-32 and G-36, in certain respects. More specifically, FINRA department of enforcement alleged that the firm filed 72 out of 934 filings late, resulting in an overall failure rate during the review period of 7.7 percent, in alleged violation of MSRB rules G-36 and G-32.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations or findings, the firm consented to a censure and fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on December 19, 2011 and on January 4, 2012, the firm submitted a wire in payment of the fine in the amount of $7,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2310},{"d":"2011-12-16","di":"2011-12-16","dr":"2011-12-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"A censure, fine and undertaking","st":"Final","fine":12500.0,"dk":"20080141700-01","al":"Between June 1, 2007 and May 31, 2009, it is alleged that Janney reported 12,733 transactions on OTC securities which it was not required to report and that the firm's supervisory system was not reasonably designed to achieve compliance with applicable securities laws concerning trade reporting.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$12,500.00 paid by credit card on 12/28/2011.","sm":"The firm has updated its written supervisory procedures with respect to trade reporting transactions by way of a give up agreement.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2311},{"d":"2011-12-16","di":"2011-12-16","dr":"2011-12-16","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7000.0,"dk":"2008012707301","al":"NASD rule 3340: for the period between July 1, 2007 through December 31, 2007, the firm directly and/or indirectly effected 35 transactions in securities while a trading halt was in effect with respect to each of the securities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore it is censured and fined $7,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2312},{"d":"2011-12-14","di":"2011-08-12","dr":"2011-12-14","k":"Regulatory Action","rg":"Other","reg":"Australian Securities Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":49520.0,"dk":"E2010029","al":"In a contravention notice dated August 12, 2011 (the \"notice\"), the Australian Securities Exchange (\"ASX\") alleged that, during the period from November 4, 2009 to August 6, 2010 (the \"relevant contravention period\"), (I) Goldman Sachs Australia pty LTD (\"GS Australia\", formerly known as Goldman Sachs & partners Australia pty LTD) contravened ASX market rule 7.11.1 by failing to comply with the relevant provisions of the Australian corporations act (and its accompanying regulations) governing the keeping and treatment of money paid, or property given, to GS Australia in connection with services provided to, or products held by, clients of GS Australia, and (II) GS Australia contravened ASX market rule 7.11.10 by failing to perform a reconciliation in relation to the relevant trust account in the time, form and manner required by the ASX.","res":"Decision","sm":"The alleged contraventions were referred to the tribunal for determination. On December 14, 2011, the tribunal determined that GS Australia contravened asx market rules 7.11.1 and 7.11.10 during the relevant contravention period in the manner alleged in the notice, and imposed of a fine of au$50,000, plus tax. In determining the penalty, the tribunal took into account that: (I) GS Australia has previous disciplinary history, not withstanding that GS Australia has no disciplinary history regarding the matters relevant to the misconduct; (II) the relevant conduct had the potential to damage the reputation and integrity of the asx and the market and facilities it operates; (III) the misconduct was self-reported in a timely and comprehensive manner; (IV) GS Australia fully co-operated with asx in relation to the conduct of its investigation into the contraventions; (v) GS Australia agreed at the earliest opportunity not to contest the contraventions; (VI) the misconduct was unintentional and in a number of cases the conduct was the responsibility of an unrelated third party; (VII) at no stage was any market transaction not enabled because of the misconduct; (VIII) there was no commercial advantage or financial benefit obtained because of the misconduct; (IX) there were no losses suffered by clients, or compensation claims or complaints made by clients in relation to the contraventions and (x) GS Australia promptly implemented remedial measures to seek to prevent any recurrence of the contravening conduct.","ab":"Goldman Sachs Australia","firms":[361],"id":2313},{"d":"2011-12-08","di":"2011-12-08","dr":"2011-12-08","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":500000.0,"dk":"2008015717401","al":"FINRA rule 2010, NASD rules 2110, 3010: during the period 2006-2009, the firm failed to establish and enforce effective written supervisory procedures and supervise its total return swaps business. Because of its supervisory failures, the firm was unable to demonstrate that the swaps were properly structured and supervised with particular regard to yield enhancement payments. The firm failed to establish and maintain written supervisory procedures that were reasonably designed to ensure compliance with applicable laws and regulations. The firm's procedures were inadequate in some respects, and in other respects were not appropriately enforced by the firm. Areas in which the firm exhibited such supervisory deficiencies involved the following: (1) initial absence of written procedures; (2) failure to document and review early terminations, as the procedures required; (3) short-term transactions; and (4) market-on-close pricing. The firm initially lacked any written procedures regarding its total return swap program, and failed to institute such procedures until October 2006. In practice, despite the general limitations in the procedures, swaps were often terminated early. In the period 2006-2007, when the firm failed to document and carry out after-the-fact review of swaps that were terminated early, 598 swaps were open for less than 45 days and, of these, 215 were open for less than 25 days and 78 for less than 15 days. Because the firm did not initially have written supervisory procedures, and because the firm failed to provide the supervisory review that its procedures subsequently required, swaps could be opened and closed in a few days' time, at prices that allowed market risk to be minimized.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings; therefore it is censured and fined $500,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2314},{"d":"2011-12-08","di":"2011-12-08","dr":"2011-12-08","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptroller of the Currency (\"OCC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000000.0,"dk":"# 2011 - 174; AA - EC - 11-97","al":"The ooc alleged that, from at least 1997 through at least 2006, wachovia bank, N.A. and first union national bank (\"wachovia bank\"), predecessors to Wells fargo bank, N.A., engaged in illegal conduct and/or unsafe or unsound banking practices in connection with the marketing and sale of certain derivative financial products to certain municipalities and other non-profit organizations (\"counterparties\") in certain competitively bid transactions.","res":"Consent","sm":"The OCC alleged that wachovia bank won bids for the temporary investment of proceeds from the sale of tax-exempt municipal securities by, among other things, participating in schemes with outside individuals to agree on bids and to artificially set prices in connection with the sale of certain derivative financial products to certain municipalities and non-profit organizations, submitting false or sham courtesy bids, communicating with direct competitors and./or coordinating with third party brokers to fix bid prices, and/or coordinating with direct competitors and/or third party brokers to determine which bidder would win a particular transaction. Wells fargo bank, N.A. resolved this matter by agreeing to the sanctions and restitution outlined above and further undertakings with respect to: its compliance, training and audit programs; assessing and evaluating its competitive bidding activities; and preparing and submitting annual reports concerning the effectiveness of its supervisory control policies and procedures.","ab":"Wells Fargo Bank, N. A.","firms":[11025,19616],"id":2315},{"d":"2011-12-08","di":"2011-12-08","dr":"2011-12-08","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Disgorgement injunction","st":"Final","fine":25000000.0,"al":"The SEC alleged fraudulent bidding practices, from at least 1997 through at least 2005, by wachovia bank, N.A. (\"wachovia bank\"), predecessor to Wells Fargo Bank, N.A., involving the temporary investment of proceeds from the sale of tax-exempt municipal securities in certain investment instruments by state and local governmental entities, affecting the prices of the investment instruments, depriving municipalities of a conclusive presumption that their investment instruments were purchased at fair market value and/or jeopardizing the tax-exempt status of the underlying municipal securities.","res":"Consent","sd":"The court permanently restrained and enjoined Wells Fargo Bank, N.A. from future violations of section 17(a) of the Securities Act of 1933. The court also found Wells Fargo Bank, N.A. liable for disgorgement of $13,802,984.00, prejudgment interest thereon in the amount of $7,275,607.00, and a civil penalty in the amount of $25,000,000.00. Wells Fargo Bank, N.A. was ordered to pay the aggregate of the foregoing amounts totaling $46,078,591.00 to the entities and in the amounts directed by the court within 60 days of entry of the final judgment.","ab":"Wells Fargo Bank, N. A.; Wells Fargo Bank, N.A.","firms":[11025,19616],"id":2316},{"d":"2011-11-29","di":"2011-08-09","dr":"2011-11-29","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"11-08270","al":"Pursuant to an annual CTR pit/back office audit conducted by the applicant's futures sro, the Chicago board of trade (\"CBOT\"), the applicant was found to have violated CME rule 536.f when trade data reviewed for the trade dates of August 9 and 10, 2011 reflected an unacceptable CTR error rate of 37.50%.","res":"Settled","sm":"Without admitting or denying the findings, the applicant agreed to settle the matter with the payment of a fine in accordance with the automatic fine schedule.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2317},{"d":"2011-11-15","di":"2011-11-15","dr":"2011-11-15","k":"Regulatory Action","rg":"State regulator","reg":"New Mexico Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":73187.42,"dk":"11-11-998-003","al":"Various state regulators, including the New Mexico Securities Division, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the New Mexico Securities Division alleged that Goldman, Sachs & co. (\"the firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the New Mexico Securities Division on November 15, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $73,187.42 to the New Mexico Securities Division, which amount was paid on November 23, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2318},{"d":"2011-11-03","di":"2011-11-03","dr":"2011-11-03","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1755209.9,"dk":"0559-S-4/11","al":"Various state regulators, including the Florida Office of Financial Regulation, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent agreement and final order, the Florida Office of Financial Regulation alleged that Goldman, Sachs & co. (\"the firm\") failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent agreement and final order with the Florida Office of Financial Regulation on November 3, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,755,209.90 to the Florida Office of Financial Regulation, which amount was paid on November 14, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2319},{"d":"2011-11-02","di":"2011-11-02","dr":"2011-11-02","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":410062.5,"dk":"11-043","al":"Various state regulators, including the Ohio Division of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Ohio Division of Securities alleged that Goldman, Sachs & co. (\"the firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Ohio Division of Securities on November 2, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $410,062.50 to the Ohio Division of Securities which amount was paid on November 15, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2320},{"d":"2011-11-02","di":"2011-11-02","k":"Regulatory Action","rg":"Other","reg":"Department of Insurance, Securities and Banking of the Government of the District of Columbia","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":98427.93,"dk":"SB-CO-24-11","al":"Various state regulators, including the Department of Insurance, Securities and Banking of the Government of the District of Columbia, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Department of Insurance, Securities and Banking of the Government of the District of Columbia alleged that Goldman, Sachs & co. (\"the firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Department of Insurance, Securities and Banking of the Government of the District of Columbia on November 2, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $98,427.93 to the Department of Insurance, Securities and Banking of the Government of the District of Columbia, which amount was paid on November 14, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2321},{"d":"2011-10-27","di":"2011-10-27","dr":"2011-10-27","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":176017.95,"dk":"16249","al":"Various state regulators, including the Minnesota Department of Commerce, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Minnesota Department of Commerce alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Minnesota Department of Commerce on October 27, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $176,017.95 to the Minnesota Department of Commerce, which amount was paid on November 3, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2322},{"d":"2011-10-24","di":"2011-10-24","dr":"2011-10-24","k":"Regulatory Action","rg":"Other","reg":"District of Columbia, Department of Insurance, Securities and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking; reprimand","st":"Final","fine":434215.0,"dk":"SB-CO-09-11","al":"The District of Columbia, Department of Insurance, Securities and Banking (department) alleged that in connection with the sale of securities in the District of Columbia by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in the District of Columbia, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a failure to reasonably supervise, failed to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures, and sold securities in the District of Columbia through unregistered CAS.","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the department describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2323},{"d":"2011-10-24","di":"2011-10-24","dr":"2011-10-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine of $350,000.00","st":"Final","fine":350000.0,"dk":"20090206307","al":"NASD rules 2110, 3010(b)(1): the firm failed to establish, maintain and enforce adequate written procedures related to the restoration or release of accounts from abandoned status. The firm's written procedures required that employees wishing to restore customer accounts from an abandoned status send a written request to its escheatment group to restore the account. The firm's written procedures failed to identify the firm personnel who were authorized to submit requests to have abandoned accounts restored or released from abandoned status. Escheatment accepted requests to restore abandoned accounts from branch office personnel working in the branch office where the abandoned account was last serviced. The firm's written procedures did not require that the requestor obtain supervisory approval before submitting requests to have abandoned accounts restored or released from abandoned status, did not require the requestor to submit proof to escheatment that a customer had been located and did not require the requestor to submit proof to escheatment of the customer's new address. The firm's procedures also did not require that escheatment notify branch office managers when accounts were restored to active status. After the restoration of an abandoned account, the requestor was required to submit a change of address request with the customer's new address to the firm's new accounts group. Upon receipt of the address change requests, the firm changed the address of record of the restored account and sent letters confirming the change of address to both the customer's new and old address, although the old address was invariably an invalid address. The firm's deficient procedures facilitated a firm operations manager's conversion of approximately $850,000 in customers' funds for her personal use and enabled the operations manager's conduct to escape detection by the firm.","res":"Acceptance, Waiver & Consent(AWC)","sm":"In April 2011, the Financial Industry Regulatory Authority (\"FINRA\") notified Wells fargo advisors, L.L.C. (\"Wells fargo\") of its intent to recommend that Wells fargo be subject to disciplinary action for violations of NASD rule 3010(b)(1) and FINRA rule 2010 for its failure, from October 2005 - March 2007, to establish and maintain adequate procedures for the restoration of accounts from \"abandoned\" to \"active\" status. During that time, a registered principal of WACHOVIA securities, LLC (\"WACHOVIA\"), n/k/a Wells fargo advisors,LLC misappropriated approximately $847,188.87 of assets from abandoned client accounts by fraudulently restoring \"abandoned\" accounts to \"active\" status and thereafter forging check and wire transfer documentation to convert \"abandoned\" assets to her own use and benefit. WACHOVIA was a registered broker-dealer and wholly-owned subsidiary of WACHOVIA corporation. WACHOVIA securities, LLC was renamed Wells fargo advisors, L.L.C. After WACHOVIA corporation merged with Wells fargo & company on December 31, 2008. After discovering the fraudulent activity, WACHOVIA restored all funds to each affected account and implemented additional policies and procedures to strengthen oversight of the process through which accounts are restored from \"abandoned\" to \"active\" status. Wells fargo has fully cooperated with the FINRA investigation.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2324},{"d":"2011-10-21","di":"2011-10-21","dr":"2011-10-21","k":"Regulatory Action","rg":"Department of Labor","reg":"South Dakota Department of Labor & Regulation, Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking","st":"Final","fine":418500.0,"al":"The South Dakota Department of Labor & Regulation, Division of Securities (division), alleged that in connection with the sale of securities in South Dakota by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in South Dakota, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a violation of arsd 20:08:03:08 for failure to establish a reasonably designed supervisory system and a failure to enforce reasonably designed procedures, failed to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures, and sold securities in South Dakota through unregistered CAS.","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the division describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2325},{"d":"2011-10-18","di":"2011-10-18","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","st":"On appeal","fine":18471600.0,"al":"Not complying with the regulations pertaining to commissions, costs and revenues of the funds afected in relation to certain rebates.","res":"Judgment Rendered","sd":"$18,471,600","ab":"Santander Asset Management SA Sgiic","self":true,"firms":[143883],"id":2326},{"d":"2011-10-13","di":"2011-10-13","dr":"2011-10-13","k":"Regulatory Action","rg":"Other","reg":"ICE Futures U.S., Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2011-019","al":"In a notice of summary fine dated October 13, 2011, ICE Futures U.S., Inc. (\"ICE\") compliance department informed Goldman, Sachs & co. (the \"firm\") that, after completing a review of audit trail data corresponding to orders that were routed to the ICE electronic trade system (\"ETS\") through a third-party front-end employed by a client of the firm, ICE compliance department concluded that the firm failed to provide complete electronic audit trail data corresponding to 18 orders that were entered onto the ETS in October 2010, in alleged violation of ICE rule 27.12a.","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a fine in the amount of $5,000 which was paid by submission of a wire on October 21, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2327},{"d":"2011-10-12","di":"2011-10-12","dr":"2011-10-12","k":"Regulatory Action","rg":"Other","reg":"ICE U.S. OTC Commodity Markets, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":20000.0,"dk":"MATTER NO.","al":"ICE U.S. OTC Commodity Markets, LLC alleged dbag violated ICE OTC rule 1.13 (enforcement of position limits and position accountability levels)by holding both intra-day and inter-day positions in excess of the firm's exempted position limit for July 2011 ICE henry hub LD1 contract between June 23, 2011 and June 24, 2011.","res":"Settled","sm":"Without admitting or denying the allegations, dbag agreed to the settlement and fine of $20,000.","ab":"Deutsche Bank AG","firms":[300838],"id":2328},{"d":"2011-10-04","di":"2011-10-04","dr":"2011-10-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":1000000.0,"dk":"2008013990502","al":"The firm failed to have a supervisory system, to ensure that all employee/employee-interested accounts were monitored and reviewed for misconduct. The employee activity review system (EARS) was the firm's primary means of monitoring employee account activities. EARS automatically captured accounts opened by employees who were using their social security numbers as the primary tax identification number. However, if the employee's social security number or tax identification number was not the primary number, EARS failed to automatically capture the account in its database. In these instances the firm relied solely on its employees to input their accounts into EARS. A significant number of employees either did not report such accounts or did not do so in a timely manner and as a result, a significant number of employee/employee-interested accounts failed to be monitored in EARS. The firm also failed to establish, maintain and enforce written procedures to adequately supervise a registered representative (RR). From April 2007 to June 2008, the RR used a business account he opened at the firm to implement a fraudulent scheme. The RR completed the new account documentation and submitted the company partnership agreement to the firm, as required by firm policy. However, the firm's procedures failed to require a supervisory review of the company partnership agreement prior to approval of the account. The firm approved the opening of the business account, designating the account as an employee account but the account was not automatically included in EARS and the RR did not disclose it on EARS, despite being told to do so. The firm failed to require its supervisors to review EARS after approving the opening of an account to ensure that the employee reported the account on the system. The firm also failed to have written procedures that required a supervisor to verify the approval of outside business activity before authorizing the opening of an account by an employee for business. Had the firm established such a procedure, it would have discovered that the RR never obtained firm approval for his outside business activities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings, therefore the firm is censured and fined $1,000,000.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2329},{"d":"2011-09-27","di":"2011-09-27","dr":"2011-09-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"Please archive / withdraw this amendment no sanctions were proposed.","st":"Final","fine":3234065.06,"dk":"20090184210","al":"By letter dated May 8, 2012, FINRA informed counsel for the firm that it would not be recommending commencement of disciplinary action against the firm in regards to this matter based on the information currently in their possession.","res":"Withdrawn","sm":"BY LETTER DATED MAY 8, 2012, FINRA INFORMED COUNSEL FOR THE FIRM THAT IT WOULD NOT BE RECOMMENDING COMMENCEMENT OF DISCIPLINARY ACTION AGAINST THE FIRM IN REGARDS TO THIS MATTER BASED ON THE INFORMATION CURRENTLY IN THEIR POSSESSION. THE FIRM HAD RECEIVED A WELLS NOTICE, DATED 08/08/2011, INDICATING THAT FINRA HAD MADE A PRELIMINARY DETERMINATION TO BRING DISCIPLINARY ACTION AGAINST THE FIRM FOR FAILING TO SUPERVISE ONE OF ITS FINANCIAL ADVISORS AND FOR 7 LATE FORM U5 FILINGS REGARDING MATTERS THAT BECAME REPORTABLE BETWEEN JUNE 2009 AND DECEMBER 2009. G S UC O S This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2330},{"d":"2011-09-20","di":"2011-09-20","dr":"2011-09-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":7500.0,"dk":"2009018535701","al":"Alleged violations of FINRA rule 7450. FINRA alleged that during Q1 2009, Instinet, LLC: 1)failed to repair rejected reportable order events (\"ROES\") that were repairable within the required five business days; and 2) failed to transmit ROES to the order audit trail system(\"OATS\")that were rejected by OATS for context or syntax errors.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the imposition of sanctions and paid a $7,500 fine on September 27, 2011.","ab":"Instinet, LLC","self":true,"firms":[7897],"id":2331},{"d":"2011-09-20","di":"2011-09-20","dr":"2011-09-20","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Wachovia securities, LLC is ordered to pay $150,000.00 to the commonwealth of Pennsylvania within 30 days of the date of this","st":"Final","fine":150000.0,"dk":"2010-03-23","al":"The commonwealth of Pennsylvania alleged that the firm failed to supervise an agent located in morgantown, WV from June 2007 to October 2008. Without admitting any liability or wrongdoing, the firm settled this matter on September 20, 2011 with the client for the amount of $158,557.85. FINRA matter # was 20100226488.","res":"Settled","sm":"The commonwealth of Pennsylvania alleged that the firm failed to supervise an agent located in morgantown, WV during the time period of June 2007 to October 2008. Without admitting any liability or wrongdoing, the firm settled this matter with the client on September 20, 2011 for the amount of $158,557.85. FINRA matter # 20100226488.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2332},{"d":"2011-09-16","di":"2011-09-16","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"Class action claiming losses related to the liquidation of part of the assets intended to produce returns on two funds in the midst of the 2008 financial crisis (etpp and etga). In this motion, the applicant seeks damages and punitive damages against: 1- Desjardins trust as contracting party and depositary (the court authorized the discontinuance for trust on May 4, 2015); 2- Desjardins financial services firm inc. (\"DCSF\") due to representations and omissions in the context of the offering of investments; 3- dgam due to investment management.","ab":"Desjardins Global Asset","firms":[135405],"id":2333},{"d":"2011-09-12","dr":"2011-09-12","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; reprimand; undertaking","st":"Final","fine":251760.0,"dk":"N/A","al":"The Nebraska Department of Banking & Finance (department) alleged that in connection with the sale of securities in Nebraska by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in Nebraska, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a failure to establish a reasonably designed supervisory system, and to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures, in violation of neb. Rev. Stat. §8­1103(9)(a)(XI) and sold securities in Nebraska through unregistered CAS in violation of neb. Rev. Stat. §8­1103(1).","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the department describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2334},{"d":"2011-09-08","di":"2011-04-11","dr":"2011-09-08","k":"Regulatory Action","rg":"Other","reg":"Central Bank of Ireland","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Reprimand","st":"Final","fine":219360.0,"dk":"ASP/GSBE/BSD","al":"On April 11, 2011, the Central Bank of Ireland (the \"central bank\") provided Goldman Sachs Bank (EUROPE) P.L.C. (\"GSBE\") a notice of commencement of examination (the \"notice\"), pursuant to part iiic of the irish central bank act of 1942 (the \"act\"), in connection with central bank concerns that GSBE may have committed certain prescribed contraventions for the purpose of section 33ao(1) of the act. The prescribed contraventions cited by the central bank are that from in or around December 2008 to October 2010, GSBE failed: (I) to have or to implement, any, or any effective, processes to identify, manage, monitor or report the counterparty risks it was or might have been exposed to, in alleged contravention of regulation 16(3)(b) of the european communities (licensing and supervision of credit institutions) regulations 1992 (the \"regulations\"), and (II) to have or maintain any or adequate internal control mechanism to identify that the capital adequacy tracking system-counterparty risk requirement application was incorrectly calculating the regulatory capital requirements, in alleged contravention of regulation 16(3)(c) of the regulations.","res":"Settled","sm":"On September 8, 2011, gsbe entered into a settlement agreement (the \"settlement agreement\") with the central bank in relation to breaches of the regulations, relating to gsbe's failure, during the period from July 16, 2008 to December 17, 2010, to comply with: (I) regulation 16(3)(b) of the regulations, in that gsbe's processes failed to manage, monitor and report accurately its regulatory counterparty risk capital requirement, and (II) regulation 16(3)(c) of the regulations, in that gsbe's internal control mechanism failed to identify that its regulatory counterparty risk capital requirement was incorrectly calculated. Gsbe agreed to a reprimand and to the payment of a monetary penalty to the central bank in the amount of 160,000.00 euros, which amount was paid by submission of a wire on September 14, 2011. The settlement agreement specifically states that the error at issue did not result in any breach of the capital adequacy ratios and no counterparties were impacted and that, in deciding the appropriate penalty to impose, the central bank took into account: (I) the regulatory capital maintained by gsbe between July 16, 2008 to December 17, 2010 was at all times in excess of its capital requirements, (II) gsbe self reported the issue to the central bank and has taken appropriate remedial steps to rectify the breaches and (III) the cooperation of gsbe during the investigation and in settling at an early stage in the administrative sanctions procedure. The central bank confirms that the matter is closed.","ab":"Goldman Sachs Bank","firms":[361],"id":2335},{"d":"2011-08-31","di":"2011-08-31","dr":"2011-08-31","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; reprimand; undertaking","st":"Final","fine":417760.0,"dk":"81-7691","al":"The West Virginia Securities Commission (commission) alleged that in connection with the sale of securities in West Virginia by certain Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPFS) client associates (CAS) who were not registered in West Virginia, MLPFS failed to establish an adequate system to monitor the registration status of persons accepting client orders, which constituted a failure to reasonably supervise in violation of West Virginia code §32­2­204(a)(j), failed to require its CAS to be registered in the appropriate jurisdictions, which constituted a failure to enforce its established written procedures, and sold securities in West Virginia through unregistered CAS in violation of West Virginia code §32­2­201(a).","res":"Consent","sm":"Under the terms of the settlement, MLPFS agreed to certain undertakings, including establishing and maintaining a trade monitoring system and filing a report with the commission describing certain monitoring improvements.","ab":"Merrill Lynch, Pierce, Fenner & Smith Incorporated","self":true,"firms":[7691],"id":2336},{"d":"2011-08-30","di":"2011-06-28","dr":"2011-08-30","k":"Regulatory Action","rg":"Other","reg":"Bourse de MontrÉAl Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50837.61,"al":"In an originating notice to Goldman Sachs international (\"GSI\") dated June 28, 2011, and received by GSI on July 1, 2011, the Bourse de MontrÉAl Inc. (the \"Bourse\") alleged that, during the period from May 27, 2008 to November 2, 2010, GSI provided certain personnel access to the electronic trading system of the Bourse without having obtained the prior approval of the Bourse, in alleged contravention of section a) of article 6366 of the rules of the Bourse.","res":"Decision","sm":"By way of an offer of settlement approved on August 30, 2011 by the special committee - regulatory division of the Bourse, gsi agreed to pay a fine in the amount of cad$50,000, as well as an additional amount of cad$2,500 for costs, which amount was paid by submission of a wire on September 22, 2011. As indicated in a circular published by the Bourse on September 7, 2011: (I) gsi did not have any prior disciplinary record with the Bourse, and provided the Bourse with full cooperation throughout its inquiries and (II) gsi's actions did not result in any harm or financial loss to customers or to other approved participants, nor did it give rise to a financial gain to gsi or its employees.","ab":"Goldman Sachs","firms":[361],"id":2337},{"d":"2011-08-05","di":"2010-11-18","dr":"2011-08-05","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Securities Division","san":"Cease and Desist","os":"Fine","st":"Final","fine":1000.0,"dk":"I10-336-JH","al":"Broker dealer operated a branch office in Nevada without first registering it","res":"Order","sd":"Fines paid 8/5/2011","sm":"Firm was not aware that Nevada did not permit unregistered home offices which are permitted under FINRA and NYSE rules","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2338},{"d":"2011-07-20","di":"2011-07-20","dr":"2011-07-20","k":"Regulatory Action","rg":"Federal Reserve","reg":"The Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Civil and administrative penalt(IES) / fine(s) restitution","st":"Final","fine":85000000.0,"dk":"11-094-B-HC1; 11-094-B-HC2; 11-094-I-HC1; 11-094-I-HC2","al":"The Board of Governors alleged that Wells fargo financial, inc., a subsidiary of Wells fargo & company, engaged in activities constituting unsafe or unsound banking practices, and violations of the federal trade commission act and state law in connection with certain home mortgage lending activities.","res":"Settled","sm":"This matter was resolved by settlement and a mutually agreed order dated July 20, 2011 providing for: (I) payment of civil monetary penalty of $85 million; (II) the submission within 90 days of remedial plans for paying restitution to eligible borrowers; and (III) the submission within 90 days of acceptable plans for the prevention of similiar future conduct, overseeing compliance with federal and state law applicable to home mortgage lending activities, and modifying incentive compensation and performance management programs related to home mortgage lending activities.","ab":"Wells Fargo and Company","firms":[11025,19616],"id":2339},{"d":"2011-07-18","di":"2011-06-29","dr":"2011-07-18","k":"Regulatory Action","rg":"Other","reg":"Federal Financial Supervisory Authority of Germany","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":13274.6,"dk":"GZ: WA 17-WP 3120-2009/0236 2011/0363267","al":"The Federal Financial Supervisory Authority of Germany (bundesanstalt fÜr finanzdienstleistungsaufsicht ­ \"BAFIN\") alleged a negligent breach of supervisory duties in contravention of certain shareholder disclosure requirements of section 21 (1) of the securities trading act (wertpapierhandelsgesetzes - WPHG) against GS Equity Markets, L.P. (\"GSEM\").","res":"Decision","sm":"BAFIN imposed a monetary penalty on gsem of 9,453.50 euros in the aggregate, representing an administrative fine of 9,000 euros and procedural expenses of 453.50 euros, which amount was paid on July 18, 2011.","ab":"GS Equity Markets, L.P.","firms":[361],"id":2340},{"d":"2011-07-11","di":"2011-07-11","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, censure and an undertaking to retain a qualified, independent consultant to review the firm's relevant","st":"Final","fine":850000.0,"dk":"3-14459","al":"It is alleged that Janney failed to adequately establish, maintain and enforce policies and procedures reasonably designed, taking into consideration of its business, to prevent the misuse of material, nonpublic information pursuant to section 15(g) of the Exchange Act and in certain instances, failed to properly implement or enforce such policies and procedures.","res":"Order","sd":"Civil monetary penalty of $850,000 paid in full by Janney Montgomery Scott LLC on July 12, 2011.","sm":"Janney submitted an offer of settlement, without admitting or denying the allegations, and consented to the finding that from 2005 through 2009, the firm failed to adequately establish, maintain and enforce policites and procedures reasonable designed, taking into consideration the nature of its business, to prevent the misuse of material, nonpublic information pursuant to section 15(g) of the Exchange Act and in certain instances, such policies and procedures were not properly implemented or enforced. Throughout the course of this matter, Janney committed signifigant resources to improving its section 15(g) policies and procedures and will continue to evaluate these procedures while working with an independent consultant.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2341},{"d":"2011-06-21","di":"2011-06-21","dr":"2011-06-21","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Cease and Desist","os":"Administrative fine","st":"Final","fine":65000.0,"dk":"0154-SR-5/11","al":"The office found that beginning in October 2004, Wells fargo advisors LLC, acting through 13 individuals, engaged in investment advisory business from offices within this state without the 13 individuals being lawfully registered in the state of Florida as investment advisor representatives for the firm in violation of section 517.12(4), f. S.","res":"Stipulation and Consent","sm":"On 6/21/2011 the office of financial regulation entered a final order adopting the stipulation and consent agreement in the matter of Wells fargo advisors, LLC. Wells fargo advisors LLC neither admitted nor denied the findings but consented to the entry of findings by the office. The office found that beginning in October 2004, Wells fargo advisors LLC, acting through 13 individuals, engaged in investment advisory business from offices within this state without the 13 individuals being lawfully registered in the state of Florida in violation of section 517.12(4), f. S. Wells fargo advisors LLC agreed to cease and desist from all present and future violations of chapter 517, F.S. And the administrative rules thereunder; and to pay an administrative fine in the amount of $65,000.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2342},{"d":"2011-06-17","di":"2011-06-17","dr":"2011-06-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"2009020728001","al":"MSRB rules G-14(b)(II), G-15(a)(I) - Wells fargo advisors, LLC failed to report the correct yield to the real-time transaction reporting system (RTRS) in reports of transactions in municipal securities. The firm failed to provide written notification disclosing to its customer the correct lowest effected yield in most of these transactions in municipal securities.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2343},{"d":"2011-06-16","di":"2011-06-16","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"Class action in connection with the liquidation of ips (strategic indices) and ipt (tactical indices) products in the midst of the 2008 financial crisis. In this motion, the applicant seeks damages and punitive damages against: 1- Desjardins financial security life assurance companie (\"DSF\") due to representations and omissions in the context of the offering of investments; 2- dgam due to investment management.","ab":"Desjardins Global Asset","firms":[135405],"id":2344},{"d":"2011-06-14","di":"2011-06-14","dr":"2011-06-14","k":"Regulatory Action","rg":"State regulator","reg":"New Hampshire Department of State, Bureau of Securities Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":92584.57,"al":"Various state regulators, including the New Hampshire Department of State, Bureau of Securities Regulation, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the New Hampshire Department of State, Bureau of Securities Regulation alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the New Hampshire Department of State, Bureau of Securities Regulation on June 14, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $92,584.57 to the New Hampshire Department of State, Bureau of Securities Regulation, which amount was paid on June 20, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2345},{"d":"2011-06-10","di":"2011-06-10","dr":"2011-06-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":27500.0,"dk":"20080163749-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) from July 1 to September 30, 2007, Goldman, Sachs & co. (the \"firm\") failed to report to the trade reporting and compliance engine (TRACE) the correct contra-party's identifier for 220 transactions in TRACE-eligible securities, in alleged violation of NASD rule 6230(c)(6), and (II) from January 1 to March 31, 2009, failed to report to TRACE 1,077 transactions in TRACE-eligible securities within 15 minutes of the time of execution, in alleged violation of FINRA rule 6730(a) and allegedly constituting a pattern or practice of late reporting without exceptional circumstances in violation of FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on June 10, 2011 and on June 28, 2011, the firm submitted a wire in payment of the fine in the amount of $27,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2346},{"d":"2011-06-10","di":"2011-06-10","dr":"2011-06-10","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":47378.87,"dk":"70-361","al":"Various state regulators, including the West Virginia Securities Commission, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the West Virginia Securities Commission alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the West Virginia Securities Commission on June 10, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $47,378.87 to the West Virginia Securities Commission, which amount was paid on June 20, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2347},{"d":"2011-06-09","di":"2011-06-08","dr":"2011-06-09","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; undertaking.","st":"Final","fine":10000000.0,"dk":"E-2009-0079","al":"The Commonwealth of Massachusetts Securities Division (the \"division\") alleged that, from January 1, 2006 through June 9, 2011, Goldman, Sachs & co. (the \"firm\") failed: (I) to establish adequate procedures and supervisory processes designed to identify and manage potential conflicts of interest related to its research services; (II) to have adequate procedures in place reasonably designed to prevent or detect the dissemination by global investment research (\"GIR\") equity analysts of certain unpublished short term trading ideas which favored the interests of certain priority clients; (III) to reasonably supervise its GIR equity analysts' communications to prevent and detect dissemination by GIR equity analysts of certain unpublished short term trading ideas which favored the interests of certain priority clients; (IV) to prevent the use and dissemination by GIR equity analysts of certain unpublished short term trading ideas which favored the interests of certain priority clients; and (v) to deal fairly and objectively with all clients in connection with the dissemination by GIR equity analysts of certain unpublished short term trading ideas, in alleged violation of section 204(a)(2)(g) and section 204(a)(2)(j) of the Massachusetts uniform Securities Act (the \"act\").","res":"Consent","sm":"Without admitting or denying the legal conclusions or violations, the firm entered into an offer of settlement with the Massachusetts securities division on June 8, 2011 (the \"offer\") and a consent order, dated June 9, 2011 (the \"order\"), pursuant to which the firm consented to a civil penalty in the amount of $10,000,000 which was paid to the Commonwealth of Massachusetts, on June 15, 2011. In connection with the order, the firm agreed to (I) permanently cease and desist from violations of the act in connection with related research activities; (II) permanently discontinue the asi; (III) permanently discontinue huddles; (IV) within 90 days of the signed order, review and enhance, as appropriate, its written supervisory policies and procedures with respect to certain practices within gir; and (v) require the director or the co-director of americas equity research to certify to the division in writing, within 180 days after the date of entry of the order, that the firm has fully adopted and complied with the various undertakings set forth in the consent order.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2348},{"d":"2011-06-09","di":"2011-06-02","dr":"2011-06-09","k":"Regulatory Action","rg":"Other","reg":"ICE Futures Europe","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":40465.0,"dk":"011191","al":"On January 28, 2011, monitoring by ICE Futures Europe (the \"exchange\") detected six notable \"price spikes\" in the APRIL11 brent/wti spread that were investigated by the exchange and found to be the result of a limit order and several large market orders placed in quick succession by a Goldman Sachs trader at the request of his client, in alleged breach of exchange rule G.20.","res":"Consent","sm":"As indicated in a circular published by the exchange on June 17, 2011 (the \"circular\"), on June 2, 2011 the exchange's authorisation, rules and conduct committee (the \"committee\") summarily concluded: (I) the behavior of gsi and its client to be a clear case of disorderly trading, in that the distorting price impact of the placement of such large orders in close proximity was not considered, and (II) both gsi and its client to be at fault in the matter, emphasizing that all exchange members have a responsibility to trade in an orderly fashion at all times, whether on their own behalf or on behalf of a client. Gsi did not seek to appeal the committee's findings and paid the fine on June 17, 2011. The circular also specifically states that while the committee considered the breach to be of a serious nature, the committee found no evidence of intentional manipulation of the market. Gsi provided the exchange with full cooperation throughout its inquiries.","ab":"Goldman Sachs","firms":[361],"id":2349},{"d":"2011-05-10","di":"2011-05-10","dr":"2011-05-10","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":722977.33,"dk":"2010-0205","al":"Various state regulators, including the Maryland Securities Commissioner, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Maryland Securities Commissioner alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Maryland Securities Commissioner on May 10, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $722,977.33 to the Maryland Securities Commissioner, which amount was paid on May 13, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2350},{"d":"2011-05-10","di":"2011-05-10","dr":"2011-05-10","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1368553.05,"dk":"E-2011-0016","al":"Various state regulators, including the Massachusetts Securities Division, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Massachusetts Securities Division alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Massachusetts Securities Division on May 10, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,368,553.05 to the Massachusetts Securities Division, which amount was paid on May 13, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2351},{"d":"2011-05-10","di":"2011-05-10","dr":"2011-05-10","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":75000.0,"dk":"2009018503501","al":"It is alleged that Janney did not comply with MSRB rules G-8, G-17, G-27, G-32, related to the delivery of official statements.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented to the described sanctions and the entry of findings; therefore, the firm is censured and fined $75,000.","sm":"Without admitting or denying the findings, the firm was censured and fined $75,000 related to violations of MSRB rules G-32, G-8, G-27 and G-17, stemming from its untimely delivery of official statements to customers who purchased municipal securities during the primary offering disclosure period, in transactions in which Janney was neither an underwriter nor part of the underwriting syndicate. In response, Janney enhanced its policies and procedures relating to timely delivery of official statements and provided staff training on rule requirements and the enhanced procedures. Janney also notified clients who may not have received an official statement by settlement date and provided instructions as to how one might be obtained. Janney is confident that these measures demonstrate its ongoing commitment to compliance in all areas of its business, including its obligations as to municipal securities disclosure obligations.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2352},{"d":"2011-05-06","di":"2011-05-06","dr":"2011-05-06","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":959794.35,"dk":"2010-025","al":"Various state regulators, including the New Jersey Bureau of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the New Jersey Bureau of Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the New Jersey Bureau of Securities on May 6, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $959,794.35 to the New Jersey Bureau of Securities, which amount was paid on May 11, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2353},{"d":"2011-05-04","di":"2011-05-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertakings","st":"Final","fine":1000000.0,"dk":"2010022921801","al":"FINRA alleged that wfa failed to deliver prospectuses to its customers within three business days of their purchases in 934,047 mutual fund transactions between January 1, 2009 and December 31, 2009 (the \"relevant period\"). FINRA alleged that wfa failed to timely file certain amendments to uniform applications for securities industry or transfer (\"forms U4\") and uniform termination notices for securities industry registration (\"forms U5\") from July 1, 2008 to June 30, 2009.","res":"Acceptance, Waiver & Consent(AWC)","sm":"AWC accepted on May 4, 2011","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2354},{"d":"2011-05-02","di":"2011-05-02","dr":"2011-05-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":23000.0,"dk":"2006005324201","al":"NASD rules 2110, 2320: in eight transactions for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm sent the $23,000.00 fine to FINRA on 05/13/2011.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2355},{"d":"2011-05-02","di":"2011-05-02","dr":"2011-05-02","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire Department of State Bureau of Securities Regulations","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":289021.88,"dk":"ADMINISTRATIVE CONSENT ORDER: INV- 2009000015","al":"The state of New Hampshire-department of state-bureau of securities regulations has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2356},{"d":"2011-05-02","di":"2011-05-02","dr":"2011-05-02","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist, requalification","st":"Final","fine":3500.0,"dk":"14166/TF","al":"The Minnesota Department of Commerce alleged that the registered representative claimed credit for ce credit hours that were not actually completed in order to continue insurance producer licensure with the department of commerce in violation of Minnesota stat. Sections 45.027, subd. 7(a)(1) & (2) and 60K.56, SUBD.8A (2008).","res":"Consent","sd":"Registered representative was given 90 days to requalify and completed the required ce credits prior to the execution of the consent order.","ab":"Opp, Mark, Adam","firms":[155216],"id":2357},{"d":"2011-04-28","di":"2011-04-28","dr":"2011-04-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":58000.0,"dk":"2007008011601","al":"NASD rules 2110, 2440, interpretative MATERIAL-2440, MSRB rules G-17, G-30(a): in nine transactions, the firm sold (or bought) corporate bonds to (or from)customers and failed to sell (or buy) such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each bond at the time of the transaction, the expense involved and that the firm was entitled to a profit. In ten transactions, the firm sold municipal securities for its own account to a customer at an aggregate price (including any mark-up) that was not fair and reasonable, taking into consideration all relevant factors, including the best judgment of the broker, dealer or municipal securities dealer as to the fair market value of the securities at the time of the transactions and of any securities exchanged or traded in connection with the transaction, the expense involved in effecting the transaction, the fact that the broker, dealer, or municipal securities dealer is entitled to a profit, and the total dollar amount of the transaction.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm sent the $58,000.00 fine to FINRA on 05/11/2011.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2358},{"d":"2011-04-19","di":"2011-04-19","dr":"2011-04-19","k":"Regulatory Action","rg":"Other","reg":"Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":10000.0,"dk":"0356-S-07/10","al":"It was alleged that Janney did not comply with certain items in the registration agreements of several registered representatives.","res":"Order","sd":"Administrative fine of $10,000.00 paid in full by Janney Montgomery Scott LLC on 04/19/2011.","sm":"Without admitting or denying the allegations raised by the state of Florida, office of financial regulation, Janney Montgomery Scott LLC entered into a stipulation and consent agreement with the office, which was adopted by the office through a final order dated April 19, 2011. Janney consented to the finding that it did not comply with certain terms of the registration agreements belonging to several of its registered representatives, agreed to cease and desist from any other violations of Florida's administrative rules and paid an administrative fine of $10,000. The office of financial regulation agreed to release three registered representatives from their registration agreements.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2359},{"d":"2011-04-18","di":"2010-08-31","dr":"2011-04-18","k":"Regulatory Action","rg":"Other","reg":"Colorado Division of Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":14300.0,"dk":"228311","al":"Failing to report regulatory actions to the Colorado Division of Insurance during the period 2004-2010 in violation of 10-2- 801(1)(a) and 10-2-801(3), C.R.S.","res":"Stipulation and Consent","sd":"$14,300 fine paid via a check issued May 4, 2011.","sm":"The firm without admitting or denying the allegations stipulated to the order issued April 18, 2011 imposing a fine of $14,300.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2360},{"d":"2011-04-13","di":"2011-04-13","dr":"2011-04-13","k":"Regulatory Action","rg":"Federal Reserve","reg":"Board of Governors of the Federal Reserve System","san":"Cease and Desist","os":"Remediation actions","st":"Final","dk":"11-029-B-HC","al":"On April 13, 2011, the Board of Governors of the Federal Reserve System (\"Federal Reserve\") issued a cease and desist consent order (\"consent order\") against Bank of America corporation (\"BAC\"). The consent order makes no finding on any issues of fact or law or any explicit allegation concerning BAC. The consent order describes a consent order that the office of the Comptroller of the Currency (\"OCC\") and Bank of America, N.A. (the \"bank\"), which is owned and controlled by BAC, entered into addressing areas of weakness identified by the OCC in loan servicing, loss mitigation, foreclosure activities, and related functions by the bank. The consent order also states that the OCC's findings raised concerns that BAC did not adequately assess the potential risks associated with such activities of the bank. The consent order directs the Board of directors of BAC to take appropriate steps to ensure that the bank complies with the OCC consent order.","res":"Order","sm":"Bac submitted an offer of settlement to the Federal Reserve. In the offer of settlement, bac agreed to consent to the entry of the consent order, without the consent order constituting an admission by bac or any of its subsidiaries of any allegation made or implied by the Federal Reserve in connection with the matter. The consent order was issued on April 13, 2011, the highlights of which are described above in item 7. The sanctions imposed are explained above in item 12.c.","ab":"Bank of America","firms":[142558],"id":2361},{"d":"2011-04-13","di":"2011-04-13","dr":"2011-04-13","k":"Regulatory Action","rg":"OCC","reg":"The Comptroller of the Currency of the United States of America","san":"Cease and Desist","os":"Remediation actions","st":"Final","dk":"AA-EC-11-12","al":"On April 13, 2011, The Comptroller of the Currency of the United States of America (\"OCC\") issued a cease and desist consent order (\"order\") against Bank of America, National association (\"BANA\"). The order identified certain deficiencies and unsafe or unsound practices in residential mortgage servicing and in BANA's initiation and handling of foreclosure proceedings. The order finds that in connection with certain foreclosures of loans in it is residential servicing portfolio, BANA; (a) filed or caused to be filed in courts executed affidavits making various assertions that were not based on the affiants' personal knowledge or review of relevant books and records; (b) filed or caused to be filed in courts numerous affidavits or other mortgage-related documents that were not properly notarized; (c) litigated foreclosure proceedings and initiated non-judicial foreclosure proceedings without always ensuring that the promissory note or the mortgage document were properly endorsed or assigned and, if necessary, in the possession of the appropriate party at the appropriate time; (d) failed to devote sufficient resources to ensure proper administration of its foreclosure processes; (e) failed to devote to its foreclosure processes adequate oversight, internal controls, policies and procedures, compliance risk management, internal audit, third party management and training; and (f) failed to sufficiently oversee third-party providers handing foreclosure-related services.","res":"Order","sm":"Bana submitted an offer of settlement to the OCC. In the offer of settlement, bana agreed to consent to the entry of the order, without admitting or denying any wrongdoing. The order was issued on April 13, 2011, and made the findings of violations described above in item 7. The sanctions imposed are explained above in item 12.c. On February 27, 2012, bana entered into an agreement with the OCC, without admitting or denying any wrongdoing, to forgo the assessment of civil money penalties and to release from certain claims in the order so long as bana: (a) provides borrowers assistance and certain payments pursuant to a settlement agreement with the United States of america, acting through the United States Department of Justice and with the attorneys general of various states, to settle certain potential state and federal claims relating to bana's residential mortgage origination, servicing and foreclosure practices; (b) provides detailed reports and accounting for the payments described above; and (c) shall make available certain documents associated with the payments above upon the request of the OCC. On June 17, 2015, the OCC terminated this order against bana because the OCC determined that the protection of the depositors, other customers, and shareholders of bana, as well as its safe and sound operation, does not require the continued existence of the order issued in April, 2011 and bana has satisfied all of the requirements of an amendment to the order issued in February, 2013.","ab":"Bank of America, National","firms":[142558],"id":2362},{"d":"2011-04-05","di":"2011-04-05","dr":"2011-04-05","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"20100237082-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that on July 29, 2010, Goldman, Sachs & co. (the \"firm\") effected, directly or indirectly, one transaction in a security while a trading pause was in effect, in alleged violation of FINRA rule 5260.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a fine and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on April 5, 2011 and on April 20, 2011, the firm submitted a wire in payment of the fine in the amount of $5,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2363},{"d":"2011-04-04","di":"2011-04-04","dr":"2011-04-04","k":"Regulatory Action","rg":"Federal Reserve","reg":"Federal Reserve","san":"Cease and Desist","st":"Final","dk":"11-025-B-HC","al":"Federal Reserve consent order re: bank's mortgage foreclosure practices","res":"Consent","sm":"Wells fargo & company (Wells fargo) entered into a consent order with the Federal Reserve pursuant to which Wells fargo agreed, among other things, (I) to ensure the bank's compliance with the OCC consent order; (II) to develop for the Federal Reserve's approval a written plan to enhance its enterprise risk management with respect to oversight of residential mortgage loan servicing; (III) to develop for the Federal Reserve's approval a written plan to enhance its enterprise-wide compliance program with respect to oversight of residential mortgage loan servicing; and (IV) to develop for the Federal Reserve's approval a written plan to enhance the internal audit program with respect to residential mortgage loan servicing.","ab":"Wells Fargo and Compaany","firms":[11025,19616],"id":2364},{"d":"2011-03-31","di":"2011-03-31","k":"Regulatory Action","rg":"OCC","reg":"Office of the Comptrollerof the Currency (\"OCC\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":70000000.0,"dk":"2016-56 AMENDS 2011-051, 2013-132, 2015-067, AND AA-EC-11-19 TO TERMINATE. 2016-055 (AA-EC-2016-30) ORDER FOR CIVIL PENALTY","al":"Wells fargo bank, N.A. failed to comply with certain provisions of prior OCC consent orders relating to certain residential mortgage servicing practices from prior consent orders. # 2016-055 (AA-EC-2016-30) orders Wells fargo bank, N.A. pay a $ 70,000,000. Civil money penalty.","res":"Stipulation and Consent","ab":"Wells Fargo Bank, N. A.","firms":[19616],"id":2365},{"d":"2011-03-23","di":"2011-03-23","dr":"2011-03-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Ohio Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":814454.59,"dk":"ADMINISTRATIVE CONSENT ORDER - DIVISION ORDER NO. 11-015","al":"The state of Ohio has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2366},{"d":"2011-03-22","di":"2010-02-05","dr":"2011-03-22","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Final","fine":541000.0,"al":"The civil division of the federal court of justice of Germany found that Deutsche Bank AG (\"DBAG\") violated certain advisory duties in providing advice on entering into an interest rate swap agreement (CMS spread ladder swap contract) structured by the bank but not disclosing a conflict of interest.","res":"Judgment Rendered","sd":"The amount of $541,000 is in euros plus interest (after deducting interest payments received).","ab":"Deutsche Bank AG","firms":[300838],"id":2367},{"d":"2011-03-01","di":"2010-12-22","dr":"2011-03-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana Office of the Secretary of State, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"10-0504 CA","al":"G g y (y p p p ) in July 2009, the Indiana secretary of state, securities division (the \"state\") alleged that Edward jones failed to supervise the activities of a now deceased financial advisor. Specifically, the state alleged the financial advisor was able to change the primary account holder and social security number on an account by submitting a form to the headquarters office without the required number of signatures, in violation of firm policy.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2368},{"d":"2011-03-01","di":"2011-03-01","dr":"2011-03-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Mississippi, Office of the Secretary of State, Securitties and Charities Division (Division)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"MOU 03/01/2011","al":"The division alleged that a wfa employee had acted as an investmennt advisor representative in misssissippi, without being properly registered as such in violation of section 75-71-303 (b)(2) misssissippi Securities Act 2000 & section 75-71-403 (2)(d) misssissippi Securities Act 2009.","res":"Other","sm":"The division alleged that a wfa employee acted as an investmennt advisor representative in misssissippi, without being properly registered as such, violating section 75-71-303 (b)(2) misssissippi Securities Act 2000 & section 75-71-403 (2)(d) misssissippi Securities Act 2009. Wfa paid the $25000 fine to the division on 02/25/2011.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2369},{"d":"2011-01-21","di":"2011-01-21","dr":"2011-01-21","k":"Regulatory Action","rg":"State regulator","reg":"Virginia State Corporation Commission, Division of Securities & Retail Franchising","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":333137.12,"dk":"SEC-2010-00056","al":"Various state regulators, including the Virginia State Corporation Commission, Division of Securities & Retail Franchising, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Virginia State Corporation Commission, Division of Securities & Retail Franchising alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Virginia State Corporation Commission, Division of Securities & Retail Franchising on January 21, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $333,137.12 to the Virginia State Corporation Commission, Division of Securities & Retail Franchising, which amount was paid on January 31, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2370},{"d":"2011-01-21","di":"2011-01-21","dr":"2011-01-21","k":"Regulatory Action","rg":"Department of Justice","reg":"State of Delawre Department of Justice Division of Securities","san":"Undertaking","st":"Final","fine":1746.0,"dk":"CASE NO. 09-03-03","al":"State of Delawre Department of Justice Division of Securities alleged that wachovia securities, LLC violated 6 del.c. § 7316 (a)(7) of the Delaware securiyties act by executing a transaction on behalf of a customer without prior authorization","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2371},{"d":"2011-01-18","di":"2011-01-18","dr":"2011-01-18","k":"Regulatory Action","rg":"State regulator","reg":"Wisconsin Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":95100.4,"dk":"S-215589 (EX)","al":"Various state regulators, including the Wisconsin Division of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Wisconsin Division of Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Wisconsin Division of Securities on January 18, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $95,100.40 to the Wisconsin Division of Securities, which amount was paid on January 26, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2372},{"d":"2011-01-18","di":"2011-01-18","dr":"2011-01-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Alaska, Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":46009.22,"dk":"10-14-S","al":"Various state regulators, including the State of Alaska, Division of Banking and Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the State of Alaska, Division of Banking and Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the State of Alaska, Division of Banking and Securities on January 18, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $46,009.22 to the State of Alaska, Division of Banking and Securities, which amount was paid on January 26, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2373},{"d":"2011-01-14","di":"2011-01-14","dr":"2011-01-14","k":"Regulatory Action","rg":"Other","reg":"Michigan Office of Financial and Insurance Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":91099.58,"al":"Various state regulators, including the Michigan Office of Financial and Insurance Regulation, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Michigan Office of Financial and Insurance Regulation alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Michigan Office of Financial and Insurance Regulation on January 14, 2011 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $91,099.58 to the Michigan Office of Financial and Insurance Regulation, which amount was paid on January 26, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2374},{"d":"2011-01-12","di":"2011-01-12","dr":"2011-01-12","k":"Regulatory Action","rg":"State regulator","reg":"Colorado Department of Regulatory Agencies, Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":508021.39,"dk":"11-6-13","al":"Various state regulators, including the Colorado Department of Regulatory Agencies, Division of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Colorado Department of Regulatory Agencies, Division of Securities alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Colorado Department of Regulatory Agencies, Division of Securities on January 12, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $508,021.39 to the Colorado Department of Regulatory Agencies, Division of Securities, which amount was paid on January 26, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2375},{"d":"2011-01-11","di":"2011-01-11","dr":"2011-01-11","k":"Regulatory Action","rg":"State regulator","reg":"Nebraska Department of Banking & Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":51307.6,"al":"Various state regulators, including the Nebraska Department of Banking & Finance, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Nebraska Department of Banking & Finance alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Nebraska Department of Banking & Finance on January 11, 2011, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $51,307.60 to the Nebraska Department of Banking & Finance, which amount was paid on January 21, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2376},{"d":"2010-12-29","di":"2010-12-06","dr":"2010-12-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Insurance Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"FC 10-179","al":"The Connecticut insurance dept. Alleged that Wedbush failed to notify the insurance dept. Of administrativre actions against the firm that had been reported on CRD.","res":"Consent","sd":"The firm paid a fine of $1,500.00 on dec. 28, 2010.","sm":"Wedbush neither admitted or denied the allegations but agreed to pay the $1,500 fine on dec 28, 2010.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2377},{"d":"2010-12-29","di":"2010-12-29","dr":"2010-12-29","k":"Regulatory Action","rg":"Other","reg":"Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":75000.0,"dk":"CO-10-7710-S","al":"On December 29, 2010, the Connecticut banking commissioner entered a consent order with respect to wachovia securities, LLC, now known as Wells fargo advisors, LLC, a Connecticut-registered broker-dealer. The consent order alleged that the firm failed to establish, enforce and maintain an adequate supervisory system in overseeing the activities of an ex-broker-dealer agent of the firm. According to the consent order, the agent issued, and recommended to a certain wachovia securities, LLC client, unregistered promissory notes that were not suitable for the client based on the client's financial situation and needs. The consent order added that the agent acted outside the regular course or scope of his employment with the firm in selling the notes and in receiving compensation for referring brokerage and bank clients to an associate for the purpose of investing in other interest-paying promissory notes. The agent allegedly did not provide the firm with prior written notice of such activities, nor were the transactions recorded on the firm's books and records","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2378},{"d":"2010-12-28","di":"2010-12-28","dr":"2010-12-28","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":78556.45,"dk":"S-09-024-10-OR14","al":"Various state regulators, including the Arkansas Securities Commissioner, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Arkansas Securities Commissioner alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Arkansas Securities Commissioner on December 28, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $78,556.45 to the Arkansas Securities Commissioner, which amount was paid on January 6, 2011.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2379},{"d":"2010-12-22","di":"2010-12-22","dr":"2010-12-22","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":175000.0,"dk":"2009017682701","al":"FINRA rule 2010, NASD rules 2110, 3010: on December 4, 2006, the firm entered into an AWC relating to its failure to reasonably supervise its variable annuity exchange business. The firm had inadequate automated systems and written procedures for variable annuity exchanges reported on the electronic branch trade report system (\"EBTR\"). At the time the firm entered into the AWC, the firm was in the process of upgrading its centralized online order-entry system to switch from the EBTR to the annuity order entry system (AOE) system in order to enhance the firm's overall review of variable annuity exchange transactions. Accordingly, as part of the AWC, FINRA required that the firm retain an independent consultant to review and make recommendations regarding the AOE system and the firm's procedures to reasonably ensure that the firm was in compliance with federal securities laws and NASD rules relating to the exchange of variable annuities. In May 2008, the firm attested to FINRA that it had implemented the rollout of the new AOE system. When the rollout was completed, the firm amended its written supervisory procedures to make the use of the AOE system mandatory, with minor exceptions, for all registered representatives who engaged in variable annuity exchange transactions as of October 15, 2008. Despite the rollout of the AOE system and the firm's attestation to FINRA, the firm failed to enforce the mandatory usage of the AOE system until October 2009. As a result, during the period of October 2008 until October 2009, the firm's registered representatives entered orders for approximately 15% of the firm's variable annuity exchange transactions using the EBTR system instead of the AOE system. Therefore, by failing to enforce the mandatory use of the AOE system from October 2008 until October 2009, the firm failed to enforce its written supervisory procedures relating to variable annuity exchange transactions","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, LPL consented to a censure and a fine of $175,000, which LPL paid.","ab":"LPL Financial LLC","self":true,"firms":[6413],"id":2380},{"d":"2010-12-20","di":"2010-12-20","dr":"2010-12-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","st":"Final","fine":12500.0,"dk":"20080155897-01","al":"MSRB rules G-14(b)(II), G-15(a)(I) - Wells fargo advisors, LLC failed to report the correct yield to the real-time transaction reporting system (RTRS) in reports of transactions in municipal securities and failed to provide written notification disclosing to its customers the correct lowest effected yield in these municipal securities transactions.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2381},{"d":"2010-12-17","di":"2010-12-17","dr":"2010-12-17","k":"Regulatory Action","rg":"State regulator","reg":"Connecticut Department of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1014903.35,"dk":"CO-10-7842-S","al":"Various state regulators, including the Connecticut Department of Banking, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Connecticut Department of Banking alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Connecticut Department of Banking on December 17, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,014,903.35 to the Connecticut Department of Banking, which amount was paid on December 23, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2382},{"d":"2010-12-08","di":"2010-12-08","dr":"2010-12-08","k":"Regulatory Action","rg":"Other","reg":"Internal Revenue Service (\"IRS\")","san":"Restitution","st":"Final","dk":"NONE","al":"Bank of America corporation (the \"bank\") violated certain bidding requirements set forth in the Treasury regulations related to certain investment contracts, and entered into certain investment and/or swap contracts (or provided bids to enter into such contracts) that did not reflect the fair market value of those contracts.","res":"Settled","sm":"On December 8, 2010, the bank entered into a closing agreement with the IRS that addressed the bank's violation of certain bidding requirements set forth in the Treasury regulations related to certain investment contracts, and the bank's entering into certain investment and/or swap contracts (or providing bids to enter into such contracts) that did not reflect the fair market value of those contracts. The bank agreed to pay the IRS $25,000,000 as restitution for arbitrage rebate payments and other amounts that would have been payable to the IRS as a result of the conduct and the bank received a release related to its participation in, bids for, or statements or omissions related to any contracts that the bank bid on from 1998 through 2006.","ab":"Bank of America","firms":[142558],"id":2383},{"d":"2010-12-07","di":"2010-12-07","dr":"2010-12-07","k":"Regulatory Action","rg":"OCC","reg":"The Office of the Comptroller of the Currency","san":"Restitution","os":"Undertaking","st":"Final","dk":"#2010-239","al":"The Comptroller of the Currency (the \"comptroller\") examined certain activities related to the participation of certain Bank of America, National association (the \"bank\") employees in the sale of certain derivative financial products to municipalities and non-profit organizations, and reviewed information indicating that certain bank employees engaged in illegal bidding activity related to the sale of those derivative financial products variously between 1998 and January 2004. Following the review, the bank and the comptroller entered into a formal written agreement to ensure that the bank proactively and appropriately manages its compliance risk related to various competitively bid transactions, including those related to derivative financial products to municipalities and non-profit organizations.","res":"Settled","sm":"The bank has entered into a written agreement on December 7, 2010, with the Comptroller of the Currency. Under the terms of the written agreement, the bank agreed to institute and/or continue certain policies and procedures, including compliance, training and audit programs, relating to competitively bid transactions for the sale of derivative financial products to municipalities and non-profit organizations that are intended to invest or re-invest the proceeds of bonds issued by these organizations or to manage or transfer the interest rates of bonds issued by the organizations. In addition, the bank agreed to do a formal assessment of all business lines that engage in certain types of competitively bid transactions, to complete a formal evaluation of the operational policies and procedures applicable to such businesses to ensure that adequate policies and procedures exist to ensure compliance with safe and sound banking practices, law, and regulations related to the competitively bid transactions, and to develop an internal training program to ensure compliance with all laws and regulations related to competitively bid transactions. Upon approval by the comptroller, the bank must immediately begin to implement the policies, procedures and programs called for by the agreement. Finally, the bank agreed to pay unjust enrichment in the amount of $9,217,218 to certain counterparties indentified by the comptroller.","ab":"Bank of America, National","firms":[142558],"id":2384},{"d":"2010-12-06","di":"2010-12-06","dr":"2010-12-06","k":"Regulatory Action","rg":"Other","reg":"Oregon Department of Business and Consumer Services","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":80863.23,"dk":"S-10-0009","al":"Various state regulators, including the Oregon Department of Business and Consumer Services, conducted an industry-wide, joint investigation into the marketing and sale of ars. In the order to cease and desist, order for assessing civil penalty, and consent to entry of order, the Oregon Department of Business and Consumer Services alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an order to cease and desist, order for assessing civil penalty, and consent to entry of order with the Oregon Department of Business and Consumer Services on December 6, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $80,863.23 to the Oregon Department of Business and Consumer Services, which amount was paid on December 10, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2385},{"d":"2010-12-06","di":"2010-12-06","dr":"2010-12-06","k":"Regulatory Action","rg":"Federal Reserve","reg":"Federal Reserve Bank of Richmond (The \"Reserve Bank\")","san":"Undertaking","st":"Final","dk":"10-240-WA/RB-HC","al":"The Board of Governors of the Federal Reserve system conducted a review concerning various types of anti-competitive activity by certain Bank of America corporation (the \"bank\") employees in conjunction with the sale of certain derivative financial products to municipalities and non-profit organizations variously between 1998 and 2003. Following the review, the bank and the reserve bank entered into a formal written agreement to ensure that the bank proactively and appropriately manages its compliance risk related to certain competitively bid transactions.","res":"Settled","sm":"The bank has entered into a written agreement on December 6, 2010, with the reserve bank. Under the terms of the written agreement, the bank has agreed to submit a written plan to strengthen board oversight of the bank's compliance risk management program as it relates to certain types of competitively bid transactions. In addition, the bank agreed to submit a written plan to strengthen the bank's compliance risk management program regarding those same competitively bid transactions, and to promptly implement that plan once it is approved by the reserve bank.","ab":"Bank of America","firms":[142558],"id":2386},{"d":"2010-12-02","di":"2010-12-02","dr":"2010-12-02","k":"Regulatory Action","rg":"Other","reg":"Iowa Insurance Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":53181.86,"dk":"67953","al":"Various state regulators, including the Iowa Insurance Division, conducted an industry-wide, joint investigation into the marketing and sale of ars. In the administrative consent order, the Iowa Insurance Division alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Iowa Insurance Division on December 2, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $53,181.86 to the Iowa Insurance Division, which amount was paid on December 10, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2387},{"d":"2010-11-29","di":"2010-09-08","dr":"2010-11-29","k":"Regulatory Action","rg":"NYSE","reg":"NYSE AMEX LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Bar censure undertaking","st":"Final","fine":50000.0,"dk":"FINRA PROCEEDING NO. 20100241452; 10-AMEX 13","al":"On September 8, 2010, NYSE AMEX LLC initiated a settled enforcement proceeding against brandon Yarckin and daniel tosto in connection with their employment at a broker-dealer in 2006. MR. Yarckin, without admitting or denying the allegations, consented to a settlement of the action. The action alleged violations of AMEX rule 16, section 17(a) of the Securities Exchange Act of 1934, rules 17A-3 and 17A-4, AMEX rule 324, 343 and 481(a) and (b) in connection with certain trades in institutional customer accounts on one afternoon in 2006. In addition, the action alleged that messrs. Yarckin and tosto disseminated research reports without review by a supervisor approved by AMEX. The events underlying the action occurred while MR. Yarckin was associated with the trading desk of a broker-dealer, amerivest partners, L.L.C. Pursuant to the settlement, and without admitting or denying the allegations, MR. Yarckin was found to have (1) violated AMEX rule 16 by failing to adhere to the principles of good business practice; (2) caused violations of section 17(a) of the Securities Exchange Act of 1934 and rules 17a- 3 and 17A-4 thereunder, and AMEX rule 324 by causing his member firm employer to fail to keep true and complete books of account and records adequately setting forth the transactions of such members and member organizations; and (3) violated AMEX rules 343 and 481(a) and (b) by distributing research reports to the public that were not prepared, reviewed or approved by a supervisory analyst acceptable to AMEX. MR. Yarckin consented to censure, a $50,000 fine, a one-month bar from association with any NYSE AMEX trading permit holder or broker/dealer, and an undertaking to cooperate with FINRA market regulation and testify truthfully in connection with any other disciplinary proceedings relating to matters set forth in the stipulation of facts and consent to penalty. The settlement was formally approved effective as of November 29, 2010.","res":"Stipulation and Consent","sd":"One month bar effective as of close of business December 3, 2010. $50,000 fine to be paid within 45 days of close of business November 29, 2010.","ab":"Yarckin, Brandon, Scott","firms":[146052],"id":2388},{"d":"2010-11-18","di":"2010-11-18","dr":"2010-11-18","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution to nancy moore in the amount of $495.84","st":"Final","fine":8000.0,"dk":"10-0271 CA","al":"The division alleged that o/a June 9,2009, Wells fargo advisors, LLC (WFA) engaged in dishonest and unethical practices by failing to promptly and reasonably follow instructions from a client to transfer the assets in her accounts to another financial institution in­kind, in violation of ind. Code § 23­19­4­12(d)(13) and 710 iac 1-17-1(y)(2001). The division alleged that from approximately May 5. 2009, to June 11,2009, WFA engaged in dishonest and unethical practices by failing to supervise its agents and employees in violation of ind. Code § 23­19­4­12(d)(13) & 710 iac 1­17­1(v)(2001).","res":"Consent","sm":"Without admitting or denying the allegations, the firm consented to the described sanctions. The firm was fined $8,000.00 and paid restitution to the client in the amount of $495.84.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2389},{"d":"2010-11-09","di":"2010-03-02","dr":"2010-11-09","k":"Regulatory Action","rg":"State regulator","reg":"State of Montana","st":"Final","fine":100000.0,"dk":"SEC-2010-32","al":"The Montana securities department investigated the actions of a former financial advisor for allegedly misappropriating customer funds.","res":"Consent","sm":"This matter has been resolved as set forth above.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2390},{"d":"2010-11-09","di":"2010-11-09","dr":"2010-11-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":650000.0,"dk":"20100224738-01","al":"The Financial Industry Regulatory Authority (\"FINRA\") department of enforcement alleged that, between November 2009 and May 2010, Goldman, Sachs & co. (the \"firm\") (I) failed in two instances to update the uniform applications for securities industry registration or transfer (\"forms U4\") for two registered representatives who received wells notices, as required by FINRA by- laws, article v, section 2(c), and (II) did not have in place an effective procedure to ensure that the compliance group responsible for filing amendments to forms U4 was promptly notified about wells notices regarding registered persons, in alleged violation of NASD conduct rule 3010 and FINRA rule 2010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the findings, and solely for purposes of a FINRA proceeding, the firm submitted a letter of acceptance, waiver and consent which was accepted by FINRA on November 9, 2010 that included (1) a censure, (2) a fine in the amount of $650,000 which was paid on November 18, 2010 and (3) an undertaking requiring a certification by the firm within 90 calendar days that (I) it completed a review of its supervisory procedures and systems concerning Form U4 amendments and compliance with FINRA by-laws, article v, section 2(c) and (II) it implemented any necessary revisions.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2391},{"d":"2010-11-03","di":"2010-11-03","dr":"2010-11-03","k":"Regulatory Action","rg":"Other","reg":"Virgin Islands Division of Banking and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":45000.0,"dk":"12-10","al":"Various state regulators, including the Virgin Islands Division of Banking and Insurance, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Virgin Islands Division of Banking and Insurance alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Virgin Islands Division of Banking and Insurance on November 3, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $45,000.00 to the Virgin Islands Division of Banking and Insurance, which amount was paid on November 17, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2392},{"d":"2010-11-03","di":"2010-11-03","dr":"2010-11-03","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":175000.0,"dk":"LETTER OF ACCEPTANCE, WAIVER AND CONSENT (\"AWC\"), NO. 2007009458001","al":"Janney entered into an AWC arising from issues identified in FINRA's routine cycle examinations of the firm in the years 2003 through 2005. The violations set forth in the AWC, which Janney neither admitted nor denied, include 1) a failure to adequately monitor and supervise certain elements of compliance with its AML program and 2) failure to establish and maintain certain elements of its branch supervision program related to registered representatives and other associated persons, including failure to supervise certain activities of branch managers, failure to review bloomberg emails and instant messages of some employees, failure to establish procedures for approval and supervision of use of personal computers, failure to determine the number of outside accounts maintained by employees , in 2003 a failure to document supervisory review of trading in options accounts, and several instances each year of failure to pre-review and approve communications with the public.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm was censured and fined $175,000, with $25,000 related to violations of MSRB rule G-41. Janney also submitted a corrective action statement which sets forth the enhancements made to the firm's compliance and supervisory policies and procedures. The enhancements include implementing new procedures, contracting new vendors, and adopting new technologies, as well bolstering supervisory efforts in certain areas. In addition, Janney placed a firm-wide emphasis on its AML program, including firm-wide AML training and enhanced surveillance tools. Janney is confident that these measures demonstrate its ongoing commitment to compliance in all areas of its business.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2393},{"d":"2010-10-28","dr":"2010-10-28","k":"Regulatory Action","rg":"Other","reg":"Maine Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"08-012","al":"The state of Maine Office of Securities investigated the actions of a former financial advisor for allegedly exercising discretion in two customer accounts, and investigated Edward jones to determine whether it failed to reasonably supervise the financial advisor.","res":"Order","sm":"This matter has been resolved as set forth above.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2394},{"d":"2010-10-25","di":"2010-10-25","dr":"2010-10-25","k":"Regulatory Action","rg":"Other","reg":"Boston Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"20090175424","al":"Boston Options Exchange (\"BOX\") regulation, LLC alleged that: (I) during the period between January 1, 2009 and January 31, 2010, Goldman, Sachs & co. (the \"firm\"), on certain occasions, traded against a directed order that the firm had previously received and rejected without first exposing it to the BOX book for at least three seconds, in alleged violation of BOX trading rules chapter VI, market makers, section 5, obligations of market makers (c)(III), and (II) that the firm failed to maintain an adequate system of supervision, including adequate written supervisory procedures and effective monitoring reasonably designed to achieve compliance with BOX rules relating to the obligations of a BOX market maker when handling directed orders, in alleged violation of BOX trading rule chapter v, doing business on BOX, section 1, access to and conduct on the BOX market, (b)(IV) BOX conduct.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (AWC) which was accepted by box on October 25, 2010, and on November 1, 2010, the firm submitted a check in payment of a fine in the amount of $15,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2395},{"d":"2010-10-25","di":"2010-10-25","dr":"2010-10-25","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":789931.65,"dk":"10 E 29","al":"Various state regulators, including the Kansas Securities Commissioner, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Kansas Securities Commissioner alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Kansas Securities Commissioner on October 25, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $789,931.65 to the Kansas Securities Commissioner, which amount was paid on November 2, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2396},{"d":"2010-10-25","di":"2010-10-25","dr":"2010-10-25","k":"Regulatory Action","rg":"State regulator","reg":"Division of Securities of the State of Delaware","san":"Cease and Desist","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":89151.79,"dk":"10-6-6","al":"Various state regulators, including the Division of Securities of the State of Delaware, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Division of Securities of the State of Delaware alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Division of Securities of the State of Delaware on October 25, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $89,151.79 to the Division of Securities of the State of Delaware, which amount was paid on November 1, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2397},{"d":"2010-10-20","di":"2010-10-20","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"Disgorgement, injunction, restitution, equitable relief","st":"Pending","al":"On October 20, 2010, the los angeles city attorney's office filed a civil action in the superior court of the state of California, county of los angeles, central district, against The Goldman Sachs Group, inc. (\"GS group\"), a control affiliate of the applicant, and healthmarkets, inc. (\"healthmarkets\"), among others. The complaint is generally directed at alleged practices by healthmarkets and various of its affiliates in connection with structuring and marketing insurance products, but also names GS group and blackstone group L.P. as the alleged owners and \"alter egos\" of healthmarkets. Certain affiliates of GS group own a minority interest in healthmarkets. The complaint alleges violations of California's unfair competition law and false advertising law, and seeks equitable relief and civil penalties. People of the state of California v. healthmarkets, inc, et. Al., BC447836 (superior court of the state of California, county of los angeles, central district, filed oct. 20, 2010).","ab":"The Goldman Sachs Group,","firms":[361],"id":2398},{"d":"2010-10-19","di":"2010-10-19","dr":"2010-10-19","k":"Regulatory Action","rg":"State regulator","reg":"State of Alaska; Department Commerce, Community, and Economic Development; Division of Banking and Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":129131.1,"dk":"ADMINISTRATIVE CONSENT ORDER NO. 10-07-S","al":"The state of Alaska has alleged that wachovia securities misrepresented the sale of auction rate securities to customers","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2399},{"d":"2010-10-05","di":"2010-10-05","k":"Civil Judicial Action","san":"Other","os":"No dollar amount indicated within petition.","st":"Pending","al":"Negligence, fraud, illegality, fraudulent inducement, negligent misrepresentation, unsuitability and breach of contract.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2400},{"d":"2010-10-04","di":"2010-10-04","dr":"2010-10-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"2009016286401","al":"FINRA rule 2010, NASD rules 2110, 3010, 3070 - Wells Fargo Advisors Financial Network, LLC failed to file summary and statistical information for customer complaints by the 15TH day of the month following the calendar quarter in which they were received by the firm. The firm's supervisory system was not reasonably designed to ensure that summary and statistical information of customer complaints was filed in accordance with NASD rule 3070. The firm's supervisory system failed to provide for reasonable follow-up and review to ensure that required customer complaint filings were made.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2401},{"d":"2010-09-16","di":"2010-07-28","dr":"2010-09-16","k":"Regulatory Action","rg":"Other","reg":"BAFIN ­ Bundesanstalt FÜR Finanzdienstleistungsaufsicht","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":59441.0,"dk":"WA17-WP3120-2009/0049-0051,0067-0069","al":"Technical breach of shareholder disclosure obligations as required by bundesanstalt fÜr finanzdienstleistungsaufsicht","res":"Settled","sd":"Fine was imposed on sim LTD in the amount of $59,441 usd. Amount paid in full on 9/16/2010.","sm":"The matter has been settled and the fine has been paid.","ab":"Schroder Investment","firms":[106585],"id":2402},{"d":"2010-09-10","di":"2010-09-10","dr":"2010-09-10","k":"Regulatory Action","rg":"Other","reg":"Louisiana Office of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":118528.64,"dk":"OFI-2010-0014","al":"Various state regulators, including the Louisiana Office of Financial Institutions, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Louisiana Office of Financial Institutions alleged that Goldman, Sachs & co.(the \"firm\") failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Louisiana Office of Financial Institutions on September 10, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $118.528.64 to the Louisiana Office of Financial Institutions, which amount was paid on September 23, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2403},{"d":"2010-09-03","di":"2010-09-03","dr":"2010-09-03","k":"Regulatory Action","rg":"Other","reg":"Financial Services Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":27371750.0,"al":"The Financial Services Authority in the UK (\"FSA\") investigated Goldman Sachs international (\"GSI\") in relation to (I) the marketing of the synthetic collateralized debt obligation transaction named ABACUS 2007-AC1 (\"ABACUS\") by GSI, (II) the failure by GSI to notify the FSA of the Securities and Exchange Commission's (\"SEC\") investigation into ABACUS and (III) GSI's systems and controls with respect to the internal reporting and escalation of regulatory matters.","res":"Consent","sm":"Gsi agreed to the imposition of a fine by the FSA of GB£17.5 million, which amount was paid on September 15, 2010. As indicated in a notice published by the FSA on September 9, 2010 (the \"notice\"), in respect of breaches of FSA principles 2, 3 and 11, the FSA included in its 'reasons for the action' that, during the relevant period, which occurred between July 2009 at the latest and April 16, 2010: (I) in breach of FSA principle 2, gsi failed to conduct its business with due skill, care and diligence in relation to its regulatory obligations. Specifically, gsi failed to consider the regulatory reporting obligations for gsi of the SEC investigation, including the Goldman, Sachs & co. wells notice and the MR. fabrice tourre wells notice, (II) in breach of FSA principle 3, gsi failed to take reasonable care to organize and control its affairs responsibly and effectively with adequate policies, procedures, systems and controls in relation to internal communications within the GS group and gsi to enable gsi to fulfill its external regulatory reporting obligations, and (III) in breach of FSA principle 11, gsi failed to disclose the MR. tourre wells notice to the FSA, which was information of which the FSA would reasonably expect notice and which was reasonably material to the assessment of MR. tourre's fitness and propriety to hold a controlled function. The FSA accepted that this failure was not as a result of gsi deliberately withholding information. No finding was made with respect to the marketing of abacus by gsi. As acknowledged in the notice, a program of enhancements to gsi's systems is underway to ensure that all relevant issues are reported to the FSA. A number of improvements have already been made. The notice also specifically states that the breaches it identified were not deliberate, but inadvertent and that they do not reflect adversely on the integrity of gsi or the individuals concerned.","ab":"Goldman Sachs","firms":[361],"id":2404},{"d":"2010-08-24","di":"2010-08-24","dr":"2010-08-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"20090186424-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the periods from January 1 to March 31, 2009 and October 1 to December 31, 2009, Goldman, Sachs & co. (the \"firm\") failed to report the correct time of execution to the real-time transaction reporting system (\"RTRS\") for certain reports of transactions in municipal securities and failed to report information regarding certain purchase and sale transactions effected in municipal securities to the RTRS in a timely manner as prescribed by rule G-14 RTRS procedures and the RTRS users manual, in alleged violation of MSRB rule G-14.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on August 24, 2010 and on September 15, 2010, the firm submitted a wire in payment of a fine in the amount of $25,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2405},{"d":"2010-08-19","di":"2010-08-19","dr":"2010-08-19","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Department of Commerce and Insurance, Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":410721.37,"dk":"10-005 (SI-2008-010)","al":"Various state regulators, including the Tennessee Department of Commerce and Insurance, Securities Division, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Tennessee Department of Commerce and Insurance, Securities Division, alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with Tennessee Department of Commerce and Insurance, Securities Division, on August 19, 2010 in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $410,721.37 to the Tennessee Department of Commerce and Insurance, Securities Division, which amount was paid on September 1, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2406},{"d":"2010-08-19","di":"2010-07-14","dr":"2010-08-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":15000.0,"dk":"2009018642201","al":"From 1/1/2009-3/31/2009 the firm failed to report the correct time on 142 reports to \"RTRS\" the firm also failed to report 141 trades within the required 15 minutes.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $15,000 for 142 trades reported with an incorrect time and 141 trades reported after the required 15 minutes","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2407},{"d":"2010-08-09","di":"2010-08-09","dr":"2010-08-09","k":"Regulatory Action","rg":"State regulator","reg":"Securities Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":67707.37,"dk":"10032","al":"Various state regulators, including the Securities Commissioner of South Carolina, conducted an industry-wide, joint investigation into the marketing and sales of ars. In the administrative consent order, the Securities Commissioner of South Carolina alleged that Goldman, Sachs & co. (the \"firm\") engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Securities Commissioner of South Carolina on August 9, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $67,707.37 to the Securities Commissioner of South Carolina, which amount was paid on August 19, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2408},{"d":"2010-07-27","di":"2010-07-27","dr":"2010-07-27","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":2878447.86,"dk":"IC10-CDO-17","al":"Various state regulators, including the Texas State Securities Board, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2409},{"d":"2010-07-20","di":"2010-07-20","dr":"2010-07-20","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":132470.25,"dk":"AP-10-21","al":"Various state regulators, including the Missouri Secretary of State Securities Division conducted an industry-wide, joint investigation into the marketing and sales of ars. In the consent order, the Missouri Secretary of State Securities Division alleged that the firm engaged in unethical practices in the offer and sale of ars and failed adequately to supervise certain of its salespeople in connection with the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Missouri Secretary of State Securities Division on July 20, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $132,470.25 to the Missouri Secretary of State Securities Division, which amount was paid on July 23, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2410},{"d":"2010-07-20","di":"2010-04-16","dr":"2010-07-20","k":"Civil Judicial Action","san":"Injunction","os":"The court judgment requires the applicant to comply with certain undertakings relating to (I) the vetting and approval","st":"Final","fine":535000000.0,"al":"The conduct of the applicant alleged in the SEC complaint involved an offering of a synthetic collateralized debt obligation, which referenced a portfolio of synthetic residential mortgage-backed securities, to qualified institutional buyers in reliance on the exemption from registration under the Securities Act of 1933 provided by rule 144a thereunder and to non-U.S. persons in reliance on the safe harbor from registration provided by regulation s thereunder. Specifically, the complaint alleged that the offering materials, in describing the portfolio selection agent for the portfolio of synthetic residential mortgage-backed securities, should have disclosed that the hedge fund assuming the short side of the transaction had played a role in the selection process. In its consent to the court judgment, the applicant acknowledged that it was a mistake not to disclose the role of the hedge fund.","res":"Judgment Rendered","sd":"Permanent injunction from violation of section 17(a) of the Securities Act of 1933, civil penalties of $535,000,000 to be paid within 30 days of entry of judgment and disgorgement of $15,000,000 to be paid within 30 days of entry of judgment. The civil penalties and disgorgement were paid on August 18, 2010. The court judgment also requires the applicant to comply with certain undertakings relating to (I) the vetting and approval process for offerings of residential mortgage-related securities, (II) review of marketing materials used in connection with residential mortgage-related securities offerings by the applicant's legal department and compliance department, (III) annual internal audits of the review of such marketing materials, (IV) where the firm is the lead underwriter of an offering of residential mortgage-related securities and retains outside counsel to advise on the offering, review of the related offering materials by outside counsel and (v) education and training of persons involved in the structuring or marketing of residential mortgage-related securities offerings. The judgment further requires record-keeping to track compliance and certification of compliance with these requirements by the applicant's general counsel or global head of compliance one, two and three years after the date of entry of the judgment.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2411},{"d":"2010-07-15","di":"2010-07-15","dr":"2010-07-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"20090171872-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period from May 1, 2006 through April 30, 2009, Goldman, Sachs & co. (the \"firm\") reported to the OTC reporting facility certain last sale reports of transactions in OTC equity securities which it should have not reported, in alleged violation of NASD rule 6620(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on July 15, 2010, and on August 3, 2010, the firm submitted a check in payment of a fine in the amount of $15,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2412},{"d":"2010-07-15","di":"2010-07-15","dr":"2010-07-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Conecticut Department of Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":863341.3,"dk":"CO-10-7568-S","al":"On July 15, 2010, the Connecticut banking commissioner entered a consent order with respect to wachovia securities, LLC (n/k/a Wells fargo advisors, LLC), a Connecticut-registered broker dealer located at one north jefferson avenue, ST. louis, Missouri. The consent order followed an investigation by a multistate task force into the marketing and sale of auction rate securities (ARS) by the firm from January 1, 2006 through February 14, 2008. The consent order alleged that, in conjunction with the marketing of ARS, the firm failed to supervise their employees, and that the firm engaged in dishonest or unethical practices in the securities business by mischaracterizing or failing to adequately explain ARS to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2413},{"d":"2010-07-15","di":"2010-07-15","dr":"2010-07-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"2008012608401","al":"The firm was cited for various trade reporting violations due to incorrect trade indicators and failure to disclose trade capacity and market maker status on customer confirmations. The firm's written supervisory procedures were also found to be inadequate.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine was paid by applicant via check on July 19,2010","sm":"The firm found that most of the trade reporting violations were due to misunderstanding of how the system was reporting trades and also the reports provided were not good indicators of reporting problems. The firm has corrected system issues and have subscribed to Nasdaq's system in order to track reports in real time. The written supervisory procedures were updated and provided to FINRA for review and were found to be satisfactory.","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":2414},{"d":"2010-07-15","di":"2010-05-12","dr":"2010-07-15","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC (Nasdaq)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"2008012608402","al":"The firm failed to correctly indicate whether orders were a buy, short sale or long sale which are violations of Nasdaq rule 4755.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Applicant will pay the fine via check as soon as invoice is received from Nasdaq in August 2010.","sm":"The firm corrected system issues and updated and subsribed to Nasdaq's service to better monitor reporting, as well as, updating written supervisory procedures.","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":2415},{"d":"2010-07-14","di":"2010-07-14","dr":"2010-07-14","k":"Regulatory Action","rg":"State regulator","reg":"State of Hawaii Department of Commerce and Consumer Affairs","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":211619.92,"dk":"SEU-2008-069","al":"State of Hawaii alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2416},{"d":"2010-07-09","di":"2010-07-09","dr":"2010-07-09","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Other","os":"Consent","st":"Final","fine":40500.0,"dk":"AP-10-15","al":"In July 2009, the Missouri Securities Division (the \"division\") began an investigation regarding the sale of a variable annuity to a client of Edward jones who is now deceased. Upon completing its investigation, the division alleged Edward jones failed to reasonably supervise its financial advisor by failing to reasonably review the death benefit options available for the variable annuity.","res":"Consent","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2417},{"d":"2010-07-02","di":"2010-03-19","dr":"2010-07-02","k":"Regulatory Action","rg":"State regulator","reg":"Virginia - Division of Securities","san":"Restitution","st":"Final","dk":"SEC-2007-00021","al":"In April 2002 the Virginia state corporation commission, division of securities and retail franchising (the \"division\") commenced an investigation into Edward jones based on actions of a former financial advisor and his recommendation for use of margin dating back to 1998. After investigating the matter, the division alleged that Edward jones conducted activity that constituted a violation of the Virginia Securities Act and provisions of the code of Virginia: (I) by engaging in a transaction, practice or course of business which operates as a fraud or deceit upon a purchaser; (II) by failing to make and keep true, accurate and current, and preserve the books and records relating to its business; (III) by failing to establish, maintain and enforce written procedures; (IV) by failing to perform frequent examinations of all customer accounts to detect and prevent irregularities or abuses; and (v) by failing to review and receive written approval by the designated supervisor of the delegation by any customer of discretionary authority with respect to the customer's account.","res":"Settled","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2418},{"d":"2010-06-29","di":"2010-06-29","dr":"2010-06-29","k":"Regulatory Action","rg":"State regulator","reg":"Georgia Office of the Secretary of State, Securities and Business Regulation Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":986271.87,"dk":"ENSC-01520","al":"Various state regulators, including the Georgia Office of the Secretary of State, Securities and Business Regulation Division, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Georgia Office of the Secretary of State, Securities and Business Regulation Division on June 29, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $986,271.87 to the Georgia Office of the Secretary of State, Securities and Business Regulation Division, which amount was paid on July 1, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2419},{"d":"2010-06-29","di":"2010-06-29","dr":"2010-06-29","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market","san":"Censure","os":"Fine and undeertaking","st":"Final","fine":10000.0,"dk":"2008015287001","al":"The firms written supervisory procedures were not reasonably designed to achieve compliance with Nasdaq rules concerning clearly erroneous transaction complaints.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured, fined $10,000 and required to revise the written supervisory procedures regarding NASD notice to members 04-66","sm":"Without admitting or denying the findings the firm consented to the described sanctions and to the entry of findings","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2420},{"d":"2010-06-24","di":"2010-06-24","dr":"2010-06-24","k":"Regulatory Action","rg":"State regulator","reg":"Commissioner of Securities and Insurance, Office of the Montana State Auditor","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":81980.58,"dk":"SEC-2010-43","al":"Various state regulators, including the Commissioner of Securities and Insurance, Office of the Montana State Auditor, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Commissioner of Securities and Insurance, Office of the Montana State Auditor on June 24, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $81,980.58 to the Commissioner of Securities and Insurance, Office of the Montana State Auditor, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2421},{"d":"2010-06-23","di":"2010-06-23","dr":"2010-06-23","k":"Regulatory Action","rg":"Other","reg":"Office of Financial Institutions of Puerto Rico","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":45000.0,"dk":"C10-V-004","al":"Various state regulators, including the Office of Financial Institutions of Puerto Rico, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Office of Financial Institutions of Puerto Rico on June 23, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $45,000.00 to the Office of Financial Institutions of Puerto Rico, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2422},{"d":"2010-06-22","di":"2010-06-22","dr":"2010-06-22","k":"Regulatory Action","rg":"State regulator","reg":"Securities and Charities Division of the Mississippi Secretary of State's Office","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":49382.88,"dk":"S-10-0047","al":"Various state regulators, including the Securities and Charities Division of the Mississippi Secretary of State's Office, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Securities and Charities Division of the Mississippi Secretary of State's Office on June 22, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $49,382.88 to the Securities and Charities Division of the Mississippi Secretary of State's Office, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2423},{"d":"2010-06-22","di":"2010-06-22","dr":"2010-06-22","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":45000.0,"al":"Various state regulators, including the North Dakota Securities Department, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the North Dakota Securities Department on June 22, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $45,000.00 to the North Dakota Securities Department, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2424},{"d":"2010-06-21","di":"2010-06-21","dr":"2010-06-21","k":"Regulatory Action","rg":"State regulator","reg":"Nevada Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":278460.65,"dk":"I10-124","al":"Various state regulators, including the Nevada Secretary of State Securities Division, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Nevada Secretary of State Securities Division on June 21, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $278,460.65 to the Nevada Secretary of State Securities Division, which amount was paid on July 1, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2425},{"d":"2010-06-21","di":"2010-06-21","dr":"2010-06-21","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1181331.82,"dk":"CO-2010-0034","al":"Various state regulators, including the Alabama Securities Commission, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Alabama Securities Commission on June 21, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,181,331.82 to the Alabama Securities Commission, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2426},{"d":"2010-06-21","di":"2010-06-21","dr":"2010-06-21","k":"Regulatory Action","rg":"Other","reg":"Maine Department of Professional & Financial Regulation, Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":52907.93,"dk":"10-0043","al":"Various state regulators, including the Maine Department of Professional & Financial Regulation, Office of Securities, conducted an industry-wide, joint investigation into the marketing and sale of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Maine Department of Professional & Financial Regulation, Office of Securities on June 21, 2010, in which the firm agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $52,907.93 to the Maine Department of Professional & Financial Regulation, Office of Securities, which amount was paid on June 30, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2427},{"d":"2010-06-18","di":"2010-06-18","dr":"2010-06-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Louisiana - Office of Financial Institutions - Commissioner of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":596362.56,"dk":"OIF-2010-001","al":"Stateof Louisiana has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2428},{"d":"2010-06-07","di":"2010-06-07","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"Plaintiff is alleging negligent misrepresentation, common law fraud, civil conspiracy and breach of fiduciary duty.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2429},{"d":"2010-06-04","di":"2010-06-04","dr":"2010-06-04","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":22500.0,"dk":"20090168185-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period from February 2, 2009 through May 14, 2009, Goldman, Sachs & co. (the \"firm\"): (I) submitted certain electronic blue sheets that did not include the ticker symbol, in alleged violation of FINRA rules 8211 and 8213 and (II) that the firm's supervisory system did not include adequate written supervisory procedures concerning the validation of data on blue sheet submissions, in alleged violation of FINRA rule 2010 and NASD rule 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on June 4, 2010, and on June 17, 2010, the firm submitted a wire in payment of a fine in the amount of $22,500. According to the terms of the AWC, the firm agreed to revise its written supervisory procedures concerning the validation of data on blue sheet submissions.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2430},{"d":"2010-06-02","di":"2009-08-03","dr":"2010-06-02","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":200000.0,"dk":"2007010537701","al":"G g y (y p p p ) FINRA alleged Edward jones violated NASD rules 2110, 3010(a), 3012(a)(2)(b)(I) by failing to establish, maintain and enforce a supervisory system, including written supervisory procedures that were reasonably designed to review and monitor all transmittals of funds from the accounts of customers to third party accounts. Edward jones allegedly relied on a defective report, which was incomplete and inaccurate, to review and monitor third party wires from customer accounts, and failed to properly test and verify the sytem providing the report was functioning properly. As a result, the report failed to indentify wires from accounts from which a former Edward jones financial advisor was converting funds, and the financial advisor ultimately converted over $3 million in customer funds.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2431},{"d":"2010-05-27","di":"2010-05-27","dr":"2010-05-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":120000.0,"dk":"20070078333-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) during certain periods from April 2006 through January 2007, Goldman, Sachs & co. (the \"firm\") failed to report short interest positions in certain foreign and reportable securities, and on July 31, 2008, August 15, 2008 and August 29, 2008, reported short interest positions in certain securities when the actual short interest position in the securities was zero shares, in alleged violation of NASD rule 3360; (II) during the period from June 15, 2007 to December 31, 2007, inadvertently failed to remove its 'excused withdrawal' status as a Nasdaq market maker in three securities and consequently, on certain occasions involving such securities, accepted a short sale order in an equity security from another person, or effected a short sale order in an equity security for its own account, in mistaken reliance on the market maker exemption contained in SEC rule 203(b)(2)(III), in alleged violation of SEC rule 203(b)(1) of Regulation SHO; (III) during the period from June 15, 2007 to December 31, 2007, the firm's supervisory system did not include adequate written supervisory procedures specifically concerning SEC rule 203(b)(3), and the firm failed to provide adequate documentation that it performed certain reviews set forth in its written supervisory procedures concerning SEC rule 200(g) and NASD rule 6130(d)(6), in alleged violation of NASD rules 2110 and 3010; and (IV) during the period from January 1, 2008 through April 30, 2008, the firm failed to accept or decline in the FINRA/Nasdaq trade reporting facility certain transactions in reportable securities in a timely manner that the firm had an obligation to accept or decline as the order entry identifier (OEID), in alleged violation of NASD rule 6130(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on May 27, 2010, and on June 14, 2010, the firm submitted a wire in payment of a fine in the amount of $120,000. According to the terms of the AWC, the firm agreed to revise its written supervisory procedures regarding SEC rule 203(b)(3).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2432},{"d":"2010-05-20","di":"2010-05-20","dr":"2010-05-20","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":17500.0,"dk":"2009-167","al":"The International Securities Exchange, LLC (\"ISE\") alleged that, during the period from May 2009 through August 2009, Goldman, Sachs & co. (the \"firm\") failed to report large option position reports with regard to certain accounts that met the reporting requirement threshold in alleged violation of ISE rule 415.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by ise on May 20, 2010 and on June 4, 2010, the firm submitted a wire in payment of a fine in the amount of $17,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2433},{"d":"2010-05-19","di":"2010-05-19","dr":"2010-05-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":10000.0,"dk":"2009017658001","al":"NASD rules 2110, 2111(a), 2320 - Wedbush Securities, inc. failed to execute orders fully and promptly. In transactions for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fines $10,000.00. The firm made restitution payments totalling %581.38","sm":"Without admitting or denying the findings the firm consented to the described sanctions and findings.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2434},{"d":"2010-05-17","di":"2010-05-17","dr":"2010-05-17","k":"Regulatory Action","rg":"Other","reg":"Arizona Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":172067.59,"dk":"S-03533A-10-0110, DECISION 71698","al":"Various state regulators, including the Arizona Corporation Commission, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an order to cease and desist, order for administrative penalties, and consent to same with the Arizona Corporation Commission on May 17, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $172,067.59 to the state of Arizona, which amount was paid on May 28, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2435},{"d":"2010-05-11","di":"2010-05-11","dr":"2010-05-11","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine","st":"Final","fine":25000.0,"dk":"2007009356502","al":"Violation of NASD rules 2110, 2210(c)(1), 2210(c)(2)(a), 2210(d)(1)(a), 2210(d)(1)(b), 2210(d)(2)(b), & 2211 (d): respondent Wells fargo advisors, LLC failed to file pieces of unit investment trust \"uit\" marketing material with the NASD department of advertising regulation. The firm internally used pieces of uit marketing material that failed to comply with NASD content standards in that they failed TP provide a sound basis for evaluation and a complete presentation regarding the uits. The firm also used a piece of marketing material that compared uits to other investments without including all material differences between the investment options.","res":"Acceptance, Waiver & Consent(AWC)","sm":"FINRA alleged violation of NASD rules 2110, 2210(c)(1), 2210(c)(2)(a), 2210(d)(1)(a), 2210(d)(1)(b), 2210(d)(2)(b), & 2211(d)in that the respondent Wells fargo advisors, LLC failed to file pieces of unit investment trust \"uit\" marketing material with the NASD department of advertising regulation. The firm internally used pieces of uit marketing material that failed to comply with NASD content standards in that they failed TP provide a sound basis for evaluation and a complete presentation regarding the uits. The firm also used a piece of marketing material that compared uits to other investments without including all material differences between the investment options. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of the findings; therefore, the firm was censured and fined $25,000.00","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2436},{"d":"2010-04-30","di":"2010-04-30","dr":"2010-04-30","k":"Regulatory Action","rg":"Other","reg":"Rhode Island Department of Business Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":211744.22,"dk":"10-061","al":"Various state regulators, including the Rhode Island Department of Business Regulation, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Rhode Island Department of Business Regulation on April 30, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $211,744.22 to the state of Rhode Island, which amount was paid on May 14, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2437},{"d":"2010-04-30","di":"2010-04-30","dr":"2010-04-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7500.0,"dk":"20090203753-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that, during the period from January 1, 2009 through March 31, 2009, with respect to 12 transactions, Goldman, Sachs & co. (the \"firm\") failed to use reasonable diligence to ascertain the best inter-dealer market and to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions, in alleged violation of FINRA rule 2010 and national association of securities dealers (NASD) rule 2320.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm consented to a censure and entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on April 30, 2010. On May 19, 2010, the firm submitted a wire in payment of the fine in the amount of $7,500. Per the terms of the AWC, the firm provided restitution to the relevant market participant in the amount of $2,633.75, representing $2,504.75 plus applicable interest, by mailing of a check on May 25, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2438},{"d":"2010-04-30","di":"2010-04-30","dr":"2010-04-30","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market","san":"Censure","os":"Fine","st":"Final","fine":13500.0,"dk":"20080123149-01","al":"From July 1 to September 30 2007 the firm failed to immediately display 24 order in violation of SEC rule 604 of reg NMS. From July 1 to September 30, 2007 the firm failed to transmit 65 roe's to OATS in violation of NASD rule 6955(a).","res":"Acceptance, Waiver & Consent(AWC)","sd":"Censured and fined $13,500","sm":"The firm accepted and consented, without admitting or denying the findings noted above.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2439},{"d":"2010-04-29","di":"2010-04-29","dr":"2010-04-29","k":"Regulatory Action","rg":"State regulator","reg":"Indiana Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":284818.71,"dk":"10-0063 CO","al":"Various state regulators, including the Indiana Secretary of State Securities Division, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Indiana Secretary of State Securities Division on April 29, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $284,818.71 to the state of Indiana, which amount was paid on May 6, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2440},{"d":"2010-04-28","di":"2010-04-28","dr":"2010-04-28","k":"Regulatory Action","rg":"State regulator","reg":"Securities Division of the Washington State Department of Financial Institutions","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":285652.04,"dk":"S-10-086-10-CO01","al":"Various state regulators, including the Securities Division of the Washington State Department of Financial Institutions, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Securities Division of the Washington State Department of Financial Institutions on April 28, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $285,652.04 to the state of Washington, which amount was paid on May 7, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2441},{"d":"2010-04-28","di":"2010-04-28","dr":"2010-04-28","k":"Regulatory Action","rg":"State regulator","reg":"South Dakota Department of Revenue and Regulation Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":45792.96,"al":"Various state regulators, including the South Dakota Department of Revenue and Regulation Division of Securities, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the South Dakota Department of Revenue and Regulation Division of Securities on April 28, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $45,792.96 to the state of South Dakota, which amount was paid on May 7, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2442},{"d":"2010-04-27","di":"2010-04-27","dr":"2010-04-27","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":47234.69,"dk":"2010-7-11","al":"Various state regulators, including the Idaho Department of Finance, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Idaho Department of Finance on April 27, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $47,234.69 to the state of Idaho. The fine is not required to be paid until after July 1, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2443},{"d":"2010-04-27","di":"2010-04-27","dr":"2010-04-27","k":"Regulatory Action","rg":"State regulator","reg":"Vermont Department of Banking, Insurance, Securities and Health Care Administration","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":51668.04,"dk":"10-032-S","al":"Various state regulators, including the Vermont Department of Banking, Insurance, Securities and Health Care Administration, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the Vermont Department of Banking, Insurance, Securities and Health Care Administration on April 27, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $51,668.04 to the state of Vermont, which amount was paid on May 6, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2444},{"d":"2010-04-27","di":"2010-04-27","dr":"2010-04-27","k":"Regulatory Action","rg":"Other","reg":"California Department of Corporations","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1595769.53,"al":"Various state regulators, including the California Department of Corporations, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into an administrative consent order with the California Department of Corporations on April 27, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,595,769.53 to the state of California, which was paid on May 6, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2445},{"d":"2010-03-31","di":"2009-02-24","dr":"2010-03-31","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Filing of requested documents","st":"Final","fine":20000.0,"dk":"N/A","al":"Wedbush was alledged to fail to provide the bureau with documents in order to review the agent application of an individual who was previously a registered representative of the firm. Wedbush failed to respond to subsequent requests and a summary order was sent.","res":"Consent","sd":"Wedbush was fined $20,000 and provided the missing documents.","sm":"Wedbush signed the consent order 3/25/2010 and the bureau signed it on 3/31/2010.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2446},{"d":"2010-03-30","di":"2010-07-12","dr":"2010-03-30","k":"Civil Judicial Action","san":"Other","os":"Relief granted by the court. Also refer to details in point 14 of part II of civil judicial action disclosure reporting page (ADV).","st":"On appeal","al":"Please refer to details in point 14 of part II of civil judicial action disclosure reporting page (ADV)","res":"Judgment Rendered","sd":"Relief granted by the court. Also refer to details in point 14 of part II of civil judicial action disclosure reporting page (ADV).","ab":"Kampani, Nimesh, Nagindas","firms":[293667],"id":2447},{"d":"2010-03-29","di":"2010-03-29","dr":"2010-03-29","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Secretary of State Illinois Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1691207.3,"dk":"08-00202","al":"The state of Illinois has alleged that wachovia securities misrepresented the sale of auction rate securities (ARS) to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2448},{"d":"2010-03-25","di":"2010-03-25","k":"Regulatory Action","rg":"Other","reg":"NZX Limited","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Costs; agreement to review related customer complaint","st":"Final","fine":30000.0,"dk":"NZMDT 001/10","al":"NZX Limited (\"NZX\") alleged that Goldman Sachs Jbwere (NZ) limited (\"jbwere (NZ)\") breached NZX participant rules 11.3.1 and 8.1.1(c) by failing to bring a client's order to market and by inaccurately advising the same client that its order had been placed.","res":"Settled","sm":"The NZX and jbwere (NZ) agreed to settlement terms that were approved by the NZ markets disciplinary tribunal on May 25, 2010, and on June 22, 2010, jbwere (NZ) paid a monetary penalty in the amount of NZ$30,000 to the NZX.","ab":"Goldman Sachs Jbwere (NZ)","firms":[361],"id":2449},{"d":"2010-03-19","di":"2010-03-19","dr":"2010-03-19","k":"Regulatory Action","rg":"State regulator","reg":"Illinois Secretary of State Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase auction rate securities (\"ARS\") from certain eligible retail investors, charities and small","st":"Final","fine":1559615.06,"dk":"08-00236","al":"Various state regulators, including the Illinois Secretary of State Securities Department, conducted an industry-wide, joint investigation into the marketing and sales of ars.","res":"Consent","sm":"Without admitting or denying the allegations, the firm entered into a consent order with the Illinois Secretary of State Securities Department on March 19, 2010, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,559,615.06 to the state of Illinois, which amount was paid on March 31, 2010.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2450},{"d":"2010-03-18","di":"2010-03-18","dr":"2010-03-18","k":"Regulatory Action","rg":"Other","reg":"Commissione Nazionale Per Le SocietÀ E la Borsa","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":33460.0,"al":"Technical breach of shareholder disclosure obligations as defined by the Commissione Nazionale Per Le SocietÀ E la Borsa","res":"Settled","sd":"Fine has been paid","sm":"The matter has been settled and the fine has been paid No information Filed","ab":"Schroders Investment","firms":[106585],"id":2451},{"d":"2010-03-15","di":"2010-03-15","dr":"2010-03-15","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"20080139143-01","al":"Financial Industry Regulatory Authority, Inc. (\"FINRA\") department of market regulation alleged that: (I) during the period from January 1, 2008 through April 30, 2008, Goldman, Sachs & co. (the \"firm\") failed to report to the FINRA/Nasdaq trade reporting facility certain transactions in a timely manner that required specified modifiers and failed to report the correct time of execution of certain transactions in reportable securities, in alleged violation of national association of securities dealers (\"NASD\") rules 6130(g) and 6130(d), respectively, and (II) during the period from April 1, 2008 through June 30, 2008, failed to timely report to the trade reporting and compliance engine (\"TRACE\") certain transactions in TRACE-eligible securities, in alleged violation of NASD rules 6230(a) and 2110.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (AWC) which was accepted by FINRA on March 15, 2010, and on April 13, 2010, the firm submitted a wire in payment of a fine in the amount of $40,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2452},{"d":"2010-03-12","di":"2010-03-12","dr":"2010-03-12","k":"Regulatory Action","rg":"Other","reg":"Department of the Treasury - Financial Crimes Enforcement Network","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":110000000.0,"dk":"2010-1","al":"The financial crimes enforcement network (\"FINCEN\") of the Department of the Treasury alleged that Wachovia Bank, N.A. (\"Wachovia Bank\") failed to implement adequate policies, procedures and controls relating to cash transfers for currency exchange houses and foreign correspondent customers, to conduct adequate monitoring of related transactions and customers, to adequately staff the Bank Secrecy Act (\"BSA\") compliance function, to effectively implement an independent audit function to test for BSA compliance, to file timely suspicious activity reports and to report currency transactions","res":"Order","sm":"FINCEN issued its assessment of civil money penalty concurrently with Wachovia Bank entering into a deferred prosecution agreement (\"agreement\") with the U.S. attorney's office and the U.S. Department of Justice (collectively, the \"United States\") on March 16, 2010. Pursuant to the agreement, Wachovia Bank settled civil and criminal forfeiture claims for the amount of $110 million, paid on or before March 21, 2010, and agreed to implement certain remedial measures designed to fully comply with the Bank Secrecy Act and to abide by any FINCEN orders and regulations. Wachovia Bank merged with and into Wells fargo bank, N.A. on March 20, 2010. Wells fargo bank, N.A. agreed to be bound by the terms and conditions of the agreement following the merger. The United States agreed that prosecution of Wachovia Bank be deferred for a period of twelve months and that, if Wells fargo bank, N.A. is in compliance in all material aspects with all of its obligations under the agreement, the United States, within thirty days of the expiration of that period, would seek dismissal with prejudice of the charge.","ab":"Wachovia Bank N.A.; Wachovia Bank, N.A.","firms":[11025,19616],"id":2453},{"d":"2010-03-12","di":"2010-03-12","dr":"2010-03-12","k":"Regulatory Action","rg":"OCC","reg":"Department of the Treasury - Comptroller of the Currency","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist; - undertaking","st":"Final","fine":50000000.0,"dk":"AA-EC.-10-16; AAA-EC.-10-17","al":"The office of the Comptroller of the Currency (\"OCC\") alleged that Wachovia Bank, N.A. (\"Wachovia Bank\") failed to implement adequate policies, procedures and controls relating to cash transfers for currency exchange houses and foreign correspondent customers, to conduct adequate monitoring of related transactions and customers, to file timely suspicious activity reports and to adequately report cash structuring activity from review of internally generated reports","res":"Order","sm":"Wachovia Bank agreed, among other things, to take the necessary steps to address deficiencies and enhance its BSA and AML policies and procedures over foreign correspondent banking activities, to develop an action plan designed to address identified deficiencies and violations of law and to submit the action plan to the deputy comptroller within 90 days of the order, not to implement any material changes to the action plan without prior submission to and approval of the deputy comptroller, to submit a formal report to its board of directors and the deputy comptroller detailing the status of remediation activities within 120 days of the order, and to submit quarterly status reports until the provisions of the order are terminated by the comptroller. Wachovia Bank merged with and into Wells fargo bank, N.A. on March 20, 2010.","ab":"Wachovia Bank, N.A.; Wachovia Bank; N.A.","firms":[11025,19616],"id":2454},{"d":"2010-03-11","di":"2010-03-11","dr":"2010-03-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Arkansas Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":238385.75,"dk":"S-09-024-09-CO01","al":"Stateof Arkansas has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2455},{"d":"2010-02-24","di":"2009-08-03","dr":"2010-02-24","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"The corporation agreed, for a period of three years, to comply with and maintain certain requirements related to the","st":"Final","fine":150000000.0,"al":"The Securities and Exchange Commission (\"SEC\") alleged that Bank of America corporation (the \"corporation\") violated section 14(a) of the Securities Exchange Act of 1934 (the \"Exchange Act\") and rule 14A-9 thereunder by failing to disclose in the corporation's joint proxy statement filed on November 3, 2008 the incentive compensation that merrill lynch & co., inc. could, in its discretion, award to its employees prior to completion of its merger with the corporation.","res":"Consent","ab":"Bank of America","firms":[142558],"id":2456},{"d":"2010-02-24","di":"2010-01-12","dr":"2010-02-24","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"The corporation agreed, for a period of three years, to comply with and maintain certain requirements related to the","st":"Final","fine":150000000.0,"al":"The Securities and Exchange Commission (\"SEC\") alleged that Bank of America corporation (the \"corporation\") violated the federal proxy rules by failing to disclose information concerning merrill lynch & co., inc.'s known and estimated losses in the fourth quarter of 2008 prior to the shareholder vote on December 5, 2008 to approve the merger between the two companies.","res":"Consent","ab":"Bank of America","firms":[142558],"id":2457},{"d":"2010-02-16","di":"2010-02-16","dr":"2010-02-16","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq Omx PHLX, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"ENFORCEMENT NO. 2009-29","al":"Nasdaq Omx PHLX, Inc. (the \"exchange\") alleged that, during January 1, 2003 through August 3, 2004, and during November 1, 2005 through March 26, 2007, SLK-hull derivatives LLC (\"SHD\") failed to execute certain incoming orders for various option series at the disseminated price in an amount up to the disseminated size, in alleged violation of exchange rule 1082.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, SHD submitted an offer of settlement, stipulation of facts and consent to sanctions which was accepted by a decision of the business conduct committee of the exchange on February 16, 2010.","ab":"SLK Hull Derivatives LLC","firms":[361],"id":2458},{"d":"2010-02-12","di":"2010-02-12","dr":"2010-02-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"A fine of $38,000 (in 20060063857: $5,000 for SEC rule 604 and $5,000 for NASD rule 6955; in 2070089900: $5,000 for NASD rule 6130,","st":"Final","fine":38000.0,"dk":"20060063857-01","al":"The findings of three examinations from 2006 (2006006387), 2007 (20070089900), and 2008 (20080133281) were combined and the allegations were that the firm failed to: display immediately 27 customer limit orders in Nasdaq securities and transmitted to OATS 60 reports that contained inaccurate, incomplete, or improperly formatted data; submit the correct buy, sell, sell short or cross symbol for 56 transactions; on 69 occasions disclose that the transaction was executed at an average price; provide for one or more minimum requirements for adequate supervisory procedures; on four occasions disclose its correct capacity, on six occasions disclose the correct compensation type, and on one occasion disclose that the transaction was executed at an average price and data used for rule 605 reporting included incorrect information. The transactions involved represented less than .01% of transactions conducted during the time periods.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm paid the fine of $38,000 on 2/26/2010.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2459},{"d":"2010-02-12","di":"2010-02-12","dr":"2010-02-12","k":"Regulatory Action","rg":"Nasdaq","reg":"Nasdaq","san":"Other","os":"Fine of $5000.00","st":"Final","fine":5000.0,"dk":"20060063857-02","al":"The firm allegedly entered 11 orders into the Nasdaq market center that failed to correctly indicate whether the orders were a buy, short sale or long sale.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine of $5000.00","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2460},{"d":"2010-01-27","di":"2010-01-27","dr":"2010-01-27","k":"Regulatory Action","rg":"NYSE","reg":"NYSE ARCA, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3500.0,"dk":"NYSE ARCA MINOR RULE","al":"**01/27/2010**minor rule plan fine issued. Rule violation: violation of NYSE ARCA equities rule 10.2(d) for the failure of Wedbush Morgan securities inc. to provide timely responses to NYSE regulation's letters requesting documents and information which impeded and delayed four regulatory investigations.fine imposed: $3,500.00","res":"Decision","sd":"The firm agreed to pay a fine of $3,500.00 after originally contesting the imposition of the fine but determining it did not make financial sense to continue with the process.","sm":"The firm agreed to pay a fine of $3,500.00 on August 16, 2010 after originally contesting the imposition of the fine but determining it did not make financial sense to continue with the process.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2461},{"d":"2010-01-20","dr":"2010-01-20","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":5000.0,"dk":"2007009222201","al":"Respondent Janney failed in 2007 to report to TRACE large block transactions in TRACE-eligible securities within 15 minutes of the time of execution in violation of NASD rules 2110 and 6230(a)","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, Janney consented to a fine of $5,000,described sanction and to the entry of findings.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2462},{"d":"2010-01-15","di":"2010-01-15","dr":"2010-01-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Wisconsin Department of Financial Institutions Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":457903.77,"dk":"S-09137(EX)","al":"State of Wisconsin has alleged that wachovia securities misrepresented the sale of auction rate securities (ARS) to customers.","res":"Decision","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2463},{"d":"2010-01-04","di":"2010-01-04","dr":"2010-01-04","k":"Regulatory Action","rg":"Other","reg":"U.S. Virgin Islands - Office of the Lieutenant Governor - Division of Banking and Insurance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":116748.21,"dk":"01-09","al":"U.S. virgin islands has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2464},{"d":"2009-11-16","di":"2008-12-15","dr":"2009-11-16","k":"Regulatory Action","rg":"Other","reg":"Financial Services Authority (FSA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2900000.0,"dk":"WS00118","al":"Nomura International PLC. Failed to conduct its business with due skill, care and diligence and failed to take reasonable care to organize and control its affairs reasonably and effectively with adequate risk management systems.","res":"Consent","sd":"£1.75 million ­ the penalty imposed is discounted by 30% pursuant to the stage 1 early settlement discount scheme. Were it not for the discount, the FSA would have imposed a financial penalty of £2.5 million.","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura International PLC.","firms":[7897],"id":2465},{"d":"2009-11-03","di":"2009-11-03","dr":"2009-11-03","k":"Regulatory Action","rg":"State regulator","reg":"State of West Virginia Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":170766.82,"dk":"98-44964","al":"The state of West Virginia has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2466},{"d":"2009-10-01","di":"2009-10-01","dr":"2009-10-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"AWC NO. 20070086601-01","al":"The Financial Industry Regulatory Authority (\"FINRA\") department of market regulation alleged that, during the period from July 1, 2006 through December 31, 2006, Goldman, Sachs & co. (the \"firm\") effected transactions in certain securities with respect to which a trading halt was in effect in alleged violation of NASD rules 2110 and 3340.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered in to a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on October 1, 2009 and on October 23, 2009, the firm paid a monetary penalty in the amount of $10,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2467},{"d":"2009-09-17","di":"2009-09-17","dr":"2009-09-17","k":"Regulatory Action","rg":"State regulator","reg":"Division of Securities Utah Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":247272.91,"dk":"SD-09-0043","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2468},{"d":"2009-09-16","di":"2009-09-16","dr":"2009-09-16","k":"Regulatory Action","rg":"Other","reg":"District of Columbia Department of Insurance and Banking","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":311765.11,"dk":"SB-09-02","al":"The District of Columbia has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2469},{"d":"2009-08-28","di":"2009-08-28","dr":"2009-08-28","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Other","os":"N/a","st":"Final","fine":350000.0,"dk":"2005002169202","al":"NASD rules 2110, 3010(a), 3010(b): the firm, from August 2001, through October 2004, supervisory system and written supervisory procedures were inadequate to detect abusive sales practices regarding variable annuities thereby allowing two representatives to engage in abusive sales practices regarding variable annuities.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2470},{"d":"2009-08-18","di":"2009-08-18","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico Regulation and Licensing Department Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":221609.71,"dk":"09-09-007040","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2471},{"d":"2009-08-12","dr":"2009-08-12","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia State Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1220592.5,"dk":"SEC-20900044 ARS","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2472},{"d":"2009-08-11","di":"2009-08-11","dr":"2009-08-11","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Securities Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2527771.09,"dk":"2008-04-16","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2473},{"d":"2009-08-08","di":"2008-08-07","dr":"2009-08-08","k":"Regulatory Action","rg":"State regulator","reg":"State of South Dakota Department of Revenue & Regulation Division of Securities","san":"Other","os":"Order to show cause","st":"Final","fine":21000.0,"dk":"N/A","al":"On August 11, 2008, wachovia securities received an order to show cause from the state of South Dakota dated August 7, 2008, commencing disciplinary proceedings against the firm based on the state's investigation of two separate customer sales practice complaints.","res":"Consent","sm":"By letter dated 9/1/2010 wfa notified the state that it had completed all of its obligations under the consent order.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2474},{"d":"2009-08-08","di":"2009-08-08","dr":"2009-08-08","k":"Regulatory Action","rg":"State regulator","reg":"State of South Dakota Department of Revenue & Regulation Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Payment of cost of investigation","st":"Final","fine":21000.0,"dk":"CONSENT ORDER","al":"G g y (y p p p ) the State of South Dakota Department of Revenue & Regulation Division of Securities conducted an investigation into the activities of a team of agents who worked together for A.G. Edwards (which was later acquired by wachovia securities, LLC and later by Wells fargo advisors, LLC.) a large percentage of the team's production was from annuity and insurance sales and the division was concerned about the supervision of the team and the suitability of their sales. The firm placed the team on heightened supervision and paid the division a $21,000.00 fine and $20,000.00 to cover the costs of investigation.","res":"Consent","sm":"The State of South Dakota Department of Revenue & Regulation Division of Securities conducted an investigation into the sales activities of a team of agents who worked together for A.G. Edwards (which was later acquired by wachovia securities, LLC and later by Wells fargo advisors, LLC). Approximately 44% of the group's production (above the firm's average for the period of January 1, 2008 to September 30, 2008) was from annuity and insurance sales and the division was concerned about the supervision of the team and the suitability of their sales. Without admitting or denying the findings of fact and conclusions of law contained in the consent order, the firm voluntarily placed the team on heightened supervision for a period of one year from the date of the consent order (or until August 8, 2010); paid the division a $21,000.00 fine; and paid $20,000.00 to cover the costs of investigation. Also the firm now uses an automated tool (annuitynet) with a built in scoring system that routes variable annuity transactions to the appropriate supervisor for review.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2475},{"d":"2009-07-30","di":"2009-07-30","dr":"2009-07-30","k":"Regulatory Action","rg":"Other","reg":"Iowa Insurance Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":191289.03,"dk":"64477","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2476},{"d":"2009-06-29","di":"2009-06-29","dr":"2009-06-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Oregon Division of Finance and Corporate Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":397234.57,"dk":"S-09-0022","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2477},{"d":"2009-06-23","di":"2009-06-23","dr":"2009-06-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Wyoming Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":176314.77,"dk":"09-05","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2478},{"d":"2009-06-22","di":"2009-06-22","dr":"2009-06-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Idaho","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":191049.02,"dk":"2009-7-08","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2479},{"d":"2009-06-18","di":"2007-05-18","dr":"2009-06-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois","san":"Other","st":"Final","fine":50000.0,"dk":"0600669","al":"Failure to supervise deceptive or fraudulent securities transactions. **Amended notice of hearing securities fraud. Allegations added 1/4/2008 - amended notice of hearing securities fraud 1) suzanne wiegand engaged in fraudulent and/or deceptive securities transactions by acting as the salesperson or investment advisor rep for several pension fund accounts for which her father was the trustee and who directed transactions to her account for purposes of generaling commission 2) A.G. Edwards (not know as wachovia securities, LLC) knew or should have known of the above activities and failed to take reasonable supervisory steps to prevent or stop the illegal activities","res":"Order","sm":"Notice of hearing was issued May 18, 2007. Amended notice of hearing was issued October 10, 2007. Second amended notice of hearing was issued January 4, 2008. The hearing is scheduled for April 15, 2008. Contact (217) 785-4947","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2480},{"d":"2009-06-09","di":"2009-06-09","dr":"2009-06-09","k":"Regulatory Action","rg":"State regulator","reg":"State of Kansas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":633090.35,"dk":"09 E 012","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2481},{"d":"2009-06-04","di":"2009-06-04","dr":"2009-06-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Nebraska","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":298818.42,"dk":"N/A","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2482},{"d":"2009-06-02","di":"2008-04-14","dr":"2009-06-02","k":"Regulatory Action","rg":"Other","reg":"Office of the Attorney General of the Sate of New York","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist / offer to repurchase ars from certain eligible retail investors, charities and small businesses who purchased","st":"Final","fine":1952439.67,"dk":"AOD 08-177","al":"Various state regulators, including the state of New York office of the attorney general, conducted an industry-wide, joint investigation into the marketing and sale of auction rate securities.","res":"Consent","sm":"Without admitting or denying the obligations, the firm entered into an aod with the state of New York office of the attorney general on June 2, 2009, in which it agreed, as part of a global settlement with state regulators, to pay a total monetary penalty in the amount of $22.5 million, including $1,952,439.67 to the state of New York, which amount was paid on June 15, 2009.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2483},{"d":"2009-06-01","di":"2009-04-22","dr":"2009-06-01","k":"Regulatory Action","rg":"Other","reg":"London Stock Exchange (Lse)","san":"Other","os":"Lse, a foreign sro, issued a fine of $25,000 GBP","st":"Final","fine":40000.0,"dk":"N/A","al":"Lse alleged that Deutsche bank AG quoted prices on an ETF that were half the value of that last traded. As a result the ETF was suspended and the closing auction delayed.","res":"Settled","sm":"DB London acceptd the fine and has proactively developed and implemented a new quoting system with more sophisticated logic to prevent similar violations.","ab":"Deutsche Bank AG (London)","firms":[300838],"id":2484},{"d":"2009-05-26","di":"2009-05-26","dr":"2009-05-26","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Securities Commission","san":"Other","os":"Consent order","st":"Final","fine":683141.24,"dk":"CO-2009-0011","al":"The commission issued consent order no. CO-2009-0011, cited wachovia securities, LLC with engaging in unethical and dishonest practices and failure to properly supervise its agents. This action stemmed from the firms inappropiate marketing of auction rate securities (ARS) to customers without adequately disclosing risks of illiquidity","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2485},{"d":"2009-05-22","di":"2009-05-22","dr":"2009-05-22","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":449851.41,"dk":"09-003 SI 2008-010","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2486},{"d":"2009-05-19","di":"2009-05-19","dr":"2009-05-19","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":45000.0,"dk":"AWC NO. 20080120582-01","al":"The FINRA department of market regulation alleged that 1) during the period from June 1, 2007 through August 31, 2007, Goldman, Sachs & co. (the \"firm\") reported to the OTC reporting facility certain last sale reports of transactions in OTC equity securities that the firm should not have reported, in alleged violation of NASD rule 6620(g) and 2) during the period from February 1, 2007 through April 24, 2008, the firm improperly double-reported certain last sale reports in national market securities to the NASD/Nasdaq trade reporting facility, in alleged violation of NASD rule 4632(b).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on May 19, 2009 and on June 5, 2009, the firm paid a monetary penalty in the amount of $45,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2487},{"d":"2009-05-14","di":"2009-05-14","dr":"2009-05-14","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Kentucky","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":315300.14,"dk":"NO. 2009-AH-032","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2488},{"d":"2009-05-11","di":"2009-05-11","dr":"2009-05-11","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":387790.88,"dk":"FILE 11200","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2489},{"d":"2009-05-06","di":"2009-05-06","dr":"2009-05-06","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure; complete voluntary purchase of eligible ars from investors in relevant class; make best efforts to provide liquidity to","st":"Final","fine":200000.0,"dk":"2008013056401","al":"The violations set forth in the AWC which Janney entered into without admitting or denying were: 1) failure to adequately disclose the risk of investing in ars, that ars could become illiquid and that customers might be unable to obtain access to funds invested in ars for substantial periods of time; 2) failure to establish and maintain procedures reasonably designed to ensure that ars were marketed and sold in compliance with applicable rules and laws; 3) failure to maintain policies and procedures reasonably designed to ensure accurate descriptions of ars to customers during sales presentations; and 4) failure to provide adequate training to registered representatives regarding ars characteristics.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Prior to the acceptance by FINRA of the AWC, Janney completed its voluntary repurchase of eligible ars, repaid the difference to the single investor it reasonably identified who sold for less than par during the relevant class period. Janney also completed an offer and repurchase to 14 former customers who had purchased within the relevant class period but transferred their position. Janney paid the fine on May 11, 2009.","sm":"Janney entered into the AWC without admitting or denying the allegations. In the AWC FINRA took into account the significant steps Janney had taken to address potential harm sustained by customers as a result of the illiquidity in the ars market that began in February 2008. Additionally Janney began the following actions prior to FINRA investigation: extending cost neutral margin or nonpurpose loans to customers who had liquidity needs. In August 2008 Janney chose to repurchase all customers' ars holdings that were part of nonfunctioning markets ars holdings that were not purchased at Janney as long as they were in a Janney account by August 15, 2008.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2490},{"d":"2009-05-06","di":"2009-05-06","dr":"2009-05-06","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":509628.73,"dk":"09-0082 CO","al":"The state of Indiana has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2491},{"d":"2009-05-01","di":"2009-05-01","dr":"2009-05-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":1400000.0,"dk":"2007010181101","al":"NASD rules 2110 and 3010: respondent wachovia securities, LLC failed to deliver prospectuses and product descriptions to certain customers who purchased investment products, as required under federal securities laws and NASD rules. Wachovia securities failed to have adequate supervisory systems and appropriate written supervisory procedures in place to ensure that offering documents were being sent to customers in connection with securities transactions. Wachovia securities also failed to adequately supervise the submission of information to FINRA staff and ensure that its submissions were accurate, complete and timely submitted.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2492},{"d":"2009-04-22","di":"2009-04-22","dr":"2009-04-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Rhode Island","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":131565.93,"dk":"09-110","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2493},{"d":"2009-04-20","di":"2009-04-20","dr":"2009-04-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Colorado Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":664614.09,"dk":"09-L-11","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2494},{"d":"2009-04-20","di":"2009-04-20","dr":"2009-04-20","k":"Regulatory Action","rg":"Other","reg":"New York Merchantile Exchnge (NYMEX)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"al":"NYMEX alleged that dbag violated rule 9A.36, in that dbag had a second position limit violation within a 12 month period. Dbag was summarily fined in the amount of $5,000.00, and informed that any further violation in accordance with this rule will automatically result in a hearing before the probable cause committee (\"PCC\").","res":"Other","sm":"Without admitting or denying the allegations dbag paid the fine of $5,000.00 general instructions","ab":"Deutsche Bank AG","firms":[300838],"id":2495},{"d":"2009-04-17","di":"2009-04-17","dr":"2009-04-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5673320.82,"dk":"0420-S-2/09","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2496},{"d":"2009-04-14","di":"2009-03-10","dr":"2009-04-14","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange Division of Enforcement","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":160000.0,"dk":"HBD: 09-NYSE-5","al":"FINRA department of enforcement (\"DOE\"), on behalf of NYSE regulation, inc., alleged that between October 2000 and September 2005, Goldman, Sachs & co. (the \"firm\") had deficiencies in its reporting processes and procedures that caused it to inaccurately and/or untimely file certain required reports with the NYSE, including forms 121, forms SS20, NYSE rule 410b reports, daily program trade reports, and NYSE rule 421 short interest reports. Additionally, DOE alleged that from October 2000 until August 2004, the firm failed to provide for appropriate supervisory procedures and control, including a separate system of reasonable follow-up and review, to confirm that the reports were accurately and timely submitted. DOE also alleged that the firm failed to make timely notifications of its participation in public offerings pursuant to NYSE rule 460.30. The alleged reporting violations also resulted in alleged inaccurate books and records in violation of §17 of the Exchange Act, rules 17a­3 and 17a­4 and NYSE rule 440. Additionally, during the time period January 2005 through March 2006, DOE alleged that the firm submitted numerous inaccurate account type indicators to the NYSE's on-line comparison system in violation of NYSE rule 132.30.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm entered into a stipulation of facts and consent to penalty with FINRA department of enforcement on behalf of NYSE regulation, inc., which was approved by the NYSE hearing board on March 20, 2009 and became final on April 14, 2009. On May 14, 2009, the firm paid a monetary penalty in the amount of $160,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2497},{"d":"2009-04-14","di":"2009-04-14","dr":"2009-04-14","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine Department of Professional and Financial Regulation Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":237916.17,"dk":"ADMINISTRATIVE CONSENT ORDER","al":"The state of Maine has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2498},{"d":"2009-04-13","di":"2009-04-13","dr":"2009-04-13","k":"Regulatory Action","rg":"State regulator","reg":"State Commissioner of South Carolina","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":772958.03,"dk":"08018","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2499},{"d":"2009-04-09","dr":"2009-04-09","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Monetary fine.","st":"Final","fine":900000.0,"dk":"2006006509601","al":"FINRA alleged Edward jones violated MSRB rule G-32 by failing to timely deliver official statements to certain customers in various transactions when Edward jones was not an underwriter or member of the syndicate. FINRA alleged Edward jones violated MSRB rules G-8, G-27, and G-17 in regards to certain record keeping requirements.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Edward jones is also required within 60 days of notice of acceptance of this AWC to adopt and implement systems and procedures reasonably designed to ensure compliance with MSRB rules G-32 and G-8, including systems and procedures to provide adequate oversight if third party vendors are utilized, and provide certification by the principal of operations that Edward jones has adopted and implemented supervisory systems and procedures to ensure compliance with MSRB rules G-32 and g- 8.","ab":"Edward D. Jones & Co., L.P.","self":true,"firms":[250],"id":2500},{"d":"2009-04-03","di":"2009-04-03","dr":"2009-04-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Department of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":478286.84,"dk":"09-087","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2501},{"d":"2009-04-01","di":"2009-04-01","dr":"2009-04-01","k":"Regulatory Action","rg":"State regulator","reg":"State of North Dakota Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":121409.18,"al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2502},{"d":"2009-03-31","di":"2009-03-31","dr":"2009-03-31","k":"Regulatory Action","rg":"State regulator","reg":"The Securities Commisioner of the State of Delaware","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":309117.79,"dk":"09-2-2","al":"The state of Delaware has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2503},{"d":"2009-03-27","di":"2009-03-27","dr":"2009-03-27","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan Office of Financial and Insurance Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":653981.26,"al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2504},{"d":"2009-03-24","di":"2009-03-24","dr":"2009-03-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Arizona - Arizona Corporation Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":642280.13,"dk":"S-20655A-09-0071","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2505},{"d":"2009-03-24","di":"2009-03-24","dr":"2009-03-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington Financial Institutions Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":491556.71,"dk":"S08-229-09-CO01","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2506},{"d":"2009-03-20","di":"2008-11-13","dr":"2009-03-20","k":"Regulatory Action","rg":"NYSE","reg":"NYSE Euronext Liffe Administration and Management","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Reprimand","st":"Final","fine":17059.19,"dk":"20080219GSF","al":"Pursuant to settlement proceedings, NYSE euronext LIFFE (\"LIFFE\") market services, London (\"MSL\") alleged that on February 19, 2008, Goldman Sachs international (\"GSI\"), through the agency of an unregistered individual, procured matching business for two client orders which, in each case, were at a price inside the minimum price movement of the sterling futures contract, and which necessitated the execution of two trades in the same strategy at different price levels to achieve the average price, in alleged violation of LIFFE rule 2.2.3.","res":"Settled","sm":"Further to the settlement proceedings, and following the reduction of the fine by one third, it was agreed that gsi be fined £5,666, and make a contribution of £6,000 towards the costs incurred as a result of the disciplinary proceeding, in relation to contravention of general notice no. 2515, in respect of facilitating contingent orders which had the effect of achieving a transaction at an average price inside the minimum price movement of the contract concerned. MSL (I) acknowledged that gsi had apologized for the incident and had co-operated fully with MSL during the course of its preliminary investigation, (II) accepted that neither the sales person nor the responsible person involved had benefitted from the execution of the block trades, and that (III) gsi had taken steps, since the incidents, to ensure that all relevant staff were fully aware of the provisions of general notice 2515.","ab":"Goldman Sachs","firms":[361],"id":2507},{"d":"2009-03-18","di":"2009-03-18","dr":"2009-03-18","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange, LLC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"2007-162 & 2008-06","al":"The International Securities Exchange, LLC (\"ISE\") alleged that, during the third and fourth quarters of 2007, Goldman, Sachs & co. (the \"firm\") sent certain principal acting as agent (\"p/a\") orders through the linkage in which (1) the customer order had already been filled or (2) the p/a order exceeded the customer order size or (3) the execution of the p/a order was not passed along to the customer in alleged violation of ISE rule 400.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\"), which was accepted by ise on March 18, 2009 and on March 27, 2009, the firm paid a monetary penalty in the amount of $10,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2508},{"d":"2009-03-18","di":"2009-03-18","dr":"2009-03-18","k":"Regulatory Action","rg":"State regulator","reg":"State of Vermont Department of Banking, Insurance, Securities and Health Care Administration","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":166923.26,"dk":"09-039-S","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2509},{"d":"2009-03-16","di":"2009-03-16","dr":"2009-03-16","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":3982274.57,"dk":"IC09-CDO-06","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2510},{"d":"2009-03-11","di":"2010-03-11","dr":"2009-03-11","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland - Office of the Attorney General - Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":810624.05,"dk":"2009-0164","al":"The state of Maryland has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2511},{"d":"2009-03-09","di":"2009-03-09","dr":"2009-03-09","k":"Regulatory Action","rg":"State regulator","reg":"State of California - Department of Corporations","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5507824.5,"al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2512},{"d":"2009-03-05","di":"2009-03-05","dr":"2009-03-05","k":"Regulatory Action","rg":"Other","reg":"Office of the Commissioner of Financial Institutions Commonwealth of Puerto Rico","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":103739.22,"dk":"C09-V-001","al":"Alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2513},{"d":"2009-03-03","di":"2009-03-03","dr":"2009-03-03","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":317667.55,"dk":"S-09-0086","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2514},{"d":"2009-02-27","di":"2009-02-27","dr":"2009-02-27","k":"Regulatory Action","rg":"Other","reg":"HCMC - Hellenic Republic Capital Market Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":30783.2,"dk":"37/501/27","al":"Technical breach of shareholder disclosure obligations as required by hellenic republic capital market commission.","res":"Settled","sd":"The issue has now been resolved and a fine agreed but not paid due to the regulator not being able to facilitate payement.","sm":"The issue has now been resolved and a fine agreed but not paid due to the regulator not being able to facilitate payement. This is on the ADV form under a separate entity","ab":"Schroder Investment","firms":[106585],"id":2515},{"d":"2009-02-24","di":"2009-02-24","dr":"2009-02-24","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina Department of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1700203.25,"dk":"09SEC029","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2516},{"d":"2009-02-24","di":"2009-02-24","dr":"2009-02-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Georgia Commissioner of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1076276.28,"dk":"ENSC-1465","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2517},{"d":"2009-02-19","di":"2009-02-19","dr":"2009-02-19","k":"Regulatory Action","rg":"State regulator","reg":"Common Wealth of Massachusetts Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":782321.56,"dk":"E-2008-0053","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2518},{"d":"2009-02-19","di":"2009-02-19","dr":"2009-02-19","k":"Regulatory Action","rg":"State regulator","reg":"State of South Dakota Department of Revenue and Regulation Division of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":155069.08,"dk":"ADMINISTRATIVE CONSENT ORDER","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2519},{"d":"2009-02-17","di":"2009-02-17","dr":"2009-02-17","k":"Regulatory Action","rg":"State regulator","reg":"Montana Securities Department","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":148811.54,"dk":"CASE NO. SEC-2009-5","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2520},{"d":"2009-02-17","di":"2009-02-17","dr":"2009-02-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada Office of the Secretary of State Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":839326.74,"dk":"FILE NO. I09-038","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2521},{"d":"2009-02-17","di":"2009-02-05","dr":"2009-02-17","k":"Civil Judicial Action","san":"Injunction","os":"Undertakings: the settlement, which is subject to court approval, provides, among other things, that: wachovia will offer","st":"Final","al":"SEC litigation release 20885, February 5, 2009: section 15(c) of the Securities Exchange Act of 1934 - the Securities and Exchange Commission announced a settlement with wachovia securities, LLC that will provide more than $7 billion in liquidity to thousands of customers who invested in auction rate securities (ARS) before the market for those securities collapsed. The settlement resolves the SEC's charges that wachovia misled investors regarding the liquidity risks associated with ARS that it underwrote, marketed and sold. The SEC's complaint alleges that wachovia and another firm, whose broker-dealer operations were consolidated into wachovia misrepresented to customers that ARS were safe, highly liquid investments that were comparable to cash or money market instruments. According to the SEC's complaint, wachovia reinforced the perception of liquidity by routinely purchasing ARS from the other firm's customers between auctions, without telling customers that wachovia's willingness to do so depended upon the continued success of the auctions. The SEC's complaint alleges that wachovia became aware of mounting evidence that put the firm on notice that the risk of auction failures had materially increased. Wachovia, nevertheless, continued to market ARS to its customers as highly liquid investments. Wachovia followed the lead of other broker-dealers and decided to stop supporting auctions. Without broker-dealer support, ARS auctions failed and thousands of wachovia's customers were left holding billions of dollars in illiquid ARS, without any practical means of redeeming, selling or deriving value from them.","res":"Judgment Rendered","sd":"SEC judgment civil case 09-CV-743, February 17, 2009: the Securities and Exchange Commission having filed a complaint and defendant wachovia securities, LLC having entered a general appearance; consented to the court's jurisdiction over defendant and the subject matter of this action; consented to entry of this judgment without admitting or denying the allegations of the complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this judgment: it is hereby ordered, adjudged, and decreed that defendant and defendant's agents, servants, employees, attorneys, and all persons in active concert or participation with them who receive actual notice of this judgment by personal service or otherwise are permanently restrained and enjoined from violating, directly or indirectly, section 15(c)(1) of the Securities Exchange Act of 1934; the court shall determine whether it is appropriate to order a civil penalty and, if so, the amount of the civil penalty; the consent is incorporated herein with the same force and effect as if fully set forth herein, and that defendant shall comply with all of the undertakings and agreements set forth therein; this court shall retain jurisdiction of this matter for the purposes of enforcing the terms of this judgment.without admitting or denying the SEC's allegations, wachovia agreed to be permanently enjoined from violations of section 15(c) of the Securities Exchange Act of 1934, the broker-dealer fraud provision, and to comply with a number of undertakings. After wachovia has completed its obligations under the settlement agreement, the SEC will decide whether to seek a financial penalty.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2522},{"d":"2009-02-12","di":"2009-02-12","dr":"2009-02-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150500.0,"dk":"E9A2005013001","al":"Allegations that the firm (1) made recommendations through its registered representatives to customers to purchase class b and class c mutual fund shares where an equal investment in class a shares would have been more advantageous for certain clients in violation of NASD rule 2310 and (2) failed to establish, maintain and enforce supervisory systems and procedures reasonably designed to provide consideration, on a consistent basis, of the benefits of various mutual fund classes as they applied to individual customers.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2523},{"d":"2009-02-12","di":"2009-02-12","dr":"2009-02-12","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4410000.0,"dk":"E9A2005013001","al":"Allegations that the firm (1) made recommendations through its registered representatives to customers to purchase class b and class c mutual fund shares where an equal investment in class a shares would have been more advantageous for certain clients in violation of NASD rule 2310, (2) did not provide certain eligible customers with the benefit of nav transfer programs in connection with mutual fund purchases and sales discounts in connection with purchases of unit investment trusts (\"UIT\") and (3) failed to establish, maintain and enforce supervisory systems and procedures reasonably designed (a) to provide consideration, on a consistent basis, of the benefits of various mutual fund classes as they applied to individual customers, (b) to identify opportunities for investors to purchase mutual funds at nav and (c) to ensure that sales charge discounts were applied to eligible UIT purchases by customers in violation of NASD rules 2110 and 3010.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2524},{"d":"2009-02-04","di":"2009-02-04","dr":"2009-02-04","k":"Regulatory Action","rg":"State regulator","reg":"Attorney General of the State of New York Investor Protection Bureau","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000000.0,"dk":"ASSURANCE NO. 08-179","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2525},{"d":"2008-12-23","di":"2008-12-23","dr":"2008-12-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"AWC NO. 20080121055-01","al":"The FINRA department of market regulation alleged that, during the period from January 1, 2007 through June 30, 2007, Goldman, Sachs & co. (the \"firm\") failed to report the contra-party identifier for certain inter-dealer transactions effected in certain municipal securities to the real-time transaction reporting system (\"RTRS\") in alleged violation of municipal securities rulemaking board (\"MSRB\") rule G-14.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered into a letter of acceptance, waiver and consent (\"AWC\") which was accepted by FINRA on December 23, 2008 and on January 15, 2009, the firm paid a monetary penalty in the amount of $17,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2526},{"d":"2008-12-08","di":"2006-01-01","dr":"2008-12-08","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland","san":"Undertaking","os":"Fine","st":"Final","fine":50000.0,"dk":"2008-0268","al":"In connection with respondent's (and respondent's predecessor's) employment of broker milliet k. Lanham, respondent failed to reasonably supervise within the meaning of section 11-412(a)(10) of the Securities Act.","res":"Stipulation and Consent","sm":"Consent order referred to former broker's handling of certain customer accounts. Some customers were involved in private settlement of claims. One customer, B.L., received restitution pursuant to the terms of the consent order in connection with broker's handling of her account.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2527},{"d":"2008-12-08","di":"2008-12-08","dr":"2008-12-08","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Secretary of State State of Missouri","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2841550.88,"dk":"AP-08-28","al":"The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2528},{"d":"2008-12-01","di":"2008-12-01","dr":"2008-12-01","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":600000.0,"dk":"AWC NO. 20050001219-01","al":"The FINRA department of market regulation and the New York Stock Exchange (\"NYSE\") division of enforcement alleged that, during the period from September 1, 2003 to September 30, 2004, a Goldman, Sachs & co. (the \"firm\") trading desk violated firm guidelines and certain FINRA and NYSE rules in connection with implementing a trading strategy, and that the firm also failed to reasonably supervise certain activities of its trading desk. Specifically, NYSE and FINRA alleged that the firm's trading desk failed to maintain its independence in the conduct of certain over-the-counter stock transactions in which a foreign affiliate was the counterparty. NYSE and FINRA alleged that the activities violated rules relating to trade reporting, short sales, maintenance of proper books and records and supervisory obligations, including NASD marketplace rules 6420(a) & (b), 5430(a) and 6130(d)(6), NASD conduct rules 2110, 3010(a) and (b) and 3110, NYSE rules 342, 410b and 440, as well as sections 10a and 17a of the Securities Exchange Act of 1934 and rules 10A-1(a) & (c) and 17A-3 & 4 thereunder.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, the firm entered jointly into a letter of acceptance, waiver and consent (\"AWC\") with FINRA and a stipulation of facts and consent to penalty with NYSE, and on December 15, 2008, the firm paid a joint monetary penalty in the amount of $600,000, paid as $300,000 to each of FINRA and NYSE.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2529},{"d":"2008-11-21","di":"2007-12-05","dr":"2008-11-21","k":"Regulatory Action","rg":"State regulator","reg":"State of Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"E-2005-0001","al":"A.G. Edwards failed to exercise reasonable supervision over registered representative howard '\"buck mchugh\" and permitted mchugh to cold-call retirees, trade in client accounts without authorization. Mchugh engaged in churning, day trading and free-riding in such accounts. A.G. Edwards failed to formally discipline mchugh, permitting him to switch branches multiple times and not informing subsquent managers of mchugh's prior acts.","res":"Decision","ab":"A. G. Edwards & Sons, Inc.","firms":[19616],"id":2530},{"d":"2008-11-17","di":"2008-10-13","dr":"2008-11-17","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":600000.0,"dk":"HBD NO. 08-45","al":"The Financial Industry Regulatory Authority (\"FINRA\") department of market regulation and the NYSE division of enforcement alleged that, during the period from September 1, 2003 to September 30, 2004, a firm trading desk violated firm guidelines and certain FINRA and NYSE rules in connection with implementing a trading strategy, and that the firm also failed to reasonably supervise certain activities of its trading desk. Specifically, NYSE and FINRA alleged that the firm's trading desk failed to maintain its independence in the conduct of certain over-the-counter stock transactions in which a foreign affiliate was the counterparty. NYSE and FINRA alleged that the activities violated rules relating to trade reporting, short sales, maintenance of proper books and records and supervisory obligations, including NASD marketplace rules 6420(a), 6420(b) and 5430(a), 6130(d)(6), SEC rules 17a­3 and 17a­4 and NASD conduct rules 2110, 3010(a) and (b) and 3110, NYSE rules 342, 410b and 440, as well as §§10(a) and 17(a) of the Securities Exchange Act of 1934 and rules 10A-1 (a) & (c) and 17A-3 & 4 thereunder.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, the firm entered jointly into an AWC with FINRA and a stipulation of facts and consent to penalty with NYSE, and on December 15, 2008, the firm paid a joint monetary penalty in the amount of $600,000, paid as $300,000 to each of FINRA and NYSE.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2531},{"d":"2008-10-30","di":"2008-10-30","dr":"2008-10-30","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":75000.0,"dk":"2007010115401","al":"NASD rules 1021, 1022(a)(1), 1022(a)(5), 2110, 3010: respondent member firm permitted individual to function as a principal without being properly licensed as a general securities principal (\"GP\") and permitted an individual to supervise its equity research analysts without being properly licensed as a research principal (\"RP\"). The firm also failed to ensure that a GP or RP manage and supervise the firm's advisory services group by failing to ensure that individual be properly licensed.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2532},{"d":"2008-10-06","di":"2007-03-28","dr":"2008-10-06","k":"Regulatory Action","rg":"Other","reg":"New Jersey Bureau of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":400000.0,"dk":"2007-010","al":"AG edwards permitted an unregistered person to use branch office facilities to facilitate the referal and transfer of client from previous broker-dealer to AG edwards through his former partner a former AG edwards agent. AG edwards did not supervise nor employ the individual in any capacity and permitted the unregistered person to transact securities through his former partner","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2533},{"d":"2008-09-24","di":"2008-09-24","dr":"2008-09-24","k":"Regulatory Action","rg":"Nasdaq","reg":"The Nasdaq Stock Market LLC (\"Nasdaq\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"20070102251-02","al":"Nasdaq alleged that on July 31, 2007, Goldman, Sachs & co. (\"Goldman Sachs\") entered certain orders into the Nasdaq market center and failed to appropriately indentify whether such orders were buys, short sales or long sales in alleged violation of Nasdaq marketplace rule 4755.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, Goldman Sachs entered into an acceptance, waiver and consent (\"AWC\") which was accepted by Nasdaq and on October 8, 2008, paid a monetary penalty in the amount of $5,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2534},{"d":"2008-09-24","di":"2008-09-24","dr":"2008-09-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":12500.0,"dk":"20070102251-01","al":"FINRA alleged that on July 31, 2007, Goldman, Sachs & co. (\"Goldman Sachs\") 1) inaccurately reported to the trade reporting facility certain \"riskless\" principal transactions in certain designated securities as \"principal\" transactions in alleged violation of NASD marketplace rule 4632(d) and 2) transmitted to the order audit trail system (\"OATS\") certain reports that contained inaccurate or incomplete data in alleged violation of NASD rule 6955.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, Goldman Sachs entered into an acceptance, waiver and consent (\"AWC\") which was accepted by FINRA and on October 9, 2008, paid a monetary penalty in the amount of $12,500.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2535},{"d":"2008-09-24","dr":"2008-09-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":7500.0,"dk":"20070104395-01","al":"The firm was accused of violating NASD rule 6955 in having reported to OATS 58 reports that contained inaccurate, incomplete or improperly formatted data.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm agreed to pay a fine of $7,500 for violations of NASD rule 6955 reporting 58 trades to OATS incorrectly.","sm":"The firm and FINRA settled the matter and the firm neither admitted nor denied the findings","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2536},{"d":"2008-09-24","di":"2006-06-27","dr":"2008-09-24","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":22500.0,"dk":"20060052881-01","al":"FINRA accused the firm of violation of SEC rule 605 reporting 6 trades incorrectly, NASD rule 6955 reporting 11 trades incorrectly to OATS, SEC rule 17A-3 and NASD rule 3110 incorrect time on 4 tickets and NASD rules 2110 and 3010 for not having sufficient WSP's regarding SEC rule 605","res":"Acceptance, Waiver & Consent(AWC)","sd":"$5,000 for 605 violation; $5,000 for 6955 violation; $7,500 for the 17a-s and 3110 violation and $5,000 for the 2110 and 3010 violation.","sm":"The firm and FINRA settled the matter and the firm neither admitted nor denied the findings","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2537},{"d":"2008-09-04","di":"2008-08-06","dr":"2008-09-04","k":"Civil Judicial Action","san":"Injunction","os":"N/a","st":"Final","al":"The SEC filed a complaint which alleged that Prudential Financial, Inc. improperly accounted for certain reinsurance contracts entered into with a single counterparty in the years 1997-2002 relating to the company's property and casualty operations that were sold in 2003. The complaint alleged that this resulted in an overstatment of the company's consolidated results for certain years in reports filed with the SEC,in violation of the financial reporting, books and records and internal control provisions of the Exchange Act.","res":"Consent","sd":"Court permanently enjoined Prudential Financial, Inc.; its offices, agents, servants, employees, attorneys and all persons in active concert or participation with them for violating certain provisions of the Securities Exchange Act of 1933.","ab":"Prudential Financial, Inc.","firms":[11025],"id":2538},{"d":"2008-07-23","di":"2008-06-06","dr":"2008-07-23","k":"Regulatory Action","rg":"Other","reg":"Kentucky","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"2008-AH-226","al":"Non-compliance with heightened supervision of individual registered in the state of Kentucky.","res":"Order","sd":"The voluntary $5000 contribution to the investor protection trust was paid on July 23, 2008.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2539},{"d":"2008-07-23","di":"2008-07-23","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Pending","dk":"2007010115401","al":"On 7/23/08, WSLLC received a Wells letter from FINRA relating to an employee's alleged failure to obtain required licenses in a timely manner in violation of FINRA rules and firm policies.","sm":"This DRP should be combined with occurence 1426665","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2540},{"d":"2008-07-14","di":"2008-07-14","dr":"2008-07-14","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Undertaking","st":"Final","fine":5000.0,"dk":"IC08-CAF-05","al":"The firm through a registered representative and others allowed the client's wife to effect the withdrawals from a customer's account without the required documents as required by A.G. Edwards written procedures.","res":"Order","ab":"A. G. Edwards & Sons, Inc.","firms":[19616],"id":2541},{"d":"2008-06-27","di":"2008-06-27","dr":"2008-06-27","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine in the amount of $300,0000","st":"Final","fine":300000.0,"dk":"NO.2007011877401","al":"Between 2003 and 2004, two former registered securities lending representatives of edwards facilitated improper stock loan transactions with counterparties at artificially low rates, directed or facilited unwarranted payments to finders, and participated in transactions that served no legitmate interest of the firm but benefited counterparties and finders who made payments back to edwards' registered stock loan representatives. The firm lacked supervisory systems and written procedures resonably designed to prevent and detect such activities.","res":"Acceptance, Waiver & Consent(AWC)","ab":"A. G. Edwards & Sons, Inc.","firms":[19616],"id":2542},{"d":"2008-05-08","di":"2006-01-31","dr":"2008-05-08","k":"Regulatory Action","rg":"NYSE","reg":"NYSE","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and undertaking","st":"Final","fine":200000.0,"dk":"06-196","al":"The NYSE alleged that the firm is subject to discipline pursuant to NYSE rule 476(a) for the following reasons: 1) submitted inaccurate trading information through the submission of electronic blue sheets, which led to violation of NYSE rule 401, 2) did not establish and maintain appropriate systems and procedures for the supervision and control of areas responsible for complying with electronic blue sheets reporting requirements and failed to establish a separate system to follow-up and review to ensure compliance with NYSE rules relating to the preparation and submission of electronic blue sheets, 3) made one or more material misstatements to the NYSE in response to one or more requrests for information by the NYSE, 4) did not cooperate with an NYSE investigation satisfactorily.","res":"Decision","sd":"$200,000 fine paid May 8, 2008 after being reduced in the appeal from the original $300,000","sm":"A hearing on this matter was completed in NOV-2006. A verdict was issued April 2007. An appeal was filed and a decision on the appeal received March 2008 reducing the fine and scope of the undertaking. The fine was paid May 8, 2008 and undertaking is in progress.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2543},{"d":"2008-04-18","di":"2008-03-20","dr":"2008-04-18","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\") Division of Enforcement","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"HBD#08-17","al":"The NYSE's division of enforcement alleged that, on certain occasions, Goldman, Sachs & co. (the \"firm\") violated (I) NYSE rule 123(e) and NYSE rule 123(f) by failing to provide certain required data needed to link the entry of orders with reports of execution in the front end systemic capture system; and (II) violated NYSE rule 342 in that the firm failed to implement certain controls, including a system of follow-up and review in order to fully remediate the firm's order management system to meet NYSE technical specifications in a timely manner and thereby prevent the alleged violations of NYSE rule s 123(e) and 123(f).","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a censure and on April 8, 2008, paid a monetary penalty in the amount of $100,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2544},{"d":"2008-04-17","di":"2008-04-17","dr":"2008-04-17","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":55000.0,"dk":"20041000190-01","al":"FINRA alleged that, on certain occasions, Goldman, Sachs & co. (the \"firm\"): (I) failed to report to the Nasdaq market center the correct symbol indicating the order type of certain transactions and to report certain short sale transactions with a short sale modifier in alleged violation of NASD marketplace rule 6130; (II) submitted to the order audit trail system (\"OATS\") certain route or combined order/route reports that the OATS system was unable to link to the corresponding new order submitted by the destination member firm due to data formatting irregularities in alleged violation of NASD marketplace rule 6955 and (III) failed to report to the trade reporting and compliance engine (\"TRACE\") the correct contra party's identifier for certain transactions in TRACE-eligible securities and to report certain transactions to TRACE in a timely manner in alleged violation of NASD marketplace rules 6230 (c)(6) and 2110, respectively.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On April 16, 2008, FINRA accepted a letter of acceptance, waiver and consent (\"AWC\") that was executed by the firm on March 25, 2008. Without admitting or denying the allegations, the firm consented to a censure and on April 28, 2008, paid a monetary penalty in the amount of $55,000","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2545},{"d":"2008-03-27","di":"2008-02-19","dr":"2008-03-27","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\") Division of Enforcement","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":225000.0,"dk":"HBD# 08-08","al":"The NYSE division of enforcement alleged that certain of the firm's traders inadvertently mislabeled certain proprietary orders sent to the NYSE for execution and that certain other proprietary orders by certain firm traders sent to the NYSE for execution were inadvertently mislabeled due to a computer programming problem, thereby not identifying such orders as \"g\" orders, in alleged violation of section 11(a)(1) of the Exchange Act and rule 11A1-1(t) there under and NYSE rules 90 and 410(b). The NYSE enforcement staff also alleged that (I) the firm failed to submit accurate account type indicators for comparison and/or settlement in violation of NYSE rule 132.30 and (II) failed to supervise certain aspects of the proprietary trading activities of employees involved so as to prevent mislabeling of orders in listed equity securities.","res":"Decision","sm":"Without admitting or denying the allegations, the firm consented to a censure and on April 8, 2008, paid a monetary penalty in the amount of $225,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2546},{"d":"2008-02-26","di":"2008-02-26","dr":"2008-02-26","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","st":"Final","fine":7500.0,"dk":"20050001452-03","al":"Without admitting or denying the findings, the firm has entered into an acceptance, waiver and consent with FINRA concerning certain findings regarding compliance with trade reporting and compliance engine (TRACE) rules during the period July 1, 2004 through September 30, 2004. These findings involved failing to report the correct MPID in TRACE-eligible securities. The firm has consented to a fine of $7,500.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2547},{"d":"2008-01-25","di":"2008-01-25","dr":"2008-01-25","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"20050032155-01","al":"Without admitting or denying the findings, the firm has entered into an acceptance, waiver and consent with FINRA concerning certain findings regarding compliance with trade reporting and compliance engine (TRACE) rules during the period July 1, 2005 through September 30, 2005. These findings involved failing to report 1,434 transactions in TRACE-eligible securities within 15 minutes of time of execution, and over-reporting 4,008 transactions that was not required to be reported. The firm has consented to a fine of $5,000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2548},{"d":"2007-12-14","di":"2007-12-04","dr":"2007-12-14","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","st":"Final","fine":13500.0,"dk":"2006003704001","al":"Money Concepts Capital copr. Falied to timely repot five customer-related matters disclosable under NASD conduct rule 3070 and failed to timely amend forms U-4 for six registered representatives to report six disclosable customer matters and one Form U-5 to report a disclosable customer-related matter.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Money concepts was ordered to pay $13,5oo.oo fine to FINRA and censured for late filings of Form U-4 disclosures.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2549},{"d":"2007-12-12","di":"2005-11-06","dr":"2007-12-12","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $20,000","st":"Final","fine":20000.0,"dk":"20050032430-01","al":"During the third quarter of 2005 William Blair & Company (\"the firm\") allegedly violated SEC rule 11AC1-4 by failing to immediately display twenty-two (22)customer limit orders in Nasdaq securities, in its public quotation. During the same time period, the firm allegedly violated NASD marketplace rule 6955(a) by transmitting to OATS, reports concerning seventy (70) orders that contained inaccurate, incomplete, or improperly formatted data.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was notified on December 12, 2007 that the NASD's office of disciplinary affairs and the national adjudicatory council had accepted the acceptance,waiver and consent (AWC) to settle the complaint. Without admitting or denying the allegations contained in the complaint, William Blair & Company agreed to pay the fine of $20,000 to settle the matter (consisting of $10,000 for the limit order display violations and $10,000 for the OATS violations).","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2550},{"d":"2007-11-26","di":"2007-11-26","dr":"2007-11-26","k":"Regulatory Action","rg":"Cboe","reg":"CBOE Futures Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"07-0001","al":"On November 26, 2007, without admitting or denying the allegations, Goldman, Sachs & co., (\"GS\") accepted a stipulation and consent from the CBOE Futures Exchange (\"CFE\"). The CFE alleged that on several trade dates during the period from February 27, 2007 through May 15, 2007, GS reported inaccuracies of cleared vix futures positions to the options clearing corporation as compared with large trader positions in violation of CFE rule 410 and CFTC regulation 1.46. GS consented to a censure and paid a fine of $10,000. The fine was paid on February 28, 2008.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, GS consented to a censure and payment of $10,000 fine that was accepted by the CBOE Futures Exchange on November 26, 2007.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2551},{"d":"2007-10-04","di":"2007-09-07","dr":"2007-10-04","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure, undertaking","st":"Final","fine":375000.0,"dk":"07-117","al":"In connection with an industry-wide settlement relating to prospectus delivery issues, the NYSE alleged that Goldman, Sachs & co. (\"GS\") failed to (I) send product descriptions to certain customers that purchased exchange traded funds in violation of NYSE rules 1100(b) and 342(a) (failure to supervise), and (II) deliver prospectuses in connection with certain customer purchases of asset-backed securities, certain gsam funds, and certain corporate debt and equity securities in violation of NYSE rules 401(a) and 342(a).","res":"Stipulation and Consent","sm":"The matter has been resolved pursuant to an industry-wide settlement. See response to item 12.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2552},{"d":"2007-09-19","di":"2007-09-19","dr":"2007-09-19","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure,cease and desist","st":"Final","fine":500000.0,"dk":"ADMIN PROCEEDING FILE NO. 3-12805","al":"The firm and affiliates were alleged to have entered into an agreement to allow a registered representative to market time in a specific Evergreen fund in excess of trading limits set forth in the funds' prospectus.","res":"Decision & Order of Offer of Settlement","ab":"Evergreen Investment","firms":[19616],"id":2553},{"d":"2007-09-11","di":"2007-09-11","k":"Regulatory Action","rg":"Other","reg":"Financial Supervisory Commission of Korea (\"FSC\")","san":"Censure","os":"Goldman Sachs Asset management korea co., LTD. was issued an institutional warning, required to revise certain internal","st":"Final","al":"The FSC alleged that during the period February 2007 through May 2007 (prior to its acquisition by gsam), mim violated articles 96 and 97 of the indirect investment asset management business act and article 85 of the enforcement decree of the indirect investment asset management business act. The alleged violations arose from certain accounting errors, which were discovered and corrected by mim (including reimbursements to investors and managed funds when warranted), that resulted in the miscalculation of net asset values of certain funds advised by mim.","res":"Stipulation and Consent","sm":"Gsamk amended its internal controls with regard to calculating net asset value and implemented the other requirements of the institutional warning.","ab":"Goldman Sachs Asset","firms":[361],"id":2554},{"d":"2007-08-21","dr":"2007-08-21","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"Administrative warning.no more severe penalty was imposed against defendant, among others, because information was received","st":"Final","dk":"PROCESSO ADMINISTRATIVO SANCIONADOR CVM Nº SP 2005/0155","al":"Accusation of insider trading, based upon suspicion that MR. achÉ, as an equity analyst in JGP S.A., entered into transactions in his own name and in the name of an investment vehicle under JGP's management, based upon privileged information obtained in the ordinary course of its functions as an analyst at JGP. Generally, the defense was based upon the fact that the information has been provided by the target company during business meeting, with no obligation of MR. Ache to confirm the privileged nature of such information.","res":"Decision","sd":"See item 2.","sm":"The action is currently closed in regard to MR. Ache. No information Filed","ab":"Ache, Guilherme, Mexias","firms":[160366],"id":2555},{"d":"2007-08-10","di":"2006-07-27","dr":"2007-08-10","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange Division of Enforcement","san":"Censure","os":"Fine & undertaking","st":"Final","fine":2500000.0,"dk":"HPD#07-107","al":"The NYSE alleged that Janney (1) engaged in away-from-market stock loan transactions; (2) compensated alleged finders in connection with stock loan transactions when those finders had purportedly not performed any services in connection with those transactions; (3) failed to reasonably supervise or control certain of its business activities; (4) failed to provide for appropriate procedures of supervision and control and establish a separate system of follow-up and review to determine that delegated authority and responsibility was being properly exercised; and (5) failed to make and keep accurate records reflecting its stock loan activities.","res":"Stipulation and Consent","sd":"Without admitting or denying guilt, the firm consented to (1) a censure; (2) a fine in the amount of $2,500,000; and (3) an undertaking to requiring the firm to continue to record the telephone conversations of its stock loan department and retain the recordings for a period of no less than one year.","sm":"In resolving this matter, the NYSE considered (1) that the firm immediately and voluntarily undertook numerous remedial efforts, (2) implemented revised and enhanced written supervisory procedures, (3) voluntarily commenced recording all telephone conversations in the stock loan department, (4) the firm's cooperation with NYSE regulation and (5) that no customer accounts were affected by the alleged improper activities in the stock loan department.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2556},{"d":"2007-07-27","di":"2007-07-27","dr":"2007-07-27","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":5000.0,"dk":"20050001285-01","al":"SEC rule 604 of regulation NMS (formerly SEC rule 11AC1-4) respondent member failed from April 1, 2004 to September 30, 2004 to display immediately customer limit orders in Nasdaq securities in its public quotation when each such order was at a price that would have improved the firm's bid or offer in each security; or when the order was priced equal to the firm's bid or offer and the national best bid or offer for each security and the size of the order represented more than a de minimis change in relation to the size associated with the firm's bid or offer in each security.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, Janney Montgomery Scott LLC, consented to the described sanction and to the entry of findings, therefore, the firm is fined $5,000.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2557},{"d":"2007-07-23","di":"2007-07-23","dr":"2007-07-23","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"07-0054","al":"The CBOE alleged that during the period November 2005 through March 2006, SLK-Hull Derivatives LLC (\"SHD\") violated exchange rule 6.13(b)(I)(c)(III) by entering certain hybrid \"m\" orders on the same side of the market in violation of the five (5) second time limitation for submitting orders on behalf of the same market maker or account of the same beneficial owners.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, SHD consented to a stipulation of facts and findings and sanction requiring a censure and $15,000 monetary penalty which was accepted by the CBOE on August 7, 2007. Please note, SHD, CRD number 46735, filed form BDW on March 30, 2007 and was merged with and into Goldman Sachs & Co. (CRD number 361).","ab":"SLK-Hull Derivatives LLC","firms":[361],"id":2558},{"d":"2007-07-11","di":"2007-07-11","dr":"2007-07-11","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":40000.0,"dk":"20050027552-01","al":"NASD alleged that GS violated the following NASD rules: conduct rule 2860(b)(3) by exceeding option contract position limits on four (4) occasions; conduct rule 2860(b)(5) by failing to timely report large option positions with NASD on seven (7) trading days; marketplace rule 5430 for improperly double reporting trades from October 5, 2005 to January 4, 2006; and marketplace rule 6130(b) by failing to accept or decline within twenty minutes 1,812 transactions in the trade reporting facility and the over-the- counter reporting facility from May 1, 2006 through August 31, 2006.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS submitted a letter of acceptance, waiver and consent which was accepted by the NASD on July 11, 2007. Without admitting or denying the allegations, GS agreed to a censure and payment of a $40,000 civil money penalty.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2559},{"d":"2007-06-21","di":"2004-12-13","dr":"2007-06-21","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and remediation to clients","st":"Final","fine":2000000.0,"dk":"AWC# EAF0400840001","al":"For the period January 1, 2001 through December 31, 2004, wachovia securities, LLC consented to, without admitting or denying the findings, violations of NASD rules 3010, 2110 and 2210(d) for failure to supervisor in connection with its fee in lieu of commission accounts (pilot plus accounts) based on low activity, opening accounts below stated minimums and distributing a piece of sales literature that inaccurately stated that pilot plus was a fee based advisory account.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Within 180 days of the acceptance of the AWC, identify all customers entitled to remediation and, within 195 days of acceptance, report to the NASD. Within 315 days of the acceptance of the order, remediate to clients with interest.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2560},{"d":"2007-06-19","di":"2007-06-19","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Securities Commissioner","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Undertaking","st":"Final","fine":75000.0,"dk":"06-556","al":"The North Dakota Securities Commissioner alleged that, from December 2001 to July 2002, two predecessors to wachovia securities, LLC (WSLLC) had failed to supervise a former registered representative in connection with allegedly unsuitable trading in OTC stocks and options in the accounts of several customers.","res":"Consent","sm":"WSLLC agreed to correspond with certain former clients and to address any complaints through its normal dispute resolution process.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2561},{"d":"2007-06-18","di":"2007-05-30","dr":"2007-06-18","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange Division of Enforcement","san":"Censure","os":"Fine of $90,000.","st":"Final","fine":90000.0,"dk":"HBD# 07-90","al":"On June 18 2007, an NYSE hearing officer accepted \"the stipulation of facts and consent to penalty\" entered into between NYSE regulation and wachovia securities LLC , wherein wachovia securities, LLC, without admitting or denying guilt, consented to: (I) ( ) a finding that it violated NYSE rule 345a by permitting registered representatives with inactive registrations due to continuing education requirements to perform duties and functions which required registration and violated NYSE rule 342 by failing to provide for , establish and maintain adequate supervisory procedures and controls, including a system of follow-up and review of business activities relating to compliance with continuing education training requirements by registered representatives; and, (II) the penalty of a censure and a $90,000. Fine. If no review is requested by a member of the NYSE entities identified in NYSE rule 476(g), the decision will become final at the close of business on July 13, 2007.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2562},{"d":"2007-05-02","di":"2007-01-24","dr":"2007-05-02","k":"Regulatory Action","rg":"Other","reg":"New Hampshire","st":"Final","dk":"INV06-041","al":"Failed to comply with NH requirement for a designated principal.","res":"Consent","sd":"Refrain from further violations.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2563},{"d":"2007-04-06","di":"2007-02-12","dr":"2007-04-06","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc., Division of Enforcement","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"HBD# 07-034","al":"Without admitting or denying guilt, the firm has entered into a stipulation of fact and consent to penalty with the New York Stock Exchange division of enforcement concerning certain findings made during the firm's 2004 financial and operational exam. These findings involved overstating excess net capital as of September 30, 2004 and overstating excess customer debits in its customer reserve formula as of September 30, 2004. Additional findings included failing to adequately supervise in connection with the foregoing and inadequate internal controls in connection with the calculation and documentation of its net capital and customer reserve requirements. The firm has consented to a censure and $100,000 fine.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2564},{"d":"2007-03-31","di":"2007-03-31","k":"Regulatory Action","rg":"FINRA","reg":"FINRA","san":"Censure","os":"Fine","st":"Final","fine":24000.0,"dk":"20060042923-01","al":"FINRA accused the firm of violating SEC rule 604 in failing to immediately display 52 customer limit orders, rule 5430 and 2110 for having failed to report 109 orders within 90 seconds and MSRB rule G14 for having not reported 90 municipal securities within 15 minutes","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fined $5,000 for rule 604 violation, $14,000 for the 5430 and 2110 violations and $5,000 for the G-14 violations","sm":"The firm and FINRA settled the cases and the firm neither admitted nor denied the findings.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2565},{"d":"2007-03-20","di":"2007-03-20","dr":"2007-03-20","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fine $5,000","st":"Final","fine":5000.0,"dk":"20060045897-01","al":"NASD rule 606 Northland failed to make publicly available for the 4TH calendar quarter of 2004 through the third calendar quarter of 2005 a complete report on its routing of non-directed orders in covered securiteis during those quarters.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$5,000 fine","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":2566},{"d":"2007-02-26","di":"2007-02-26","dr":"2007-02-26","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"AWC #E8A2003062017","al":"The firm was alleged to have violated NASD rules 2110, 2830(l)(4) in receiving special compensation for shares sold in a particular mutual fund during an IRA promotion that was not available to all who distributed the mutual fund and the arrangement was not properly disclosed in the prospectus or statements of additional information for the mutual funds.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2567},{"d":"2007-02-16","di":"2006-01-17","dr":"2007-02-16","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"84983","al":"CBOE alleged that on October 31, 2006, the firm controlled aggregate long call, short put positions in the spy option class of 344,193 option contracts. After applying the firm's short underlying position of spy shares as a hedge, the firm still exceeded the applicable position limit by 1,839 option contracts in violation of CBOE rule 4.11.","res":"Decision","sm":"The firm declined to contest the violation and under the CBOE's minor rule violation fine system, the firm was assessed a $5,000 summary fine effective February 16, 2007, which the CBOE thereafter debits from the firm's account with the appropriate clearing member. The fine was paid on March 7, 2007.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2568},{"d":"2007-02-15","di":"2005-02-23","dr":"2007-02-15","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $25,000","st":"Final","fine":25000.0,"dk":"20050001403-01","al":"During the first and fourth quarters of 2004, William Blair & Company (\"the firm\") allegedly transmitted to OATS reports that contained inaccurate, incomplete or improperly formatted data and failed to submit required information to OATS regarding one order. On 18 occasions during the fourth quarter of 2004 the firm allegedly failed to comply with the limit order display rule. Further, in the first quarter of 2004 the firm allegedly failed to conduct independent reviews of limit orders to ensure that the automated compliance system was working as intended.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was notified on February 15, 2007 that the NASD's office of disciplinary affairs and the national adjudicatory council had accepted the acceptance, waiver and consent (AWC) to settle the complaint. Without admitting or denying the allegations contained in the complaint, William Blair & Company agreed to pay the fine of $25,000 to settle the matter. The fine was paid on March 9, 2007.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2569},{"d":"2007-01-12","di":"2007-01-12","dr":"2007-01-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Bar","st":"Final","dk":"ADMIN PROCEEDING FILE NO. [33-8761]","al":"Pursuant to Friedman's consent, the SEC order finds that he was a registered representative of registered broker-dealer FBR and either chairman or co-chairman and either the CEO or co-CEO of that firm during his entire tenure there. The order further finds that a final judgment was entered by consent against Friedman enjoining him from violating Securities Act section 5 and, as a controlling person pursuant to Exchange Act section 20(a), from violating Exchange Act sections 10(b) and 15(f) and rule 10B-5 in the civil action SEC v. Friedman, billlings, ramsey & co., inc., et al., civil action no. 06-CV-02160 (D.D.C.). The order also finds that: the SEC's complaint alleged that in September/October 2001, Friedman, with others, directed or controlled the day-to-day management of FBR; in connection with a pipe offering by compudyne corp., FBR failed to establish, maintain, and enforce policies and procedures reasonably designed to prevent the misuse of material, non-public information, and it improperly traded compudyne stock in its market-making account while aware of material, non-public information concerning the pipe offering; Friedman, as a controlling person, is liable for the foregoing FBR conduct; and Friedman engaged in unregistered sales of compudyne securities.","res":"Settled","sd":"Friedman was barred from associating in a supervisory capacity with any broker or dealer, with the right to reapply for such association after two years to the appropriate self regulatory organization, or if there is none, to the commission. Such right to reapply became available to Friedman on January 12, 2009.","sm":"On November 17, 2006, Friedman submitted an offer of settlement to the SEC, which was accepted by the SEC on December 19, 2006. In the offer of settlement, solely for the purpose of the proceedings and any other proceedings brought by or on behalf of the commission or in which the commission is a party and without admitting or denying the findings contained in the order, except as to the entry of the final judgment, Friedman admitted to the jurisdiction of the commission and consented to the entry of an order by the commission containing the findings described in item 7, above. Friedman also consented to the imposition of the bar described in item 12, above.","ab":"Friedman, Emanuel, Joshua","firms":[138854],"id":2570},{"d":"2007-01-09","di":"2006-12-07","dr":"2007-01-09","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":5000.0,"dk":"2005003069501","al":"NASD alleged that the firm did not continuously maintain two-sided quotations in the absence of the grant of an excused withdrawal or a functional excused withdrawal by the sro during the periods of July 1 through September 30, 2005 and from April 1 through June 30, 2006. During the above-mentioned periods, the firm was registered with NASD as an intermarket trading system/computer assisted execution system (\"its/caes\") market maker.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the allegations, the firm consented and agreed to pay an AWC amount of $5,000.","sm":"Please note that Nasdaq automatically removes market maker quotes whenever there are any corporate actions (I.E. payment of dividends), and when this happens market makers are considered to be in an excused state if no new quotes are posted. During the period of July 1 through September 30, 2005, the Nasdaq system removed the firm's quotes because of dividends being paid by the ETF's the firm made markets in. Since the firm never updated its quotes in the ETF's in question, the firm was excused and withdrawn as a market maker in these securities thus eliminating the need to post two-sided quotes.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2571},{"d":"2007-01-09","di":"2007-01-09","dr":"2007-01-09","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":35000.0,"dk":"2005000251801","al":"In the result of the 2004 and 2005 trading and market marking surveillance examinations, NASD alleged that the firm is in violation of marketplace rules 4632 and 6130, NASD rule 3110, SEC rule 200(g), ineffective supervisory procedures, and OATS violations.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented and agreed to pay an AWC amount of $35,000.00.","sm":"Please note that the firm has conducted an internal investigation in regards to the matter. The firm is evaluating the adoption of new information systems for proprietary trading operations. In addition, the firm has amended its written supervisory procedures, specifically in the areas of multiple mpids, best execution, trade reporting, and other regulatory obligations.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2572},{"d":"2007-01-03","di":"2006-12-22","dr":"2007-01-03","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":85000.0,"dk":"E1020050169-01","al":"NASD alleged that from June 14, 2004 through April 24, 2005, GS failed to report or incorrectly reported certain of the firm's inter-dealer transactions in pars to the MSRB in violation of MSRB rule G-14; that GS failed to submit to a registered clearing agency information and/or instructions required to allow for automated comparison of certain of the firm's inter-dealer transactions in violation of MSRB G-12(f)(I); and that the firm's supervisory system and procedures were not reasonably designed to ensure compliance with MSRB rules G-14 and G-12(f)(I) in connection with reporting inter-dealer pars transactions, in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS submitted a letter of acceptance, waiver and consent which was accepted by the NASD on January 3, 2007. Without admitting or denying the allegations, GS agreed to a censure and payment of $85,000 civil money penalty, and made the required undertakings.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2573},{"d":"2006-12-22","di":"2006-12-20","dr":"2006-12-22","k":"Civil Judicial Action","san":"Injunction","os":"Other sanctions have been imposed in related SEC administrative and NASD proceedings, each of which is described on a","st":"Final","fine":754046.0,"al":"The Securities and Exchange Commission (\"SEC\") alleged in its complaint that MR. Friedman, while he was serving as co-chairman and co-chief executive officer of Friedman, billings, ramsey & co., inc. (\"FBR\"), made unregistered sales of securities in 2001 in violation of section 5 of the Securities Act of 1933 and is liable as a controlling person, pursuant to section 20(a) of the Securities Exchange Act of 1934, for violations by FBR in 2001 of Exchange Act sections 10(b) and 15(f) and rule 10B-5 thereunder.","res":"Consent","sd":"Without admitting or denying the allegations in the complaint, MR. Friedman consented to the entry of a final judgment (I) permanently enjoining him from violating section 5 of the Securities Act and, as a controlling person, from violating sections 10(b) and 15(f) of the Exchange Act and rule 10B-5 thereunder and (II) ordering him to pay civil money penalties of $754,046 by check, which was delivered to the commission's office of financial management on January 4, 2007.","ab":"Friedman, Emanuel, Joshua","firms":[138854],"id":2574},{"d":"2006-12-21","di":"2006-10-12","dr":"2006-12-21","k":"Regulatory Action","rg":"State regulator","reg":"The State of Rhode Island","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10250.0,"al":"It was alleged there was a violation of section 203 of riusa in Janney Montgomery Scott LLC employment of one individual as an investment advisor representative who serviced one Rhode Island account January 2006 without effective licensing.","res":"Consent","sd":"The fine was paid on December 4, 2006","sm":"Due to an administrative error a violation of section 203 of riusa occurred when Janney Montgomery Scott LLC permitted one investment advisor representative to service one Rhode Island account in January 2006 without effective licensing.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2575},{"d":"2006-12-21","di":"2006-12-11","dr":"2006-12-21","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"$10,000 fine","st":"Final","fine":10000.0,"dk":"E0420050078-01","al":"Northland transferred investor funds for private placement offerings to an escrow account under the control of affilated company Northland trust services. Northland released investor funds prior to contingency being met with bona fide investors, as directors or officers participated in offering and this disclosure was not included in the PPM","res":"Acceptance, Waiver & Consent(AWC)","sd":"$10,000 paid in full on 1/7/2007","ab":"Northland Securities, Inc.","self":true,"firms":[40258],"id":2576},{"d":"2006-12-20","di":"2006-07-25","dr":"2006-12-20","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":32500.0,"dk":"2004100023501","al":"From January 1, 2005 through April 30, 2005, the firm did not accept or decline in the Nasdaq market center (\"NMC\"), within twenty minutes after execution transactions in eligible securities, a violation of NASD marketplace rule 6130(b). Furthermore, the firm did not transmit last sale reports of OTC equity securities within 90 seconds after execution nor designate such reports as late during the same period. In addition, the short interest report on one stock was reported incorrectly in April 2004. The firm's supervisory systems and written procedures were ineffective to achieve complete compliance with the short interest reporting requirements.","res":"Decision & Order of Offer of Settlement","sd":"Without admitting or denying the allegations, the firm consented and agreed to pay an AWC amount of $32,500.","sm":"With respect to violation of NASD rule 6130(b), please note that the firm is not responsible for technical issue caused by an outside vendor on its system. Upon discovery of the issue, the firm took immediate action with the outside vendor and has since then corrected the issue.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2577},{"d":"2006-12-19","di":"2006-12-19","dr":"2006-12-19","k":"Regulatory Action","rg":"Other","reg":"National Assocation of Securites Dealers","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Suspension of association with any NASD member in a supervisory capacity for two years.","st":"Final","fine":500000.0,"dk":"20050002450-04AWC","al":"MR. Friedman accepted and consented, without admitting or denying the findings, to the entry of findings by the national association of securities dealers (\"NASD\") that MR. Friedman, while he was serving as co-chairman and co-chief executive officer of Friedman, billings, ramsey & co. inc., (\"FBR\"), violated NASD rule 2110 and is liable as a controlling person, pursuant to section 20(a) of the Securities Exchange Act of 1934, for violations by FBR in 2001 of Exchange Act sections 10(b) and 15(f) and rule 10B-5 thereunder.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Friedman was suspended from associating with any NASD member in a supervisory capacity for two years. Friedman was fined $500,000, which was payable to NASD, and he was required to pay a civil penalty of $754,046 in accordance with the terms of the final judgment entered in SEC v. Friedman, billings, ramsey & co., inc., et al. The fine was paid on December 29, 2006, and the civil penalty on January 4, 2007.","sm":"On December 14, 2006, Friedman submitted the executed AWC to counsel in NASD's market regulation department, which was accepted by NASD on December 19, 2006. In the AWC, solely for the purpose of the proceeding and any other proceeding brought by or on behalf of NASD or to which NASD is a party and without admitting or denying the findings contained in the AWC, Friedman consented to the findings described in item 7, above. As a result of the findings, Friedman consented to the imposition of the sanctions described in item 12, above.","ab":"Friedman, Emanuel, Joshua","firms":[138854],"id":2578},{"d":"2006-12-18","di":"2006-12-18","dr":"2006-12-18","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Monetary fine","st":"Final","fine":50000.0,"dk":"AWC NO. 2005001720503","al":"Due to the misconduct of a registered representative, the firm was alleged to have violated NASD conduct rules 2110 and 3010 in regards to the supervision of certain activities of this registered representative.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2579},{"d":"2006-12-14","di":"2006-12-14","dr":"2006-12-14","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":150000.0,"dk":"E0220040229-01","al":"The NASD alleged that the firm effected late trading in mutual funds after market close. Despite the time when the orders were received, the orders were executed and priced at the net asset value as of the close of trading on the same day they were received by the firm. Also, the NASD alleged that the firm's supervisory systems and written procedures were ineffective to prevent late mutual fund trading, and that the firm did not keep sufficient records that reflected the time of receipt of orders to purchase or sell mutual funds.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the findings, the firm consented and agreed to pay an AWC amount of $150,000. And is required to review and update supervisory procedures regarding late trading and record keeping.","sm":"The firm has strengthened its supervisory procedures and record-keeping requirements for mutual fund.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2580},{"d":"2006-10-09","di":"2006-08-25","dr":"2006-10-09","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Division of Enforcement","st":"Final","fine":300000.0,"dk":"HDB# 06-172","al":"In NYSE hearing board decision 06-172 the hearing officer approved the stipulation and consent to penalty wherein wachovia securities, without admitting or denying guilt consented to finding: a finding by the hearing panel that wachovia violated NYSE rule 342(a) and (b) by failing to provide for, establish and maintain adequate procedures and controls for certain activities at its bank affiliate which affect command asset program accounts, including a system of follow-up and review of its business activities relating to changes of customer address.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2581},{"d":"2006-09-15","di":"2006-09-15","dr":"2006-09-15","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":6500.0,"dk":"20050017975-01","al":"NASD alleged that from January 1 through April 30, 2005, GS violated NASD rule 2110 by failing to timely transmit through Nasdaq national market center last sale reports of certain transactions in CQS securities.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS submitted a letter of acceptance, waiver and consent which was accepted by the NASD on September 15, 2006. Without admitting or denying the allegations, GS agreed to a censure and payment of a $6,500 civil monetary fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2582},{"d":"2006-09-08","di":"2006-09-08","dr":"2006-09-08","k":"Regulatory Action","rg":"Other","reg":"Securities Exchange Board of India (\"Sebi\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":216450.22,"dk":"AP/AO-16/2006-07","al":"Sebi found that Goldman Sachs investments (MAURITIUS) I LTD. (\"GSIML\") violated sebi circular dated aug. 8, 2003, read with regulation 20 of fii regulations, by submitting a false declaration to sebi with respect to the issuance of the off-shore derivative instruments to an overseas corporate body and violated regulation 13(1) of fii regulations by issuing such off-shore derivative instruments to an overseas corporate body.","res":"Order","sm":"In compliance with the adjudication order no. ap/AO-16/2006-07, on October 17, 2006, gsiml submitted a penalty payment to sebi in the amount of RS. 10,000,000, or approximately $216,450.22 based on the exchange rate on the resolution date.","ab":"Goldman Sachs","firms":[361],"id":2583},{"d":"2006-08-26","di":"2006-07-06","dr":"2006-08-26","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc., Division of Enforcement","san":"Censure","st":"Final","fine":2250000.0,"dk":"HBD#06-151","al":"The firm, along with First Clearing, LLC (\"FC) and wachovia capital markets, LLC (\"WCM\"), is alleged to have violated section 17(a) of the Securities Exchange Act and rule 17A-4 thereunder, along with NYSE rules 440, 342 and 342.17, by failing to preserve electronic records relating to the business of the firm for at least three years and by failing to reasonably supervise the retention and/or review of electronic communications.","res":"Stipulation and Consent","ab":"First Clearing, LLC","firms":[19616],"id":2584},{"d":"2006-08-21","di":"2006-07-20","dr":"2006-08-21","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board Options Exchange (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"84081","al":"CBOE alleged that on July 18, 2006, the firm controlled aggregate long call, short put positions in the MVR option class of 36,190 option contracts, which exceeded the applicable position limit by 4,690 option contracts in violation of CBOE rule 4.11.","res":"Decision","sm":"The firm declined to contest the violation and under the CBOE's minor rule violation fine system the firm was assessed a $5,000 summary fine effective August 21, 2006, which the CBOE thereafter debits from the firm's account with the appropriate clearing member. The fine was paid on September 8, 2006.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2585},{"d":"2006-08-17","di":"1996-10-04","dr":"2006-08-17","k":"Civil Judicial Action","san":"Disgorgement","st":"Final","al":"The county sought to recover damages arising from conduct of a former first fidelity bank employee who entered into a kickback scheme with the treasurer of essex county in 1987 to steer business to first fidelity, which served as underwriter for three bond issues done by the county in 1987 and 1989.","res":"Settled","sd":"See item 14.","ab":"Wachovia Bank, N.A.; Wachovia Bank,N.A. (Non-","firms":[11025,19616],"id":2586},{"d":"2006-08-07","di":"2006-08-02","dr":"2006-08-07","k":"Regulatory Action","rg":"State regulator","reg":"Secretary of State Nevada.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"CIO6-091-DB","al":"Unlicensed investment representative","res":"Acceptance, Waiver & Consent(AWC)","sd":"A letter of caution was given to US as well as a $7000.00 fine. 8/2/06","sm":"MR. abulencia is the only iar we have licensed in the state of Nevada. We where unaware of the states branch requirements since he did not have or solicit clients while located at this branch. MR. abulencia moved from the state of calafornia where all of his advisory clients reside to the state of Nevada. The lack of registration in the state of Nevada was merely due to the misunderstanding of the iar requirements.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2587},{"d":"2006-08-03","di":"2006-08-03","dr":"2006-08-03","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"E0220040072-04","al":"Firm was fined $5000 for net capital violation from 7/22/04-7/29/04. Ref. Section 15(c)of securities and Exchange Act of 1934(SEC rule)and NASD conduct rule 2110.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Firm was fined $5000 for net capital violation from 7/22/04-7/29/04. Total fine was paid on 07/17/2006.","ab":"Syndicated Capital, Inc.","self":true,"firms":[29037],"id":2588},{"d":"2006-07-28","di":"2006-06-27","dr":"2006-07-28","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure undertaking","st":"Final","fine":50000.0,"dk":"2005002574201","al":"NASD alleged that, during the period from June 1, 2004 through June 30, 2005, GS executed certain trades in municipal securities below the minimum denomination (and, in some of those trades, did not provide the customers with written disclosure that they were buying securities below the minimum denomination) in violation of MSRB rule G-15(f); and that the firm's supervisory systems and procedures were not reasonably designed to ensure compliance with the minimum denomination restrictions of rule G-15(f) in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS submitted a letter of acceptance, waiver and consent which was accepted by the NASD on July 28, 2006. Without admitting or denying the allegations, GS agreed to a censure and payment of a $50,000 civil money penalty.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2589},{"d":"2006-07-20","di":"2006-07-20","dr":"2006-07-20","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20050023340-01","al":"NASD alleged that (I) on August 3 & 4, 2005, GS violated SEC rule 200(g) and NASD marketplace rule 6130 by failing to properly mark order tickets in connection with several proprietary short sales, and (II) GS transmitted to OATS certain reports that contained inaccurate, incomplete, or improperly formatted data in violation of NASD marketplace rule 6955.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS submitted a letter of acceptance, waiver and consent which was accepted by the NASD on July 20, 2006. Without admitting or denying the allegations, GS agreed to a censure and payment of a $20,000 civil money penalty.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2590},{"d":"2006-06-30","dr":"2006-06-30","k":"Regulatory Action","rg":"Other","reg":"Market Regulation Services Inc. (Canada)","san":"Other","os":"Regulatory fines","st":"Final","fine":525000.0,"dk":"NO 2006-006","al":"In the period February 2003 to February 2005, Raymond James LTD contravened RS inc universal market integrity rules (\"UMIR\") relating to client priority, failure to record client consentorder makingand audit trail on numerous occasions. In the period July 2003 to February 2005, Raymond James Ltd. failed to comply with its trading supervision obligations under UMIR 7.1 (1) and policy 7.1","res":"Settled","sd":"Fine of $400,000.00 payable by Raymond James LTD to market regulation services inc. (\"RS\") costs of $125,000.00 payable to RS total fine and costs $525,000.00 as indicated above","sm":"The displinary notice has been settled and no further action taken as stated above. Total fine plus costs of $525,000.00 No information Filed","ab":"Raymond James Ltd.","firms":[25853],"id":2591},{"d":"2006-05-31","di":"2006-05-31","dr":"2006-05-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure/civil penalty/undertaking","st":"Final","fine":1500000.0,"dk":"3-12310","al":"SEC alleged that fourteen investment banking firms, including GS, violated section 17(a)(2) of the Securities Act of 1933, by engaging in one or more practices relating to auctions of auction rate securities during the period from January 1, 2003 through June 30, 2004 as described in the cease-and-desist order entered by the SEC.","res":"Decision & Order of Offer of Settlement","sm":"As part of a multi-firm settlement, GS submitted an offer of settlement which was accepted by the SEC on May 31, 2006. Without admitting or denying the allegations, GS consented to a censure and cease-and-desist order and payment of $1,500,000 civil money penalty.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2592},{"d":"2006-05-11","di":"2006-03-29","dr":"2006-05-11","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"20041000178-01","al":"NASD alleged that from November 1, 2003 through January 15, 2004, with respect to certain short sale orders in a common stock, Goldman, Sachs & co. (\"GS&co.\") failed to make and/or annotate an affirmative determination that it would receive delivery of the security on behalf of the customer or that it could borrow the security on behalf of the customer for delivery by settlement date, and with respect to certain short sales in the common stock effected for the firm's proprietary account(s), GS&co. failed to make and/or annotate an affirmative determination that the firm could borrow the security or otherwise provide for delivery by settlement date in violation of NASD conduct rule 3370; with respect to certain short sale transactions in the stock, GS& co. failed to report each transaction to Nasdaq market center with a short sale modifier, and incorrectly reported certain short sale transactions in the stock to the Nasdaq market center as short sale exempt in violation of NASD market place rule 6130(d)(6).","res":"Acceptance, Waiver & Consent(AWC)","sm":"On March 29, 2006, without admitting or denying the allegations, GS&co. consented to a censure and a $20,000 fine. The letter of acceptance, waiver and consent was accepted by NASD on May 11, 2006.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2593},{"d":"2006-05-09","di":"2006-04-12","dr":"2006-05-09","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":50000.0,"dk":"E112005000901","al":"SEC rule 17A-4 requires that brokerage firms maintain and preserve, for a period of not less than three years, electroic communications relating to the firm's business as a broker-dealer. In notice to members 01-80 amd 03-33, NASD communicated to members their recordkeeping and supervisory obligations with respect to electronic communications, including e-mial and instant messaging. From December 2003 through April 2005, Raymond james LTD. stored electronic communications on various computer servers. Electronic communications stored on certain of those servers, however, are no longer retrievable. As a result, the firm did not maintain and preserve all electronic communications as required by SEC rule 17A-4. This conduct constitues separate and distinct violations of SEC rule 17A-4 and NASD conduct rules 3110 and 2110.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was censured and fined $50000.00. Firm is awaiting payment arrangements or payment details form the NASD finance department. The firm signed the letter of acceptance, waiver and consent, on April 27TH, 2006 and accepted by NASD May 9TH, 2006. Payment for $50,000 US was submitted by cheque on May 12, 2006.","ab":"Raymond James (USA) Ltd","self":true,"firms":[25853],"id":2594},{"d":"2006-03-16","dr":"2006-03-16","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","st":"Final","fine":27500.0,"dk":"20042000086-02","al":"NASD rules 2110, 2320, 5430(a), 5430(a)- the firm failed to transmit through act last sale reports of transactions within 90 seconds after execution; and in 23 occasions for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price was as favorable as possible under prevailing market conditions.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the allegations, the firm consented and agreed to pay an AWC amount of $27,500 ($20,000 for trade reporting and $7,500 for not obtaining the most favorable price possible under prevailing market conditions)and restitution to clients of $742.22 plus interest.","sm":"Of the 23 transactions that did not receive the most favorable price possible under prevailing market conditions, the average restitution was less than $35.00.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2595},{"d":"2006-02-20","di":"2006-02-20","dr":"2006-02-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida, Office of Financial Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist and restitution","st":"Final","fine":50000.0,"dk":"0221-S7/05","al":"The office of financial regulation alleged that the firm's supervisory system was inadequate with respect to the supervision of recommendations by its associated persons that clients switch from one mutual fund to another in Florida. As noted in the stipulation and consent, since the office's examination, the firm revised it supervisory system and implemented a new computerized supervisory and surveillance system.","res":"Stipulation and Consent","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2596},{"d":"2006-01-18","di":"2006-01-18","dr":"2006-01-18","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"al":"The firm was alleged to have violated exchange rule 123c, in failing to adhere to the order entry and cancellation procedures for market-on-close (MOC) and limit-on-close (LOC) orders.","res":"Other","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2597},{"d":"2006-01-03","di":"2006-01-03","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":130000.0,"dk":"05-MSR-24","al":"On January 3, 2006, CBOT alleged that Goldman, Sachs & co. (\"GS\") executed certain exchange for physical (\"EFP\") transactions in alleged violation of CBOT regulation 444.01 governing transfer trades and executed certain EFP transactions for the purpose of offsetting existing positions in the delivery month or within two business days prior to first delivery day where no change of ownership was involved and where the date of execution of the position being transferred was not the same as the transfer date in alleged violation of CBOT regulation 444.03.","res":"Settled","sm":"GS submitted an offer of settlement to the CBOT, which was accepted. Without admitting or denying the allegations, GS consented to pay a $130,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2598},{"d":"2006-01-03","di":"2003-09-01","dr":"2006-01-03","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":150000.0,"dk":"HPD 05-145","al":"NYSE alleged as part of an industry-wide settlement that, prior to 2003, Goldman, Sachs & co. (\"GS\") failed to maintain adequate written supervisory procedures relating to its blue sheet submissions, failed to establish a follow up system to confirm information contained in its blue sheet submissions, and submitted inaccurate information in its blue sheet submissions in violation of NYSE rules 410a, 401, 342 and 342.33.","res":"Decision","sm":"On January 3, 2006, without admitting or denying the allegations, GS participated in the industry-wide settlement, consenting to a censure, and a $150,000 fine, and agreed to conduct a validation of all required blue sheet data elements in accordance with isg regulatory memorandum, isg 2005-01 and to notify the NYSE when the validation is complete in writing.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2599},{"d":"2005-12-27","dr":"2005-12-27","k":"Regulatory Action","rg":"Other","reg":"Financial Services Agency (\"FSA\")","san":"Other","os":"Revisions of controls.","st":"Final","dk":"3573","al":"In December of 2005, the regulator for the asset management industry in Japan (the \"financial services agency\" or \"FSA\") issued an improvement order to Goldman Sachs Asset management co., LTD. (\"GSAMC\"), a participating investment advisory affiliate of Goldman Sachs Asset management (\"GSAM\"), in connection with certain issues identified during a regular examination of GSAMC's operations. Three main issues led to the issuance of the improvement order: (I) a post-trade reallocaiton of cerain securities between discretionary client accounts; (II) a situation involving cross trades between public offering and private placement funds; and (III) a situation involving the offering of japanese public mutual funds prior to the filing of registration statements. These situations resulted in technical violations of certain japanese regulatory requirements.","res":"Order","sm":"Gsamc has since revised its controls in these areas. The improvement order did not provide for any fines or suspensions of gsamc or its employees, and it is not anitcipated that the improvement order will materially affect gsamc's ability to provide investment management services to its clients.","ab":"Goldman Sachs Asset","firms":[361],"id":2600},{"d":"2005-11-23","di":"2005-10-12","dr":"2005-11-23","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":7500.0,"dk":"2005000060601","al":"NASD alleged that, for the period of January 1, 2004 through April 30, 2004, Goldman Sachs & Co. (\"GS\") failed to transmit through act 100 last sale reports of transactions in portal equity securities, by 6:30 PM est on the day of execution, in violation of NASD portal market rule 5322(a)(2).","res":"Acceptance, Waiver & Consent(AWC)","sm":"On October 12, 2005, without admitting or denying the allegations or findings, GS consented to a censure and $7,500 fine. The letter of acceptance, waiver and consent was accepted by NASD on November 23, 2005.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2601},{"d":"2005-10-13","di":"2005-08-26","dr":"2005-10-13","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":15000.0,"dk":"20050002343-01","al":"NASD alleged that, in connection with certain short transactions on or about August 23 and 24, 2004, Goldman, Sachs & co. (\"GS\"): (1) failed to annotate an affirmative determination that the relevant securities could be borrowed or otherwise provided for delivery of the securities by settlement date, (2) failed to report certain short sales to the Nasdaq market center with a short sale modifier, and (3) failed to maintain an adequate supervisory system, in violation of NASD conduct rule 3370, NASD marketplace rule 6130, and NASD conduct rules 2110 and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On August 26, 2005, without admitting or denying the allegations or findings, GS consented to a censure and to pay a $15,000 total fine. The letter of acceptance, waiver and consent was accepted by NASD on October 13, 2005.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2602},{"d":"2005-09-07","di":"2005-09-25","dr":"2005-09-07","k":"Regulatory Action","rg":"CFTC","reg":"CFTC","san":"Other","os":"Damages","st":"Final","fine":28600.0,"dk":"CFTC DOCKET NO. 02-R078","al":"Scott SEVERANCE (\"SEVERANCE\") alleged in an action before the CFTC that he was fraudulently induced to open an account with First Options of Chicago, inc. (\"FOC\") by an FOC employee and a floor broker, and that FOC and the floor broker allegedly engaged in unauthorized trading in the account in connection with its liquidation, in violation of CFTC regulation 166.2, commodities Exchange Act sections 4b and 2(a)(1)(b), and CFTC rule 1.33(b)(1).","res":"Order","sm":"On September 25, 2002, severance filed a complaint with the CFTC. The CFTC administrative law judge (\"ALJ\") imposed joint and several liability for money damages against foc, its employee, and the floor broker, finding among other things that foc had violated commodities Exchange Act sections 4b, 4o(1)(a) and (b), CFTC regulation 166.2 and 166.3, CFTC rule 1.33(b)(1) and was vicariously liable pursuant to section 2(a)(1)(b). On appeal the CFTC upheld the ALJ's decision against foc and the floor broker, but dismissed the complaint as to the foc employee. On September 27, 2005, foc paid the money damages to severance in the amount of $28,600.","ab":"First Options of Chicago,","firms":[361],"id":2603},{"d":"2005-08-30","di":"2005-08-30","k":"Regulatory Action","rg":"State regulator","reg":"West Virginia Office of the State Auditor Securities Commission.","san":"Other","os":"Seeks cease and desist","st":"Pending","dk":"ORDER NO. 05-1318","al":"Allegedly, aim and adi failed to disclose that they had entered into certain arrangements permitting market timing of such funds, thereby breaching their fiduciary duties to the funds.","sm":"On August 30, 2005, the West Virginia office of the state auditor - securities commission (\"WVASC\") issued a summary order to cease and desist and notice of right to hearing to aim and adi (order no. 05-1318). The WVASC alleges that aim and adi failed to disclose market timing arragements. The WVASC purports to order aim and adi to cease any further violations and seeks to impose monetary sanctions, including restitution to affected investors, disgorgement of fees, reimbursement of investigatory, administrative and legal costs and an \"administrative assessment\" to be determined by the commissioner. We believe this matter has been indefinitely suspended.","ab":"Aim Advisors, Inc.","firms":[107584,141854],"id":2604},{"d":"2005-07-21","di":"2005-07-21","dr":"2005-07-21","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":1200000.0,"dk":"EAF0300920002","al":"The NASD alleged that Janney engaged in conduct which permitted two hedge fund clients to engage in market-timing. The NASD also alleged that Janney failed to appropriately respond to market timing that was occurring and failed to establish and maintain systems and procedures reasonably designed to prevent and detect market timing and late trading. Further, the NASD alleged that Janney, from May 2, 2003 through September 18, 2003, failed to create records reflecting the time of receipt of mutual fund orders. Finally, the NASD alleged that Janney failed to establish and maintain systems and procedures reasonably designed to ensure that it conducted adequate due diligence for its responses to regulatory inquiries.","res":"Acceptance, Waiver & Consent(AWC)","sd":"Without admitting or denying the allegations described in paragraph 7 above Janney consented to the issuance of an NASD AWC imposing a censure, a fine of $1,200,000, and restitution in the amount of $998,285.81.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2605},{"d":"2005-07-19","di":"2005-06-15","dr":"2005-07-19","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":25000.0,"dk":"MRD200341928/20042000105","al":"NASD alleged that, on trade dates July 22ND and 23RD, 2003, Goldman, Sachs & co. (\"GSCO\") engaged in certain transactions that in certain respects violated rules for short sales transactions and marketplace rules for OATS (NASD conduct rules 3370, 2110 and 3010, and NASD marketplace rules 4632, 6130 and 6955(a)), and that GSCO's supervisory procedures in such areas were deficient.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On or about June 15, 2000, without admitting or denying the allegations or findings, gsco consented to a censure and to pay a total fine of $25,000. The letter of acceptance, waiver and consent was accepted by the NASD on 7/19/2005.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2606},{"d":"2005-06-13","di":"2005-06-13","dr":"2005-06-13","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Securities Division","san":"Cease and Desist","os":"Payment of $300,000 to the Missouri investor education and protection fund.","st":"Final","fine":300000.0,"dk":"CASE NO. AP-05-20","al":"The firm was alleged to have violated securities laws by failing to adequately supervise its agents in the state of Missouri.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2607},{"d":"2005-06-02","di":"2004-12-01","dr":"2005-06-02","k":"Regulatory Action","rg":"State regulator","reg":"The State of Illinois","san":"Revocation","st":"Final","dk":"0400652","al":"Respondent's registration as a dealer in The State of Illinois is subject to prohibition pursuant to section 8.e(1)(k) of the Illinois securities law because respondent consented to a Securities and Exchange Commission order.","res":"Consent","sd":"Respondent is censured and will pay $7,500 for the cost of the investigation.","sm":"The formal hearing scheduled on this matter is hereby dismissed without further proceedings.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2608},{"d":"2005-05-31","di":"2005-05-03","dr":"2005-05-31","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"04-RFT-083","al":"CBOT alleged that on December 20 through December 22, 2004, Goldman, Sachs & co. made data entry errors on 11 trades, in violation of regulation 332.08.","res":"Consent","sm":"Without admitting or denying the allegations, Goldman, Sachs & co. consented to pay a $1000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2609},{"d":"2005-05-13","di":"2005-03-04","dr":"2005-05-13","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":140000.0,"dk":"C10050037","al":"As part of an industry-wide settlement of reporting issues, on March 4, 2005, the NASD alleged that on or about January 2003 through May 2004, Goldman, Sachs & co. (\"GS\") failed to timely report 10% of its municipal securities inter-dealer transactions, and that GS failed to report the time of trade execution and/or reported invalid time of trades 49% of the time. NASD alleged that on or about February 2003 through October 2003, GS failed to report 79% of the time municipal securities inter-dealer trade executions, to the municipal securities rulemaking board (\"MSRB\"). The NASD alleged that such reporting issues violated MSRB rule G-14. On or about January 2003 through May 2004, GS failed to monitor its trades to ensure compliance with MSRB rule G-14, in violation of MSRB rule G-27.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On May 6, 2005, without admitting or denying the allegations or findings, GS consented to a censure and to pay a $140,000 fine. The letter of acceptance, waiver and consent was accepted by NASD on May 13, 2005.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2610},{"d":"2005-05-04","di":"2005-05-04","dr":"2005-05-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Colorado-Securities Commission","st":"Final","dk":"XY 2004 004","al":"Janney Montgomery Scott (JMS) allowed albert copperstone, an unlicensed sales representative in Colorado, to conduct securities transactions with a Colorado resident.","res":"Consent","sd":"JMS required to conduct 4 internal audits of boca raton branch; July - December, 2005, jan-June 2006, and jan- July 2007. Branch manager terry metzger, required to complete continuing ed program with two years of orders. Restitution of $259,227.82","sm":"JMS allowed albert copperstone, an unlicensed sales representative in Colorado, to conduct securities transactions with a Colorado resident.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2611},{"d":"2005-05-02","di":"2002-12-29","dr":"2005-05-02","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $15,000","st":"Final","fine":15000.0,"dk":"CLG050050AWC","al":"During the period January 1, 2002 through March 31, 2002, William Blair & Company (\"the firm\") allegedly violated SEC rule 11AC1-4 by failing to immediately display thirty seven customer limit orders in Nasdaq securities in its public quotation. During the same time period, the firm allegedly violated NASD marketplace rule 6955(a) and NASD conduct rule 2110 by transmitting to OATS fifty eight reports that contained inaccurate, incomplete, or improperly formatted data. During the time period June 30, 2003 through July 3, 2003, the firm allegedly violated NASD membership and registration rule 1032(f) by failing to register one person with the NASD as a limited representative - equity trader.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was notified on May 2, 2005 that the NASD's office of disciplinary affairs and the national abjudicatory council had accepted the acceptance, waiver and consent (AWC) to settle the complaint. Without admitting or denying the allegations contained in the complaint, William Blair & Company agreed to pay the fine of $15,000 to settle the matter.","sm":"The fine of $15,000.00 was paid on June 3, 2005.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2612},{"d":"2005-04-25","di":"2005-04-25","dr":"2005-04-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine, Office of Securities","san":"Censure","os":"Administrative fine of $27,000","st":"Final","fine":27000.0,"dk":"05-026-CAG","al":"During August 5, 1999 through July 31, 2000, a registered representative of the firm had transacted business with Maine clients and was not licensed or exempt. The firm was alleged to have violated the revised Maine Securities Act by employing this registered representative who was not licensed or exempt in the state and failing to reasonably supervise one of its registered representatives.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2613},{"d":"2005-04-13","di":"2005-04-13","dr":"2005-04-13","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","os":"Fine of $25,000","st":"Final","fine":25000.0,"dk":"AWC CE2050007","al":"During the period of May 25, 2001 through April 12, 2002, wachovia was alleged to have violated conduct rules 2110 and 2210(c) (1)in failing to file sales literature with the NASD, alleged to have violated rule 2110 and 3010(a)(1) in failing to resonably supervise the written communication of a registered representative, and alleged to have violated rule 2110 and 3010(b)(1)in failing to establish, maintain and enforce written procedures on communications to the public.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2614},{"d":"2005-03-17","di":"2003-05-27","dr":"2005-03-17","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":125000.0,"dk":"CE2050004","al":"The NASD alleged that Goldman Sachs violated NASD rules 2710, 2110 and 3010 for failing to take reasonable steps to ensure that shares of an issuer held by relatives of certain employees were not sold prior to the expiration of lock-up periods in connection with Goldman Sachs' role as an underwriter of such issuer's IPO.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On March 17, 2005, without admitting or denying the allegations or findings, Goldman Sachs entered into an acceptance, waiver and consent with the NASD. Goldman Sachs agreed to censure by the NASD and to pay a fine of $125,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2615},{"d":"2005-03-04","di":"2005-02-03","dr":"2005-03-04","k":"Regulatory Action","rg":"Other","reg":"Philadelphia Stock Exchange (\"PHLX\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"2005-01","al":"PHLX alleged that on April 15, 2004, Goldman, sach & co. (\"GS\") failed to maintain required position limits in violation of PHLX rule 1001.","res":"Decision","sm":"GS submitted on offer of settlement, stipulation of facts and consent to sanctions, which were accepted, without admitting or denying the allegations, GS consented to censure and payment of a $2,500 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2616},{"d":"2005-02-24","di":"2005-02-24","dr":"2005-02-24","k":"Civil Judicial Action","san":"Injunction","os":"In a related SEC administrative proceeding, CMTC agreed to an order censuring the firm and an undertaking to engage an independent consultant","st":"Final","fine":5000000.0,"al":"SEC alleged violations of Securities Act section 5, Exchange Act section 10(b) and rule 10B-5, Exchange Act section 15(a), Exchange Act section 17a(c) (1), and from aiding and abetting violations of Exchange Act section 10(b) and rule 10B-5. SEC alleged that CMTC (an entity that is 50% owned by mellon Canada holding company) had failed to register as a transfer agent with the SEC, that it had issued \"legend free\" stock certificates of a company whose shares were not registered with the SEC, that one of its managers had accepted payments of stock from the company's officers to issue the certificates, and that it had acted as an unregistered broker or dealer in connection with its stock plan administration business.","res":"Consent","sd":"CMTC was permanently enjoined from prescribed violations of Securities Act section 5, exhcange act section 10(b) and rule 10B-5, Exchange Act section 15(a), Exchange Act section 17a(c)(1), and from aiding and abetting future violations of Exchange Act section 10(b) or rule 10B-5. CMTC agreed to pay a civil monetary penalty of $5 million and disgorgement of $889,773 and prejudgment interest of $140,270. Payment was made on March 4, 2005.","ab":"CIBC Mellon Trust Company","firms":[231],"id":2617},{"d":"2005-02-04","di":"2005-01-24","dr":"2005-02-04","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","st":"Final","fine":40000000.0,"al":"The SEC alleged that Goldman, Sachs & co. (\"GS\") violated rule 101 of Regulation M under the Securities Act of 1934 by attempting to induce, or inducing certain investors to make aftermarket purchases of certain initial public offerings (\"IPOS\") underwritten by GS, during 2000.","res":"Other","sd":"GS paid a total fine of $40 million on March 31, 2005 and was permanently restrained and enjoined from violating rule 101 of Regulation M under the Securities Act of 1934.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2618},{"d":"2005-02-02","di":"2004-11-11","dr":"2005-02-02","k":"Regulatory Action","rg":"Other","reg":"Philadelphia Stock Exchange (\"PHLX\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":100000.0,"dk":"2004-10","al":"PHLX alleged that from January 2003 through June 2003, on six separate occasions, Goldman, Sachs & co. entered orders to trade all of the separate components of the exchange oil service sector index or semiconductor sector index (\"INDICES\") for its principal facilitation account prior to facilitating the execution at the PHLX of customer orders to trade options on the INDICES, in violations of PHLX rule 1064.","res":"Decision","sm":"Goldman, Sachs & co. submitted an offer of settlement to PHLX, which was accepted. Without admitting or denying the allegations, Goldman, Sachs & co. consented to pay a $100,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2619},{"d":"2005-01-10","di":"2003-09-30","dr":"2005-01-10","k":"Civil Judicial Action","san":"Other","os":"Civ - civil complaint filed","st":"Final","al":"The California corporations commissioner alleges a former branch manager failed to supervise a former registered representative who misappropriated money from his clients, all of whom have been reimbursed by the firm.","res":"Dismissed","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2620},{"d":"2004-12-31","di":"2004-12-31","dr":"2004-12-31","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"CMS040209","al":"NASD alleged that Goldman, Sachs & co.'s (\"GS\") supervisory system did not provide for supervision reasonably designed to achieve compliance with securities laws and regulations relating to (I) the proper marking of order tickets for propriety orders and compliance with the \"tick test\" and (II) trading in front of customer orders, in violation of NASD conduct rules 2110 and 3010.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The NASD allegations resulted from a trading and market marking surveillance examination conducted by the NASD department of market regulation during November 18-22, 2002. GS submitted a letter of acceptance, waiver and consent to the NASD, which was accepted. Without admitting or denying the allegations, GS consented to pay a $5,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2621},{"d":"2004-12-01","di":"2004-09-27","dr":"2004-12-01","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"04-RFT-026","al":"The CBOT alleged that Goldman, Sachs & co. failed to make all trade data submissions in a correct manner in violation of regulation 332.08.","res":"Decision","sm":"Goldman, Sachs & co. submitted an offer of settlement to the CBOT, which was accepted. Without admitting or denying the allegations, Goldman, Sachs & co. consented to pay a $1000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2622},{"d":"2004-11-30","di":"2004-11-30","dr":"2004-11-30","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","st":"Final","fine":650000.0,"dk":"AWC NO. CAF040089","al":"The firm was alleged to have failed to file Form U4 and U5 amendments in a timely manner from January, 2002 to March, 2004.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2623},{"d":"2004-11-12","di":"2003-09-30","dr":"2004-11-12","k":"Regulatory Action","rg":"State regulator","reg":"State of California, Department of Corporations","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250000.0,"al":"The firm was alleged to have violated corporations code section 25210(b), 25218, code of regulations section 260.210(a), 260.218, 260.218.4(a), 260.218.4(c)in the employing of an agent without investigating the experience and background of the individual, failing to enforce written procedures and failing to supervise the agent.","res":"Order","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2624},{"d":"2004-11-10","di":"2004-11-04","dr":"2004-11-10","k":"Civil Judicial Action","san":"Injunction","os":"Civil penalty of $37,000,000.00","st":"Final","fine":37000000.0,"al":"Without admitting or denying the allegations in the complaint, Wachovia Corporation settled a civil action brought by the U.S. Securities and Exchange Commission for violations of the proxy disclosures and other reporting requirements concerning the 2001 merger between first union corporation and old Wachovia Corporation. Under the settlement Wachovia Corporation paid $37 million civil penalty and is enjoined from future violations of certain provisions of the federal securities laws.","res":"Settled","sd":"Civil penalty of $37 million paid to the US Treasury on November 15, 2004. Wachovia Corporation was enjoined from directly or indirectly violating section 13(a) and 14(a) of the Exchange Act and rules 12B-20, 13A-13 and 14A-9 thereunder.","ab":"Wachovia Corporation","firms":[11025],"id":2625},{"d":"2004-09-20","di":"2004-09-14","dr":"2004-09-20","k":"Regulatory Action","rg":"CME Group","reg":"Chicago Mercantile Exchange (\"CME\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"04-24339-CTRA","al":"CME alleged that on September 8, 2004, Goldman, Sachs & co.'s floor order pick up exception rate of 13.40%, exceeded the acceptable rate, in violation of rule 536.","res":"Decision","sm":"Without admitting or denying the allegations, Goldman, Sachs & co. consented to pay a $1,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2626},{"d":"2004-09-16","di":"2003-07-02","dr":"2004-09-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Censure","st":"Final","fine":875000.0,"dk":"SEC RELEASE NO. 33-8475","al":"In three instances in 1999 and 2000, the firm failed to disclose that it had received a payment for publishing research. It was also alleged the firm failed to maintain internal electronic mail communications from July 1999 through June 2001.","res":"Settled","sd":"A fine of $875,000 was paid in full 09/16/2004.","sm":"During 1999 and 2000, Janney montgomery received three payments in consideration for publishing research on three public companies. Janney montgomery did not disclose those payments in its research reports. The firm's failure to disclose these payments were in violation of section 17(b) of the Securities Act. In addition, from July 1999 through June 2001, Janney montgomery failed to preserve business-related internal electronic mail communications that it was required to maintain pursuant to section 17(a) of the Exchange Act and rule 17A-4 thereunder.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2627},{"d":"2004-09-16","di":"2004-09-16","dr":"2004-09-16","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine, Office of Securities","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"04-063-CAG","al":"The firm inadvertently failed to renew sales representative, larry m malles, license by December 31, 2003 which resulted in MR malles transacting business unlicensed from January 6, 2004 through January 8, 2004.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2628},{"d":"2004-08-18","di":"2003-04-23","dr":"2004-08-18","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange (\"Ise\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"2002-1130-03; 2002-1231-10; 2003-01;","al":"The ise alleged that in 43 instances between November 2002 through April 2003, Goldman Sachs (\"GS\"), as electronic access member (\"EAM\"), received customer orders and within 30 seconds of entering the orders into the ise trading system, GS entered proprietary orders that executed against the customer orders, in violation of ise rule 717(d). The ise alleged that on one occasion in December 2002, GS, as EAM, received a customer order which was executed against an existing principal order without first posting the order on the exchange for 30 seconds, in violation of ise rule 717(d). The ise also alleged that GS failed to mention satisfactory written supervisory procedures to ensure compliance with ise rules regarding proper facilitation of customer orders by GS, in violation of ise rule 401.","res":"Acceptance, Waiver & Consent(AWC)","sm":"GS entered into a letter of acceptance, waiver and consent with ise. Without admitting or denying the allegations, GS agreed to a censure by ise and to payment of a $15,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2629},{"d":"2004-08-18","di":"2004-05-13","dr":"2004-08-18","k":"Regulatory Action","rg":"State regulator","reg":"The State of Georgia","san":"Censure","os":"Civil penalty","st":"Final","fine":3000.0,"dk":"CASE NUMBER EN-19766","al":"It was alleged Janney montgomery failed to keep the required registration records of licenses and registrations pertaining to two registered representatives.","res":"Order","sd":"The civil penalty of $3,000 plus $2,000 for cost of the investigation was paid 08/13/2004. Restitution in the amount of $1,096.50 was paid to two customers on 09/08/2004.","sm":"Janney Montgomery Scott LLC neither admits nor denies the finding of fact and conclusions of law contained herein, but consents to the entry of the foregoing consent order.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2630},{"d":"2004-08-16","di":"2004-05-07","dr":"2004-08-16","k":"Regulatory Action","rg":"State regulator","reg":"The State of Illinois","san":"Revocation","st":"Final","fine":5000.0,"dk":"0300927","al":"Respondent's registration as a dealer in The State of Illinois is subject to revocation because of an inadvertent registration error relating to the registration of two financial consultants of the firm.","res":"Consent","sd":"Consent order of censure issued. Respondent is censured and will pay for the cost of investigation.","sm":"Consent order of censure issued. Respondent, while neither admitting nor denying the truth of the allegations regarding the registration of two of its financial consultants in The State of Illinois, consented to a censure and will pay for the cost of investigation.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2631},{"d":"2004-08-13","di":"2004-07-08","dr":"2004-08-13","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Fine of $250,000","st":"Final","fine":250000.0,"dk":"HPD# 04-115","al":"As a result of its exam of first union in 2000 and 2001, the NYSE found registration issues, customer complaint reporting deficiencies, review of discretionary accounts shortcomings, insufficent disclosure in mutual fund switch letters and lack of clear language in research reports.","res":"Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2632},{"d":"2004-07-21","di":"2004-06-22","dr":"2004-07-21","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc. (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":175000.0,"dk":"04-146","al":"NYSE alleged that, during the period January through May 2001, Goldman, Sachs & co. (GS) failed to supervise and control the activities of a former registered representative (\"RR\") who failed to timely supply accounts numbers, or other indications of beneficial ownership of trades, and delay allocation of executed trades, which led to more favorable trades in the RR's personal account for a potential gain of $600,000, and was to the detriment of GS customers, GS is also alleged to have failed to ensure that its employees made and preserved books and records concerning account designations and execution of customer orders. The alleged conduct is in violation of NYSE rules 342, 342.16, 440 Securities and Exchange Commission regulations 240.17A-3(a)(6) and (7).","res":"Stipulation and Consent","sm":"GS submitted a consent to penalty to NYSE, which was accepted. Without admitting or denying the allegations, GS offered to be censured and paid a $175,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2633},{"d":"2004-07-15","di":"2004-07-15","dr":"2004-07-15","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine","st":"Final","fine":4656425.0,"dk":"CMS040106","al":"NASD alleged that on five pairs of trades executed on Goldman, Sachs & co.'s (\"GS\") high yield and distressed bond desks between July 2000 and August 2001, GS violated NASD rules relating to markups/markdowns and record-keeping and that each transaction violated NASD conduct rules 2110, 2440, IM-2440, 3010, 3110 and 6240, section 17(a) of the Exchange Act and rules 17A-3 and 17A-4.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On July 15, 2004 the NASD office of disciplinary affairs and national adjudicatory council accepted a letter of acceptance, waiver and consent (\"AWC\") that was executed by the company on July 13, 2004. In the AWC, the NASD's department of market regulation (without making any legal or factual findings) stated or alleged that the company had violated NASD rules relating to markup/markdowns in connection with five trades occurring between July 2000 and August 2001 by the company's high-yield and distressed bond desks; that the company violated record-keeping rules in that those desks failed in some instances to create certain required records and in some instances inaccurately recorded times of trade execution; and that in certain respects the company's supervisory system for high-yield and distressed bond trading was inadequate in its scope and flawed in its execution.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2634},{"d":"2004-07-01","di":"2004-07-01","dr":"2004-07-01","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000000.0,"dk":"3-11533","al":"The SEC alleged that Goldman Sachs sales traders for the asian shares sales desk made public offers of securities via e mail to certain institutional customers in connection with four international public offerings during the \"waiting period,\" when the registration statements were filed, but not yet declared effective by the SEC, during the period October 1999 to March 2000, in violation of section 5(b) of the Securities Act of 1933 (\"Securities Act\"). The SEC alleged that Goldman Sachs failed to supervise these sales traders for purposes of section 15(b)(4)(e) of the Securities Exchange Act of 1934. The SEC also alleged that a Goldman Sachs representative made comments to the media on four occasions in connection with one of the public offering during the \"pre-filing period,\" the period before the registration statement was filed with the SEC, from January to February 2000, in violation of section 5(c) of the Securities Act.","res":"Order","sm":"Goldman Sachs submitted an offer to the SEC, which was accepted. Without admitting or denying the allegations, Goldman Sachs offered to cease and desist from committing or causing violations, and any future violations, of section 5(b) and 5(c) of the Securities Act, and to pay a civil money penalty of $2,000,000 to the United States Treasury.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2635},{"d":"2004-07-01","di":"2002-05-23","dr":"2004-07-01","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":20000.0,"dk":"CMS 040111","al":"NASD alleged that in 128 instances between July 2003 and September 2003, during the 9 minute period immediately prior to the opening of the market, Goldman Sachs, as market maker for certain securities, caused a locked/crossed market condition by entering a bid (ASK) quotation that locked/crossed another market maker's quotation without immediately sending through selectnet to such locked/crossed market maker a trade-on-move message that was at the receiving market maker's quoted price and whose aggregate size was at least 5,000 shares, in violation of NASD marketplace rule 4613(e)(l)(c).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Goldman Sachs entered into a letter of acceptance, waiver and consent (\"AWC\") with NASD. Without admitting or denying the allegations, Goldman Sachs agreed to a censure by NASD and the payment of a $20,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2636},{"d":"2004-06-28","di":"2004-06-28","dr":"2004-06-28","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Restitution of $19,486.25","st":"Final","fine":20000.0,"dk":"C05040043","al":"The firm was alleged to have failed to execute eight municipal security positions at prices that were fair and reasonable, during the period from on or about August 22, 2002 through December 10, 2002 in violation of MSRB rules G-17 and G-30(a).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2637},{"d":"2004-02-12","di":"2004-02-12","dr":"2004-02-12","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Monetary fine and undertakings","st":"Final","fine":2422232.0,"dk":"CAF040008","al":"Without admitting or denying the allegations, the firm was alleged to have violated NASD conduct rule 2110, standards of commercial honor and principles of trade, as it relates to dislosing to clients their eligibility of receiving mutual fund breakpoint discounts.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The firm agreed to the letter of acceptance, waiver and consent without admitting or denying the allegations. In addition to the censure and monetary fine, the firm has agreed to certain undertakings: (1) a trade by trade review of all front end loaded fund sales above $2500 from January 1, 1999 through November 3, 2003 to ensure that customers receive the appropriate sales discounts and provide refunds where applicable and (2) within 6 months of the date of the AWC, the firm will certify to the regulators that a system is in place reasonably designed to make certain customers get appropriate breakpoint discounts.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2638},{"d":"2004-02-12","di":"2004-02-12","dr":"2004-02-12","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"Censure, monetary fine and disgorgement, plus prejudgment interest","st":"Final","fine":2422232.0,"dk":"3-11410","al":"Without admitting or denying the allegations, the firm was alleged to have violated section 17(a)(2) of the Securities Act in failing to notify customers of appropriate breakpoint discounts and violated rule 10B-10 under the Exchange Act in failing to disclose the remuneration the firm received from front end sales loads.","res":"Decision & Order of Offer of Settlement","sm":"The firm agreed to an offer of settlement without admitting or denying the allegations. In addition to the censure, cease and desist order, monetary fine, the firm has agreed to certain undertakings set forth under NASD AWC#CAF040008: (1) a trade by trade review of all front end loaded fund sales above $2500 from January 1, 1999 through November 3, 2003 to ensure that customers receive the appropriate sales discounts and provide refunds where applicable, and (2) within 6 months of the date of the AWC, the firm will certify to the regulators that a system is in place reasonably designed to make certain customers get appropriate breakpoint discounts.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2639},{"d":"2004-01-23","di":"2004-01-23","dr":"2004-01-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"ST-03-6927-S","al":"Alleged to have violated section 36B-6(b) and section 36B-6(c) of the Connecticut uniform Securities Act where certain finacial advisors and a sales assistant were not registered as investment advisory agents.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2640},{"d":"2003-12-29","di":"2002-04-12","dr":"2003-12-29","k":"Regulatory Action","rg":"State regulator","reg":"State of West Virginia/ Office of the State Auditor","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"E03-1353","al":"Various state regulators, including the State of West Virginia/ Office of the State Auditor, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of West Virginia/ Office of the State Auditor that found Goldman Sachs to have violated the West Virginia Securities Act which proscribes the use of dishonest or unethical practices in the securities business under West Virginia code § 32­2­204(a)(2)(g) and West Virginia code § 32­2­204(a) (2)(j), broker-dealers also are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2641},{"d":"2003-12-15","di":"2002-04-12","dr":"2003-12-15","k":"Regulatory Action","rg":"State regulator","reg":"State of California - Business, Transportation and Housing Agency, Department of Corporations","san":"Cease and Desist","st":"Final","fine":2609851.0,"dk":"081832609851","al":"Various state regulators, including the State of California - Business, Transportation and Housing Agency, Department of Corporations conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of California business, transportation and housing agency, department of corporations, that found Goldman Sachs to have violated corporations code section 25218 and title 10 California code of regulations section 260.218 and 260.218.4(a) by: failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking and failing to reasonably supervise its employees to ensure that its analysts who issued research were adequately insulated from pressures and influenced from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2642},{"d":"2003-12-05","di":"2002-04-12","dr":"2003-12-05","k":"Regulatory Action","rg":"State regulator","reg":"New Mexico Regulation & Licensing Department/ Securities Division","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"03-03-031-048 (CO)","al":"Various state regulators, including the New Mexico Regulation & Licensing Department/ Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the New Mexico Regulation & Licensing Department/ Securities Division that found Goldman Sachs to have failed to ensure and failed reasonably to supervise that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking under section 58-13B-16.A(2)(h).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2643},{"d":"2003-12-04","di":"2002-04-12","dr":"2003-12-04","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois Secretary of State Securities Department","san":"Cease and Desist","st":"Final","fine":956921.0,"dk":"0300910","al":"Various state regulators, including the State of Illinois Secretary of State Securities Department, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Illinois securities department that found Goldman Sachs to have violated section 8.e(1)(b) that proscribes the use of unethical practices in the securities business and section 8.e(1)(e)(IV) that requires dealers to supervise adequately the conduct of their employees.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2644},{"d":"2003-11-25","di":"2002-04-12","dr":"2003-11-25","k":"Regulatory Action","rg":"State regulator","reg":"Missouri Office of Secretary of State","san":"Cease and Desist","st":"Final","fine":431117.0,"dk":"AO-03-15","al":"Various state regulators, including the Missouri Office of Secretary of State, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Order","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Missouri office of SEC. of state that found Goldman Sachs to have violated §409.204(a)(2)(g) rsmo by the commissioner of securities by failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2645},{"d":"2003-11-25","di":"2002-04-12","dr":"2003-11-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Nebraska/ Department of Banking & Finance","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"RECEIPT # 75114","al":"Various state regulators, including the State of Nebraska/ Department of Banking & Finance, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Nebraska/ Department of Banking & Finance that found Goldman Sachs to have violated the neb. Rev. Stat. § 8­1103(9)(a)(VII) that Goldman Sachs failed to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2646},{"d":"2003-11-25","di":"2002-04-12","dr":"2003-11-25","k":"Regulatory Action","rg":"State regulator","reg":"The State of New Hampshire/ Department of State/ Bureau of Securities Regulation","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"CRD #361","al":"Various state regulators, including the state of New Hampshire/department of state/bureau of securities regulation, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with The State of New Hampshire/ Department of State/ Bureau of Securities Regulation that found Goldman Sachs to have violated the New Hampshire Securities Act under N.H. Rev. Stat. §§ 421­b:10(I)(b)(7) which proscribes the use of dishonest or unethical practices in the securities business and 421­ b:10(I)(b)(10) which states broker-dealers also are required to supervise adequately the conduct of their employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2647},{"d":"2003-11-25","di":"2002-04-12","dr":"2003-11-25","k":"Regulatory Action","rg":"State regulator","reg":"State of North Carolina/ Department of the Secretary of State","san":"Cease and Desist","st":"Final","fine":620209.0,"dk":"03-009-IG","al":"Various state regulators, including the State of North Carolina/ Department of the Secretary of State, conducted an industry- wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of North Carolina/ Department of the Secretary of State that found Goldman Sachs to have violated the North Carolina Securities Act under N.C.G.S. §78a­39(a)(2) (g) which proscribes the use of dishonest or unethical practices in the securities business.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2648},{"d":"2003-11-25","di":"2002-04-12","dr":"2003-11-25","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Pennsylvania/ Pennsylvania Securities Commission","san":"Cease and Desist","st":"Final","fine":946269.0,"dk":"2003-04-46","al":"Various state regulators, including the Commonwealth of Pennsylvania/ Pennsylvania Securities Commission, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Pennsylvania securities commission that found Goldman Sachs to have violated proceedings under section 305(a)(x) of the 1972 act, 70 P.S. § 1­305 (a)(IX) which prohibits the use of dishonest or unethical practices; and that there would be a basis for the commission to suspend, revoke or condition the broker-dealer registration of Goldman Sachs in the Commonwealth of Pennsylvania.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2649},{"d":"2003-11-24","di":"2002-07-17","dr":"2003-11-24","k":"Regulatory Action","rg":"Other","reg":"Philadelphia Stock Exchange","san":"Censure","os":"Monetary/fine of $20,000.00","st":"Final","fine":20000.0,"dk":"ENFORCEMENT NUMBER 2002-09","al":"Without admitting or denying any allegations or violations, respondent consented to findings that from December 3, 2001, through May 8, 2002, it violated PHLX rules 707, 708, and 748. Specifically, (I) an employee of respondent represented and executed for respondent 46 orders on the PHLX floor at a time when such employee was not a member of the PHLX eligible to conduct business on the PHLX floor; (II) anther employee of respondent represented and executed for respondent 41 orders on the PHLX floor at a time when such employee had not become an effective member of the PHLX by temporarily assuming legal title to one of respondent's PHLX memberships; (III) respondent avoided costs associated with acquiring equitable title to a third PHLX membership and avoided having pay to the PHLX certain dues, fees and charges; and (IV) respondent failed to maintain and enforce written supervisory procedures, and a system to enforce such procedures, regarding its operations on the PHLX floor.","res":"Decision & Order of Offer of Settlement","sd":"Respondent consented to: (I) a censure; (II) a fine in the amount of $20,000; and (III) completion of the following undertakings: (1) issuance of written policies and procedures (including supervisory procedures) pertaining to the conduct of business by respondent on the PHLX floor. Such policies and procedures should inform respondent's exchange floor personnel and supervisors of, among other things, respondent's policies and procedures concerning inactive nominee status on the PHLX floor; and (2) issuance of a compliance bulletin, not unacceptable to PHLX staff, to all members of respondent's exchange floor operations, explaining respondent's policies and procedures concerning inactive nominee status on the PHLX floor.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2650},{"d":"2003-11-21","di":"2002-04-12","dr":"2003-11-21","k":"Regulatory Action","rg":"State regulator","reg":"Maryland Securities Division","san":"Cease and Desist","st":"Final","fine":408100.0,"dk":"2002-0893","al":"Various state regulators, including the Maryland Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Maryland Securities Division that found Goldman Sachs to have violated Maryland Securities Act, section 11-412(a)(7) that subject broker-dealers to sanction for engaging in dishonest or unethical practices in the securities business and Maryland Securities Act 11-412(a)(10) that states broker-dealers are also subject to sanction for failure to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2651},{"d":"2003-11-19","di":"2002-04-12","dr":"2003-11-19","k":"Regulatory Action","rg":"Other","reg":"Government of the District of Columbia, Department of Insurance and Securities","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"SEC. CO 03-03","al":"Various state regulators, including the Government of the District of Columbia, Department of Insurance and Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Government of the District of Columbia, Department of Insurance and Securities regulation that found Goldman Sachs to have violated D.C. Official code §31­ 5602.07(a)(9) by failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking. Goldman Sachs also violated D.C. Official code §31­5602.07(a)(12) by failing to reasonably supervise its employees to ensure that its analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2652},{"d":"2003-10-31","di":"2003-04-28","dr":"2003-10-31","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"$10,000,000 for investor education $50,000,000 to fund independent, third-party research","st":"Final","fine":50000000.0,"al":"On April 28, 2003, the SEC filed complaints against ten investment banking firms as part of a global settlement relating to equity research analyst conflicts of interests. The complaint against Goldman Sachs alleges that the firm violated (I) NYSE rules 401 and 476 and NASD conduct rule 2110 by engaging in acts and practices during the period July 1, 1999 through June 30, 2001 that created and/or maintained inappropriate influence by investment banking over research analysts and therefore imposed conflicts of interest on its research analysts; (II) NYSE rule 472 and NASD conduct rule 2210 by issuing in certain instances research reports for companies that were not based on principles of fair dealing and good faith and did not provide a sound basis for evaluating facts, contained exaggerated or unwarranted claims about these companies, and/or contained opinions for which there was no reasonable basis; and (III) NYSE rule 342 and NASD conduct rule 3010 by failing to establish and maintain adequate supervisory procedures over research analysts to prevent or manage conflicts of interest.","res":"Other","sd":"$25,000,000 as disgorgement $25,000,000 as a penalty $50,000,000 to fund independent, third-party research $10,000,000 for investor education","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2653},{"d":"2003-10-31","di":"2003-04-28","dr":"2003-10-31","k":"Civil Judicial Action","san":"Civil Penalty(ies)/Fine(s)","os":"$10,000,000 for investor education; $50,000,000 to fund independent, third-party research.","st":"Final","fine":50000000.0,"al":"On April 28, 2003, as part of a global settlement, the SEC filed a complaint against ten investment banking firms, including GS alleging that they violated (I) NYSE rules 401 and 476 and NASD conduct rule 2110 by permitting investment banking to exercise inappropriate influence over research analysts; (II) NYSE rule 472 and NASD conduct rule 2210 by issuing research reports that contained exaggerated or unwarranted claims; and (III) NYSE rule 342 and NASD conduct rule 3010 by failing to prevent or manage conflicts of interest adequately.","res":"Other","sd":"$25,000,000 as a penalty; $25,000,000 as disgorgement; $10,000,000 as investor education; $50,000,000 to fund independent, third-party research.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2654},{"d":"2003-10-27","di":"2002-04-12","dr":"2003-10-27","k":"Regulatory Action","rg":"State regulator","reg":"Ohio Department of Commerce/ Division of Securities","san":"Cease and Desist","st":"Final","fine":874773.0,"dk":"CHECK # 056674","al":"Various state regulators, including the Ohio Department of Commerce/ Division of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Ohio Department of Commerce/ Division of Securities that found Goldman Sachs to have violated Ohio revised code chapter 1707 and the rules promulgated there under that Goldman Sachs failed to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banks.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2655},{"d":"2003-10-20","di":"2002-04-12","dr":"2003-10-20","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia/ State Corporation Commission","san":"Cease and Desist","st":"Final","fine":545408.0,"dk":"SEC-2003-0016","al":"Various state regulators, including the Commonwealth of Virginia/ State Corporation Commission, conducted an industry-wide, joint investigation into conflicts of interest between equity","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Commonwealth of Virginia/ State Corporation Commission that found Goldman Sachs to have violated the act which proscribes the use of dishonest or unethical practices in the securities business under securities vac 5-20-280 e 12 and 21 vac 5-20-260 which requires broker-dealers to supervise adequately the conduct of its employees and agents. NASD conduct rule 2110 requires broker-dealers to observe high standards of commercial honor and just and equitable principles of trade.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2656},{"d":"2003-10-20","di":"2002-04-12","dr":"2003-10-20","k":"Regulatory Action","rg":"State regulator","reg":"The Commissioner of Securities of the State of Louisiana","san":"Cease and Desist","st":"Final","fine":344339.0,"dk":"UNKNOWN","al":"Various state regulators, including The Commissioner of Securities of the State of Louisiana, conducted an industry-wide, joint investigation into conflicts of interest between equity.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with The Commissioner of Securities of the State of Louisiana that found Goldman Sachs to have violated the Louisiana securities law in failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking. Additionally, Goldman Sachs failed to supervise its employees to ensure analysts who issued research were adequately insulated from pressured and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2657},{"d":"2003-10-14","di":"2003-10-14","dr":"2003-10-14","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":10000.0,"dk":"CMS030239","al":"NASD alleged that on 18 occasions between March 1, 2002 and July 17, 2002, Goldman Sachs effected transactions in OTC equity options for customer accounts that exceeded NASD equity option position limits, and that each transaction violated NASD conduct rules 2110 and 2860(b)(3).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Goldman Sachs entered into a letter of acceptance, waiver and consent (\"AWC\") with NASD. Without admitting or denying the allegations, Goldman Sachs agreed to a censure by NASD and to payment of a $10,000 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2658},{"d":"2003-10-07","di":"2002-04-12","dr":"2003-10-07","k":"Regulatory Action","rg":"State regulator","reg":"North Dakota Securities Department","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"CRD #361","al":"Various state regulators, including the North Dakota Securities Department, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the North Dakota Securities Department that found Goldman Sachs to have violated the Securities Act under section 10-04-11(1)(c) N.D.C.C. Which proscribes the use of dishonest or unethical practices in the securities business; section 10-04-11(1)(m) N.D.C.C. Which states broker-dealers also are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2659},{"d":"2003-10-06","di":"2002-04-12","dr":"2003-10-06","k":"Regulatory Action","rg":"State regulator","reg":"Alabama Department of Commission and Office of the State of the Attorney General, State of Alabama","san":"Cease and Desist","os":"Goldman Sachs will cease and desist from violating 8-6-3(j)(7) and 8-6-3(j)(10) in connection with the research practices","st":"Final","fine":342654.0,"dk":"CO-2003-0031","al":"Various state regulators, including the Alabama securities commission and office of the attorney general, state of Alabama, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Alabama securities commission and office of the attorney general that found Goldman Sachs to have violated code of Alabama 1975 8-6-3(j)(7) which prohibits the use of dishonest or unethical practices in the securities business and code of Alabama 1975 8-6-3(j)(10) which states broker- dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2660},{"d":"2003-10-06","di":"2002-04-12","dr":"2003-10-06","k":"Regulatory Action","rg":"State regulator","reg":"State of Colorado Department of Regulatory Agencies, Division of Securities","san":"Cease and Desist","st":"Final","fine":331417.0,"dk":"04-L-12","al":"Various state regulators, including the State of Colorado Department of Regulatory Agencies, Division of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Colorado Department of Regulatory Agencies, Division of Securities that found Goldman Sachs to have violated §11­51­410(1)(g), C.R.S., and rule 51­4.7 that proscribes the use of dishonest or unethical practices in the securities business and §11­51­410 (1)(I), C.R.S. That states broker­ dealers are required to supervise adequately the conduct of its employees and sales representatives.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2661},{"d":"2003-10-02","dr":"2003-10-02","k":"Regulatory Action","rg":"State regulator","reg":"State of New Jersey/ Department of Law and Public Safety/ Division of Consumer Affairs/ Bureau of Securities","san":"Cease and Desist","st":"Final","fine":648335.0,"dk":"N/A","al":"Various state regulators, including the State of New Jersey/ Department of Law and Public Safety/ Division of Consumer Affairs/ Bureau of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of New Jersey/ Department of Law and Public Safety/ Division of Consumer Affairs/ Bureau of Securities regulation that found Goldman Sachs to have violated N.J.S.A. 49:3-58(a)(2)(VII) to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking and N.J.S.A. 49:3-58(a)(2)(XI) that Goldman Sachs failed reasonably to supervise its employees to ensure that its analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2662},{"d":"2003-09-30","di":"2002-04-12","dr":"2003-09-30","k":"Regulatory Action","rg":"Other","reg":"Oregon/ Department of Consumer and Business Services/ Division of Finance and Corporate Securities","san":"Cease and Desist","st":"Final","fine":263622.0,"dk":"S-03-0036","al":"Various state regulators, including the Oregon/department of consumer and business services/ division of finance and corporate securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Order","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Oregon/ Department of Consumer and Business Services/ Division of Finance and Corporate Securities that found Goldman Sachs to have violated the provisions of ors chapter 59 under ors 59.205 (2) which proscribes the use of dishonest or unethical practices in the securities business; and oar division 441-205-210(1) in which broker-dealers also are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2663},{"d":"2003-09-29","di":"2002-04-12","dr":"2003-09-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Arizona Consumer Protection & Advocacy, Securities Division","san":"Cease and Desist","st":"Final","fine":395321.0,"dk":"S-03533A-03-0000","al":"Various state regulators, including the State of Arizona Consumer Protection & Advocacy, Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Arizona consumer protection & advocacy securities division that found Goldman Sachs to have violated A.R.S. §44­1961 (a)(13) in failing to ensure that analysts who issued research were adequately insulated from pressure and influences from covered companies and investment banking. Additionally, Goldman Sachs failed to supervise its employees to ensure analysts who issued research were adequately insulated from pressured and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2664},{"d":"2003-09-25","di":"2002-04-12","dr":"2003-09-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Georgia Secretary of State Commissioner of Securities","san":"Cease and Desist","st":"Final","fine":630775.0,"dk":"EN-19516","al":"Various state regulators, including the State of Georgia Secretary of State Commissioner of Securities, conducted an industry- wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Georgia, secretary of state, commissioner of securities that found Goldman Sachs to have violated O.C.G.A. §§ 10­5­4 (a)(8) and 10­5­12 (a)(1) and rule 590-4-2-.14(1) that states analysts who issue research be adequately insulated from pressures and influences from covered companies and ib. Additionally, O.C.G.A. §§ 10­5­4 (a)(11) and 10­5­12(a)(1) and rule 590­4­2­.08 (1) that states analysts who issued research were reasonably supervised.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2665},{"d":"2003-09-24","di":"2002-04-12","dr":"2003-09-24","k":"Regulatory Action","rg":"State regulator","reg":"Kansas Office of the Securities Commissioner","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"2003E045","al":"Various state regulators, including the state of Kansas Office of the Securities Commissioner, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Kansas Office of the Securities Commissioner that found Goldman Sachs to have violated K.S.A. 17-1254(m)(7) that proscribes the use of dishonest or unethical practices in the securities business and K.S.A. 17-1254(m)(12) that requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2666},{"d":"2003-09-24","di":"2002-04-12","dr":"2003-09-24","k":"Regulatory Action","rg":"State regulator","reg":"State of Wisconsin/ Department of Financial Institutions","san":"Cease and Desist","st":"Final","fine":413277.0,"dk":"FILE NO. S-03102 (EX)","al":"Various state regulators, including the State of Wisconsin/ Department of Financial Institutions, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Wisconsin/ Department of Financial Institutions that found Goldman Sachs to have violated the Wisconsin uniform securities law, CH. 551, Wisconsin statutes, under SEC. 551.34(1)(g), Wisconsin statutes which proscribes the use of dishonest or unethical practices in the securities business and 551.34(1)(j), wis. Stats which requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2667},{"d":"2003-09-22","di":"2002-04-12","dr":"2003-09-22","k":"Regulatory Action","rg":"State regulator","reg":"Arkansas Securities Department","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"S-03-016-03-C003","al":"Various state regulators, including Arkansas Securities Department, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Arkansas Securities Department that found Goldman Sachs to have violated ark. Code ann. §§ 23­42­308 (a)(2)(g) which proscribes the use of dishonest or unethical practices in the securities business and ark. Code ann. §§ 23­42­308 (a)(2)(j) which states broker­dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2668},{"d":"2003-09-22","di":"2002-04-12","dr":"2003-09-22","k":"Regulatory Action","rg":"State regulator","reg":"The Commonwealth of Massachusetts, Securities Division","san":"Cease and Desist","st":"Final","fine":489205.0,"dk":"E-2003-41","al":"Various state regulators, including The Commonwealth of Massachusetts, Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs has entered into a consent order with the common-wealth of Massachusetts, securities division that found Goldman Sachs to have violated M.G.L. C. 110a, §204(a)(2)(g) that proscribes the use of dishonest or unethical practices in the securities business and M.G.L. C. 110a, §204(a)(2)(j) that states broker­dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2669},{"d":"2003-09-19","di":"2002-04-12","dr":"2003-09-19","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida Office of Financial Regulation","san":"Cease and Desist","st":"Final","fine":1231461.0,"dk":"OFR NO. 0043-S-6/03","al":"Various state regulators, including the State of Florida Office of Financial Regulation, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Florida, office of financial regulation that found Goldman Sachs to have violated section 517.161 (1)(a), fla. Stat., and 3E-600.013 (1)(p)1., fla. Admin. Code that proscribes the use of dishonest or unethical practices in the securities business and the requirement that broker-dealers supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2670},{"d":"2003-09-19","di":"2002-04-12","dr":"2003-09-19","k":"Regulatory Action","rg":"State regulator","reg":"State of Wyoming/ Secretary of State","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"CONSENT ORDER NO. 02-09","al":"Various state regulators, including the State of Wyoming/ Secretary of State, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Wyoming/ Secretary of State that found Goldman Sachs to have violated the Wyoming Securities Act under wyo. Stat. §17­4­106(a)(II)(g) which proscribes the use of dishonest or unethical practices in the securities business and wyo. Stat. §17­4­106 (b)(II)(a) in which broker­dealers are required to supervise adequately the conduct of its employees/agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2671},{"d":"2003-09-15","di":"2002-04-12","dr":"2003-09-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Rhode Island and Providence Plantations/ Department of Business Regulation/ Securities Division","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"CASE # 361","al":"Various state regulators, including the State of Rhode Island and Providence Plantations/ Department of Business Regulation/ Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Rhode Island and Providence Plantations/ Department of Business Regulation/ Securities Division that found Goldman Sachs to have violated the Rhode Island uniform Securities Act of 1990 (\"RISUSA\") § 7­11­212(b)(8) which prohibits the use of dishonest or unethical practices in the securities business; and the Rhode Island uniform Securities Act of 1990 (\"RISUSA\") § 7­11­212(b)(11) stating a broker-dealer is also required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2672},{"d":"2003-09-11","di":"2002-04-12","dr":"2003-09-11","k":"Regulatory Action","rg":"Department of Justice","reg":"State of Delaware Deputy Attorney General, Department of Justice","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"C.A. NO. 03-6-5","al":"Various state regulators, including the State of Delaware Deputy Attorney General, Department of Justice, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Delaware Department of Justice that found Goldman Sachs to have violated 6 del.c. §7316 (a)(7) that proscribes the use of dishonest or unethical practices in the securities business and 6 del. C. §7316(a)(10) that states broker­dealers are required to supervise reasonably the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2673},{"d":"2003-09-10","di":"2002-04-12","dr":"2003-09-10","k":"Regulatory Action","rg":"State regulator","reg":"Vermont Department of Banking, Insurance, Securities and Health Care Administration","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"03-061-S","al":"Various state regulators, including the Vermont Department of Banking, Insurance, Securities and Health Care Administration, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Vermont Department of Banking, Insurance, Securities and Health Care Administration that found Goldman Sachs to have failed to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking under §4221a(a)(8) of the Securities Act.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2674},{"d":"2003-09-05","di":"2002-04-12","dr":"2003-09-05","k":"Regulatory Action","rg":"State regulator","reg":"State of Michigan, Office of Financial and Insurance Services","san":"Cease and Desist","st":"Final","fine":765768.0,"dk":"03-039-M","al":"Various state regulators, including the State of Michigan, Office of Financial and Insurance Services, conducted an industry- wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs has entered into a consent order with the State of Michigan, Office of Financial and Insurance Services that found Goldman Sachs to have violated MCL 451.604(a)(1)(g) that proscribes the use of dishonest or unethical practices in the securities business and MCL 451.604(a)(2) that states broker-dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2675},{"d":"2003-09-05","di":"2002-04-12","dr":"2003-09-05","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Cease and Desist","st":"Final","fine":1606657.0,"dk":"ORDER NO. CAF-1534","al":"Various state regulators, including the Texas State Securities Board, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Texas State Securities Board that found Goldman Sachs to have violated section 14.a(3) of the Texas Securities Act which is to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2676},{"d":"2003-09-04","di":"2003-09-04","dr":"2003-09-04","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Censure","os":"Cease and desist, disgorgement, civil penalty and undertaking","st":"Final","fine":5000000.0,"dk":"FILE NO. 3-11240","al":"Goldman Sachs allegedly violated (I) section 15(c)(1) and rule 15C1-2 of the Exchange Act as a result of certain trading in U.S. Treasury bonds on October 31, 2001; and (II) section 15(f) of the Exchange Act by failing to maintain policies and procedures specifically addressed to the possible misuse of non-public information obtained from outside consultants.","res":"Consent","sm":"On September 4, 2003, the SEC entered its order instituting administrative and cease-and-desist proceedings, making findings, and imposing remedial sanctions and a cease-and-desist order pursuant to sections 15(b)(4) & 21c of the Securities Exchange Act of 1934 as to Goldman, Sachs & co., as described above.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2677},{"d":"2003-09-04","di":"2002-04-12","dr":"2003-09-04","k":"Regulatory Action","rg":"Other","reg":"Hawaii Department of Commerce and Consumer Affairs, Securities Enforcement Attorney","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"SEU2002-045","al":"Various state regulators, including the Hawaii Department of Commerce and Consumer Affairs, Securities Enforcement Attorney, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Hawaii department of commerce and affairs that found Goldman Sachs to have violated H.R.S. §485­15(7) that proscribes the use of dishonest or unethical practices in the securities business and H.R.S. §485­15(10) that states broker­dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2678},{"d":"2003-09-04","di":"2002-04-12","dr":"2003-09-04","k":"Regulatory Action","rg":"Other","reg":"Minnesota Department of Commerce","san":"Cease and Desist","st":"Final","fine":379051.0,"dk":"SE2304866","al":"Various state regulators, including the Minnesota Department of Commerce, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the minn. Department of commerce that found Goldman Sachs to have violated minn. Stat. §80A.07, subd. 1(7) (2002), which proscribes the use of dishonest or unethical practices in the securities business and minn. Stat. §80A.07, subd. 1(10) (2002) and minn. R. CH. 2875.0910(3) (2001) which state broker dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2679},{"d":"2003-09-03","di":"2002-04-12","dr":"2003-09-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Nevada/ Office of the Secretary of State","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"FILE NO. I03-183","al":"Various state regulators, including State of Nevada/ Office of the Secretary of State, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Nevada/ Office of the Secretary of State that found Goldman Sachs to have violated NRS 90.420(1)(h) which proscribes the use of dishonest or unethical practices in the securities business and NRS 90.420(1)(k) which states that broker-dealers also are required to supervise adequately the conduct of their employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2680},{"d":"2003-09-03","di":"2002-04-12","dr":"2003-09-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Oklahoma Department of Securities","san":"Cease and Desist","st":"Final","fine":265877.0,"dk":"ODS FILE NO. 03-129","al":"Various state regulators, including the State of Oklahoma Department of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Oklahoma Department of Securities that found Goldman Sachs to have violated the Oklahoma Securities Act and the rules of the Oklahoma securities commission and the administrator of the department of securities (the \"rules\") which proscribe the use of dishonest or unethical practices in the securities business pursuant to paragraph (8) of subsection (a) of section 204 of the act and 660:10-5- 42 of the rules. Paragraph (12) of subsection (a) of section 204 of the act and 660:10-5-42 of the rules also requires broker- dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2681},{"d":"2003-09-03","di":"2002-04-12","dr":"2003-09-03","k":"Regulatory Action","rg":"State regulator","reg":"South Dakota/ Department of Revenue and Regulation/ Division of Securities","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"CASE # 646","al":"Various state regulators, including the South Dakota/ Department of Revenue and Regulation/ Division of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the South Dakota/ Department of Revenue and Regulation/ Division of Securities that found Goldman Sachs to have violated the uniform Securities Act, chapter 47- 31a, under §47­31a­204(a)(2)(g) which proscribes the use of dishonest or unethical practices in the securities business; and §47­ 31A-204(a)(2)(g) in which broker-dealers also are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2682},{"d":"2003-09-03","di":"2002-04-12","dr":"2003-09-03","k":"Regulatory Action","rg":"State regulator","reg":"State of Tennessee/ Department of Commerce and Insurance/ Office of Legal Counsel","san":"Cease and Desist","st":"Final","fine":438366.0,"dk":"FILE NO. 03-004","al":"Various state regulators, including the State of Tennessee/ Department of Commerce and Insurance/ Office of Legal Counsel, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Tennessee/ Department of Commerce and Insurance/ Office of Legal Counsel that found Goldman Sachs to have violated Tennessee code annotated § 48­2­ 112 (a)(2)(g), failing to ensure that analyst who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2683},{"d":"2003-08-29","di":"2002-04-12","dr":"2003-08-29","k":"Regulatory Action","rg":"State regulator","reg":"Office of the Mississippi Secretary of State/ Business Regulation and Enforcement Division","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"02-11-06-S","al":"Various state regulators, including the Office of the Mississippi Secretary of State/ Business Regulation and Enforcement Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Goldman Sachs will cease and desist from violating the Mississippi Securities Act in connection with the research practices referenced in this order and will comply with the act in connection with the research practices referenced in this order and will comply with the undertakings of addendum a, incorporated herein by reference.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2684},{"d":"2003-08-29","di":"2002-04-12","dr":"2003-08-29","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Puerto Rico/ Office of the Commissioner of Financial Institutions","san":"Cease and Desist","st":"Final","fine":293457.0,"dk":"MATTER NO. C 03-V-012","al":"Various state regulators, including the Commonwealth of Puerto Rico/ Office of the Commissioner of Financial Institutions, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Commonwealth of Puerto Rico/ Office of the Commissioner of Financial Institutions that found Goldman Sachs to have violated the act no. 60, (section 204(a)(2) (g)) and regulation 6078 (section 26.1) which proscribe the use of dishonest or unethical practices in the securities business; and act no. 60, (section 204(a)(2)(j)) and regulation 6078 (sections 25.4.4 and 28.2) which states broker-dealers also are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2685},{"d":"2003-08-27","di":"2002-04-12","dr":"2003-08-27","k":"Regulatory Action","rg":"State regulator","reg":"State of Connecticut Department of Banking","san":"Cease and Desist","st":"Final","fine":262402.0,"dk":"CO-2003-6797-S","al":"Various state regulators, including the State of Connecticut Department of Banking, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Connecticut, department of banking, that found Goldman Sachs to have violated section 36B-4(b) of the act that proscribes engaging in dishonest or unethical practices in connection with the offer, sale or purchase of a security and section 36B-31-6F(b) of the regulations stating broker-dealers are required to establish, enforce, and maintain a system for supervising their employees and agents that is reasonably designed to achieve compliance with applicable securities laws and regulations.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2686},{"d":"2003-08-27","di":"2002-04-12","dr":"2003-08-27","k":"Regulatory Action","rg":"State regulator","reg":"State of Maine Department of Professional and Financial Regulation Office of Securities","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"03-103","al":"Various state regulators, including the State of Maine Department of Professional and Financial Regulation Office of Securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the state of Maine office of securities that found Goldman Sachs to have violated 32 M.R.S.A. § 10313(1)(g) that proscribes the use of dishonest or unethical practices in the securities business and 32 M.R.S.A. §10313(1)(j) that requires broker­dealers to supervise reasonably the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2687},{"d":"2003-08-25","di":"2002-04-12","dr":"2003-08-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Idaho Department of Finance","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"2003-7-21","al":"Various state regulators, including the State of Idaho Department of Finance, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Order","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Idaho Department of Finance that has found Goldman Sachs to have violated Idaho code 30-1413(7) that proscribes the use of dishonest or unethical practices in the securities business and idapa 12.01.08.119(01) that requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2688},{"d":"2003-08-25","di":"2002-04-12","dr":"2003-08-25","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Kentucky Department of Financial Institutions","san":"Cease and Desist","st":"Final","fine":311423.0,"dk":"CRD #361","al":"Various state regulators, including the Commonwealth of Kentucky Department of Financial Institutions, conducted an industry- wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Commonwealth of Kentucky Department of Financial Institutions that found Goldman Sachs to have violated KRS 292.330(13)(a)7 that proscribes the use of dishonest or unethical practices in the securities business and KRS 292.330(13)(a)9a that requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2689},{"d":"2003-08-25","di":"2002-04-12","dr":"2003-08-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington/ Department of Financial Institutions/Securities Division","san":"Cease and Desist","st":"Final","fine":454149.0,"dk":"S-03-091-03-CO01","al":"Various state regulators, including the State of Washington/ Department of Financial Institutions/Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Washington/ Department of Financial Institutions/Securities Division that found Goldman Sachs to have violated RCW 21.29.119(1)(g) in which Goldman Sachs failed to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2690},{"d":"2003-08-21","di":"2002-04-12","dr":"2003-08-21","k":"Regulatory Action","rg":"State regulator","reg":"State of New York/ Office of the Attorney General","san":"Cease and Desist","st":"Final","fine":1462158.0,"dk":"FEDERAL REFERENCE # 3243","al":"Various state regulators, including the State of New York/ Office of the Attorney General, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order (assurance of discontinuance) with the state of New York office of the attorney general relating to the violation of the martin act in connection with the company's research practices and shall comply, inter alia, with the provisions of exhibit 1 and exhibit 2, as attached with the consent order.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2691},{"d":"2003-08-08","di":"2003-05-29","dr":"2003-08-08","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"AWC C8A030063","al":"Between approximately July 1999 and September 2000, William Blair & Company,L.L.C. Failed to establish written supervisory procedures reasonably designed to achieve compliance with the NASD's free-riding and withholding interpretation in that its existing written procedures failed to require a periodic review of accounts that purchased hot issues to confirm that registered representatives had performed reasonable due diligence to determine that the account was not restricted. During the same period, stephen Elkins, a principal of William Blair & Company, L.L.C., sold hot issue securities to an individual who was registered with another member of the NASD, in his personal account and in an account in which the individual had a beneficial interest.","res":"Acceptance, Waiver & Consent(AWC)","sd":"As to William Blair & Company, L.L.C. - A fine of $2,500; as to stephen Elkins - a fine of $4,233.46, which includes disgorgement of commissions of $1,733.46","ab":"Elkins, Stephen Edward","firms":[1252],"id":2692},{"d":"2003-05-23","di":"2002-04-12","dr":"2003-05-23","k":"Regulatory Action","rg":"Other","reg":"Alaska Department of Community & Economic Development, Division of Banking, Securities and Corporations","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"04-02 S","al":"Various state regulators, including the Alaska department of community & economic development, division of banking, securities, and corporations, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Alaska department of community & economic development, division of banking, securities, and corporations that found Goldman Sachs to have violated Alaska code as 45.55.060 (a)(7) which proscribes the use of dishonest or unethical practices in the securities business and as 45.55.060 (b)(1) which states broker-dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2693},{"d":"2003-05-09","di":"2002-04-12","dr":"2003-05-09","k":"Regulatory Action","rg":"State regulator","reg":"Montana State Auditor","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"I 05-01-03-112","al":"Various state regulators, including the office of the Montana State Auditor, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Montana State Auditor that found Goldman Sachs to have violated the SEC. act of Montana § 30­10­101 et seq., mca, and § 30­10­201(13)(g), mca, which proscribes the use of dishonest or unethical practices in the securities business; and §30­10­201(13)(k), mca which states broker­dealers are required to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2694},{"d":"2003-04-24","di":"2002-04-29","dr":"2003-04-24","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000000.0,"dk":"NASD CAF030024","al":"The NYSE, the NASD and the SEC conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On April 28, 2003, without admitting or denying liability, ten investment banking firms, including GS, entered into global settlements with the SEC, the NYSE, the NASD, the New York attorney general and other states to resolve the investigations relating to equity research analyst conflicts of interest. GS was charged with violating NYSE rules 342, 401, 472 and 476, and NASD conduct rules 2110, 2210 and 3010. GS also agreed to censure by the NYSE and the NASD and to pay a total of $110,000,000. GS also agreed to adopt a set of industry-wide reforms of its research and investment banking businesses and to adopt certain restrictions on the allocations of \"hot\" IPO shares. The terms of the global settlement were entered in an order by a federal court in the southern district of New York on October 31, 2003 (civil action number 03CV2944).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2695},{"d":"2003-04-22","di":"2002-04-12","dr":"2003-04-22","k":"Regulatory Action","rg":"State regulator","reg":"State of Utah Division of Securities of the Department of Commerce.","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"SD-02-0166","al":"Various state regulators, including the Utah division of securities, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, GS entered into a consent order with the Utah division of securities that found GS to have violated Utah code §61­1­6(1)(g), which prohibits dishonest or unethical business practices, by failing to ensure that its research analysts were adequately insulated from pressures and influences from covered companies and investment banking, and Utah code § 61­1­6(1)(j) by failing reasonably to supervise its employees to ensure that its analysts were adequately insulated from pressures and influences from covered companies and investment banking. GS also agreed to adopt a set of industry-wide reforms of its research and investment banking businesses. GS has reached similar settlement agreements with many other U.S. states and territories.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2696},{"d":"2003-04-22","di":"2002-04-29","dr":"2003-04-22","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange Division of Enforcement (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":50000000.0,"dk":"HPD# 03-65","al":"The NYSE, the NASD and the SEC conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On April 28, 2003, without admitting or denying liability, ten investment banking firms, including GS, entered into global settlements with the SEC, the NYSE, the NASD, the New York attorney general and other states to resolve the investigations relating to equity research analyst conflicts of interest. GS was charged with violating NYSE rules 342, 401, 472 and 476, and NASD conduct rules 2110, 2210 and 3010. GS also agreed to censure by the NYSE and the NASD and to pay a total of $110,000,000. GS also agreed to adopt a set of industry-wide reforms of its research and investment banking businesses and to adopt certain restrictions on the allocations of \"hot\" IPO shares. The terms of the global settlement were entered in an order by a federal court in the southern district of New York on October 31, 2003 (civil action number 03CV2944).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2697},{"d":"2003-04-22","di":"2002-04-12","dr":"2003-04-22","k":"Regulatory Action","rg":"State regulator","reg":"The Securities Division of the Attorney General of the State of South Carolina","san":"Cease and Desist","st":"Final","fine":309130.0,"dk":"FILE NO. 03085","al":"Various state regulators, including The Securities Division of the Attorney General of the State of South Carolina, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with The Securities Division of the Attorney General of the State of South Carolina that found Goldman Sachs to have failed to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking under §35­1­520(2)(b)(I) of the act.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2698},{"d":"2003-03-24","di":"2003-02-24","dr":"2003-03-24","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers","san":"Censure","os":"Fine","st":"Final","fine":15000.0,"dk":"CMS030032AWC","al":"From October 2, 2001 to December 31, 2001, William Blair & Company, L.L.C., a market maker, was a party to a locked or crossed market condition prior to the market opening during the period between 9:20 and 9:29:59 A.M. Eastern time and received, in 105 instances, a trade-or-move message through selectnet. William blair, within 30 seconds of receiving such messages, failed to fill the incoming trade-or-move message for the full size of the message or move its bid down (or offer up) by a quotation increment that would have unlocked/uncrossed the market, in violation of NASD marketplace rule 4613(e)(1)(c).","res":"Decision","sd":"The fine of $15,000 was paid on March 26, 2003.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2699},{"d":"2003-03-19","di":"2003-03-19","k":"Regulatory Action","rg":"State regulator","reg":"State of New Hampshire","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"INV03-010","al":"Failure of predecessor firm wachovia securities, inc. (BD 431) to file annual audited statements within timely manner and to pay penalty of $500 for late filing.","res":"Order","sm":"The respondent wachovia securities, inc. (BD 19616)voluntarily consented to the entry of the order and to pay the penalty incurred by the former wachovia securities, inc. (BD431), which merged with first union securities, inc. on 6/15/2002 to become wachovia securities, inc. (BD19616).","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2700},{"d":"2003-01-30","di":"2002-04-12","dr":"2003-01-30","k":"Regulatory Action","rg":"State regulator","reg":"State of Iowa Securities Bureau","san":"Cease and Desist","st":"Final","fine":250000.0,"dk":"C04-12-429","al":"Various state regulators, including the State of Iowa Securities Bureau, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the Iowa securities bureau that found Goldman Sachs to have violated section 502.304(1)(g), code of Iowa (2003) that proscribes the use of dishonest or unethical practices in the securities business and section 502.304(1)(j), code of Iowa (2003) that requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2701},{"d":"2003-01-10","di":"2002-08-19","dr":"2003-01-10","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"02-MSI-21","al":"Goldman, Sachs & co. allegedly violated CBOT regulations 444.03 and 545.02 on a single occasion by netting down US Treasury bond futures and to accurately report to the CBOT. Without admitting or denying the allegations, Goldman Sachs paid a fine of $15,000.00.","res":"Settled","sm":"On 01/10/2003, Goldman Sachs sent a check in the amount of $15,000.00 to the CBOT.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2702},{"d":"2003-01-10","di":"2002-08-19","dr":"2003-01-10","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBOT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"02-MSI-21","al":"Goldman, Sachs & co.(\"GS\")allegedly violated CBOT regulations 444.03 and 545.02 on a single occasion by netting down U.S. Treasury bond futures and to accurately report to the CBOT. Without admitting or denying the allegations, GS paid a fine of $15,000.00.","res":"Settled","sm":"On 01/10/2003, GS sent a check in the amount of $15,000.00 to the CBOT.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2703},{"d":"2002-12-13","di":"2002-11-11","dr":"2002-12-13","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman Sachs consented to censure by the SEC NYSE and NASD and to the imposition of a cease and desist order by the SEC.","st":"Final","fine":550000.0,"dk":"EXCHANGE HEARING PANEL DECISION 02-223","al":"In November 2002, the SEC, NASD and NYSE alleged that five broker dealers including Goldman Sachs violated section 17(a) of the Exchange Act and rule 17A-4 hereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve e- mail communications for 3 years and/or to preserve e-mail communications for the first 2 years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of e-mail communications.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, 5 broker-dealers including Goldman Sachs consented to censure by the SEC, NASD and NYSE and to the imposition of a cease and desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its procedures regarding the preservation of e-mail communications for compliance with the federal securities laws and regulations and rules of the NASD and NYSE and to confirm within a specified period of time that it has established systems and procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2704},{"d":"2002-12-13","di":"2002-11-11","dr":"2002-12-13","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange (\"NYSE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman, Sachs & co.consented to censure by the SEC, NYSE and NASD and to the imposition of a cease-and-desist order by the SEC.","st":"Final","fine":550000.0,"dk":"EXCH HEARING PANEL DECISION 02-223","al":"In November 2002, the Securities and Exchange Commission (\"SEC\"), the national association of securities dealers (\"NASD\") and the New York Stock Exchange, inc. (\"NYSE\") alleged that five broker dealers, including Goldman Sachs violated section 17(a) of the Exchange Act and rule 17A-4 thereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve electronic mail communications for three years and/or to preserve electronic mail communications for the first two years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of electronic mail communications.","res":"Stipulation and Consent","sm":"Without admitting or denying the allegations, five broker dealers, including Goldman Sachs, consented to censure by the SEC, NASD and NYSE and to the imposition of a cease-and-desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its systems and procedures regarding the preservation of electronic mail communications for compliance with the federal securities laws and regulations and the rules of the NASD and NYSE, and to confirm within a specified period of time that it has established procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2705},{"d":"2002-12-03","di":"2002-11-11","dr":"2002-12-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman Sachs consented to censure by the SEC NYSE and NASD and to the imposition of a cease and desist order by the SEC.","st":"Final","fine":550000.0,"dk":"SEC ADM. PROCEEDING FILE NO. 3-10957","al":"In November 2002, the SEC, NASD and NYSE alleged that five broker dealers including Goldman Sachs violated section 17(a) of the Exchange Act and rule 17A-4 hereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve e- mail communications for 3 years and/or to preserve e-mail communications for the first 2 years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of e-mail communications.","res":"Order","sm":"Without admitting or denying the allegations, 5 broker-dealers including Goldman Sachs consented to censure by the SEC, NASD and NYSE and to the imposition of a cease and desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its procedures regarding the preservation of e-mail communications for compliance with the federal securities laws and regulations and rules of the NASD and NYSE and to confirm within a specified period of time that it has established systems and procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2706},{"d":"2002-12-03","di":"2002-11-11","dr":"2002-12-03","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman, Sachs & co.consented to censure by the SEC, NYSE and NASD and to the imposition of a cease-and-desist order by the SEC.","st":"Final","fine":550000.0,"dk":"SEC ADM. PROCEEDING FILE NO. 3-10957","al":"In November 2002, the Securities and Exchange Commission (\"SEC\"), the national association of securities dealers (\"NASD\") and the New York Stock Exchange, inc. (\"NYSE\") alleged that five broker dealers, including Goldman Sachs, violated section 17(a) of the Exchange Act and rule 17A-4 thereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve electronic mail communications for three years and/or to preserve electronic mail communications for the first two years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of electronic mail communications.","res":"Order","sm":"Without admitting or denying the allegations, five broker dealers, including Goldman Sachs, consented to censure by the SEC, NASD and NYSE and to the imposition of a cease-and-desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its procedures regarding the preservation of electronic mail communications for compliance with the federal securities laws and regulations and the rules of the NASD and NYSE, and to confirm within a specified period of time that it has established systems & procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2707},{"d":"2002-11-22","di":"2002-11-11","dr":"2002-11-22","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman Sachs consented to censure by the SEC NYSE and NASD and to the imposition of a cease and desist order by the SEC.","st":"Final","fine":550000.0,"dk":"AWC NO. CAF020064","al":"In November 2002, the SEC, NASD and NYSE alleged that five broker dealers including Goldman Sachs violated section 17(a) of the Exchange Act and rule 17A-4 hereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve e- mail communications for 3 years and/or to preserve e-mail communications for the first 2 years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of e-mail communications.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, 5 broker-dealers including Goldman Sachs consented to censure by the SEC, NASD and NYSE and to the imposition of a cease and desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its procedures regarding the preservation of e-mail communications for compliance with the federal securities laws and regulations and rules of the NASD and NYSE and to confirm within a specified period of time that it has established systems and procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2708},{"d":"2002-11-22","di":"2002-11-11","dr":"2002-11-22","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Goldman, Sachs & co.consented to censure by the SEC, NYSE and NASD and to the imposition of a cease-and-desist order by the SEC.","st":"Final","fine":550000.0,"dk":"AWC NO. CAF020064","al":"In November 2002, the Securities and Exchange Commission (\"SEC\"), the National Association of Securities Dealers (\"NASD\") and the New York Stock Exchange, inc. (\"NYSE\") alleged that five broker dealers, including Goldman, Sachs & co.(\"Goldman Sachs\"), violated section 17(a) of the Exchange Act and rule 17A-4 thereunder, NYSE rules 440 and 342 and NASD rules 3010 and 3110 by allegedly failing to preserve electronic mail communications for three years and/or to preserve electronic mail communications for the first two years in an accessible place, and by allegedly having inadequate supervisory systems and procedures in relation to the retention of electronic mail communications.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, five broker dealers,including Goldman Sachs, consented to censure by the SEC, NASD and NYSE and to the imposition of a cease-and-desist order by the SEC and Goldman Sachs paid a total fine of $1,650,000 ($550,000 each to the SEC, NASD and NYSE). Goldman Sachs also undertook to review its procedures regarding the preservation of electronic mail communications for compliance with the federal securities laws and regulations and the rules of the NASD and NYSE, and to confirm within a specified period of time that it has established systems& procedures reasonably designed to achieve compliance with those laws, regulations and rules.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2709},{"d":"2002-11-19","di":"2002-11-19","dr":"2002-11-19","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine","st":"Final","fine":20000.0,"dk":"NASD #CMS020212","al":"Wedbush Morgan, without admitting or denying the allegations, submitted a letter of acceptance, waiver, & consent,consenting to sanctions and the entry of findings on a few occasions that it was a party to a locked or crossed market condition prior to market opening and failed to fill an incoming trade-or-move message for the full size of the message or move its market within 30 seconds.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$20,000.00 fined","sm":"Wedbush Morgan, without admitting or denying the allegations,submitted a letter of acceptance,waiver,&consent,consenting to sanctions and the entry of findings that on a few occasions that it was a party to a locked or crossed market condition prior to market opening and failed to fill an incoming trade-or-move message for the full size of the message or move its market within 30 seconds. The firm was censured and fined $20,000.00","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2710},{"d":"2002-11-19","di":"2002-11-19","dr":"2002-11-19","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":10000.0,"dk":"NASD #CMS020236","al":"Wedbush Morgan,without admitting or denying the allegations,submitted a letter of acceptance,waiver,&consent,consenting to sanctions and the entry of findings that on a few occasions failed to display immediately customer limit orders in its public quotation,when such order was at a price which would have improved the firm's bid or offer,or when the order was priced equal to the firm's bid or offer and the national best bid or offer in such security.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$10,000.00 fined","sm":"Wedbush Morgan,without admitting or denying the allegations,submitted a letter of acceptance,waiver&consnet,consenting to sanctions and the entry of findings that on a few occasions it failed to display immediately customer limit orders in its public quotation,when such order was at a price which would have improved the firm's bid or offer,or when the order was priced equal to the firm's bid or offer and the national best bid or offer in such security.the firm was censured and fined $10,000.00.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2711},{"d":"2002-11-19","di":"2002-11-19","dr":"2002-11-19","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine","st":"Final","fine":15000.0,"dk":"NASD #CMS020210","al":"Wedbush Morgan securities failed to honor its published quotations.","res":"Acceptance, Waiver & Consent(AWC)","sd":"$15,000.00 fined","sm":"Wedbush Morgan, without admitting or denying the allegations, submitted a letter of acceptance, waiver,& consent consenting to sanctions and the entry of findings that it failed on a few occasions to honor its published quotations. The firm was censured,fined $15,000, and required to revise its written supervisory procedures relating to firm quote compliance.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2712},{"d":"2002-10-30","di":"2002-10-30","dr":"2002-10-30","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","st":"Final","fine":10000.0,"dk":"CMS020202","al":"SEC rule 11AC1-4 - without admitting or denying the allegations, the respondent member consented to the entry of findings that it failed to display immediately the customer limit orders in Nasdaq securities in its public quotation, when each such order was at a price that would have improved the firm's bid or offer in each such security; or when the order was priced equal to the firm's bid or offer and the national best bid or offer in such security, and the size of the order represented more than a de minimis change in relation to the size associated with its bid or offer in each such security.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2713},{"d":"2002-10-24","di":"2002-10-24","dr":"2002-10-24","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","st":"Final","fine":5000.0,"dk":"CMS020193","al":"NASD rule 2110 - without admitting or denying the allegations, wachovia securities, inc. consented to the entry of findings that it failed to report to the fixed income pricing system (\"FIPS\")46 transactions in FIPS securities within five minutes after execution during the period from January 1, 2001 through June 28,2001, which constitutes a pattern or practice of reporting in violation of rule 2110. The firm paid a fine of $5,000.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2714},{"d":"2002-10-23","di":"2002-09-12","dr":"2002-10-23","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"$20,000.00 fine","st":"Final","fine":20000.0,"dk":"CMS020229","al":"Goldman, Sachs & co. allegedly violated NASD conduct rule 3360 by failing to report fully its short interest position in certain securities for certain periods. Without admitting or denying the allegations, Goldman Sachs agreed to a censure and a $20,000.00 fine.","res":"Acceptance, Waiver & Consent(AWC)","sm":"AWC was accepted by the NASD on 10/23/02.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2715},{"d":"2002-08-24","di":"2002-06-25","dr":"2002-08-24","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"A fine of $7,500.00 and restitution by respondent to investors in the total amount of $1,056.00 plus interest from the date of the","st":"Final","fine":7500.0,"dk":"CMS020150 AWC","al":"Goldman, Sachs & co. (\"GS\") allegedly violated NASD rules 2110, 2320, 6130(d) and SEC rule 11AC1-4. GS allegedly failed to execute orders promptly, to use reasonable diligence to ascertain best inter-dealer market for most favorable customer price, report correct transaction symbols and to immediately display customer limit orders in its public quotation. Without admitting or denying allegations, GS consented to the entry of findings.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On June 25, 2002, without admitting or denying, Goldman, Sachs & co. submitted an AWC to the NASD and later paid a fine of $7,500 and restitution to investors in the total amount of $1,056.00 plus interest for alleged violations of NASD rules 2110, 2320, 6130(d) and SEC rule 11AC1-4. The AWC was accepted by the NASD on August 24, 2002.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2716},{"d":"2002-08-24","di":"2002-06-25","dr":"2002-08-24","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"A fine of $7,500.00 and restitution by respondent to investors in the total amount of $1,056.00 plus interest from the date of the","st":"Final","fine":7500.0,"dk":"CMS020150 AWC","al":"Goldman, Sachs & co.(\"GS\") allegedly violated NASD rules 2110, 2320, 6130(d)and SEC rule 11AC1-4, respectively, in connection with a discreet number of transactions by allegedly failing to execute orders promptly, to use reasonable diligence to ascertain best inter-dealer market for most favorable customer price, report correct transaction symbols and to immediately display customer limit orders in its public quotation. Without admitting or denying the allegations, GS consented to the entry of findings.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2717},{"d":"2002-07-23","di":"2002-05-23","dr":"2002-07-23","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $17,500.00","st":"Final","fine":17500.0,"dk":"CMS020112 AWC","al":"Goldman, Sachs & co. (\"GS\") allegedly violated NASD rule 4613(e). GS, a market maker, allegedly failed to make reasonable efforts to avoid a locked or crossed market. Without admitting or denying the allegations, GS consented to the entry of findings.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On May 23, 2002, without admitting or denying, Goldman, Sachs & co. submitted an AWC to the NASD and later paid a fine of $17,500 for alleged violations of NASD rule 4613(e). The AWC was accepted by the NASD on July 23, 2002.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2718},{"d":"2002-06-28","di":"2002-05-23","dr":"2002-06-28","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $17500.00","st":"Final","fine":17500.0,"dk":"CMS020112 AWC","al":"Goldman, Sachs & co.(\"GS\")allegedly violated NASD rule 4613(e) by allegedly failing to make reasonable efforts to avoid a locked or crossed market on certain occasions. Without admitting or denying the allegations, GS consented to the entry of findings.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2719},{"d":"2002-04-12","di":"2002-04-12","k":"Regulatory Action","rg":"State regulator","reg":"State of Indiana Securities Division","san":"Cease and Desist","st":"Final","fine":468508.0,"dk":"03-0064 CO","al":"Various state regulators, including the State of Indiana Securities Division, conducted an industry-wide, joint investigation into conflicts of interest between equity research analysts and investment banking.","res":"Other","sm":"Without admitting or denying liability, Goldman Sachs entered into a consent order with the State of Indiana Securities Division, that found Goldman Sachs to have violated ind. Code § 23­2­1­11(a)(6); 710 ind. Admin. Code 1­17­1(w) that proscribes the use of dishonest or unethical practices in the securities business and ind. Code § 23­2­1­11(a)(14); 710 ind. Admin. Code 1­17­1(v) that requires broker-dealers to supervise adequately the conduct of its employees and agents.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2720},{"d":"2002-04-04","di":"2002-04-04","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Pending","al":"Claimant allege that representative, shelly smith, made certain negligent misrepresentation inducing claimant to purchase unsuitable stocks and mutual funds. Claimant is alleging that Money Concepts Capital Corp. has breached its fiduciary duties.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2721},{"d":"2002-02-07","di":"2000-04-03","dr":"2002-02-07","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine of $5,000","st":"Final","fine":5000.0,"dk":"C07020006-AWC","al":"The NASD alleges that on or about April 3, 2000 NASD Regulation staff requested pursuant to NASD procedural rule 8210 that first union complete and return a branch office information questionnaire by April 18, 2000. First union requested and recieved an extension of the response deadline until May 12, 2000. After further communication with first union, NASD Regulation staff did not receive the requested information until March 2001. The NASD alleges that such conduct violates NASD procedural rule 8210 and NASD conduct rule 2110.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying guilt, first union securities cosented to the NASD's findings that on or about April 3, 2000 NASD Regulation staff requested pursuant to NASD procedural rule 8210 that first union complete and return a branch office information questionnaire by April 18, 2000. That first union requested and recieved an extension of the response deadline until May 12, 2000. That after further communication with first union, NASD Regulation staff did not receive the requested information until March 2001. That the NASD alleges that such conduct violates NASD procedural rule 8210 and NASD conduct rule 2110.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2722},{"d":"2002-01-28","di":"2000-04-01","dr":"2002-01-28","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc.","san":"Censure","os":"Fine of $145,000","st":"Final","fine":145000.0,"dk":"01-232","res":"Consent","sm":"Without admitting or denying any guilt, everen securities (now known as first union securities) consented to the NYSE's findings that 1. Violated exchange rule 440 and SEC regulations 240.71A-3 and 17A-4 by failing it to make and perserve required records relating to account designation and execution of customer orders, 2. Exchange rule 410 by failing to make and perserve required records regarding the timely allocation of orders to customer accounts, 3. Exchange rule 351 by failing to promptly report certain customer complaints and/or settlements to the exchange as required, 4. Exchange rule 342 in that it failed to reasonably supervise and control and provide appropriate procedures of supervision and control and establish a system of follow-up and review with respect to (a)assuring compliance with exchange rules and federal securities laws requiring the making and preservation of timely records relating to the account designation and execution of customer orders, (b) assuring that trade corrections effected by branch office managers are properly reviewed, and (c) assuring compliance with exchange rules to promptly and accuratley report customer complaints and/or settlements to the exchange.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2723},{"d":"2001-12-26","di":"2001-11-07","dr":"2001-12-26","k":"Regulatory Action","rg":"Other","reg":"Indiana","san":"Cease and Desist","st":"Final","dk":"01-0215 CD","al":"A cease and desist order was placed agains JW genesis in connection with alleged unauthorized trade by a registered representative of the firm.","res":"Vacated","sm":"State of Indiana filed Form U6 against first union securities, inc. (nka wachovia securities, LLC) instead of first union financial services, inc. (nka wachovia securities financial network, LLC).","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2724},{"d":"2001-10-10","di":"2001-08-22","dr":"2001-10-10","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"C01020054","al":"WMS was alleged to be in violation of NASD conduct rules 3110 and SEC rule 17 A-3.","res":"Acceptance, Waiver & Consent(AWC)","sd":"WMS paid fine in the amount of $2,500.","sm":"On 09/27/01, without admitting or denying the allegations, Wedbush signed an acceptance and consent to findings that on a single trade date it failed to stamp 11 manual orders promptly upon receipt and agreed to pay a fine in the amount of $2,500 to NASD reg, inc.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2725},{"d":"2001-09-17","di":"2001-09-17","dr":"2001-09-17","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Censure and fine","st":"Final","fine":50000.0,"dk":"C11010029","al":"Without admitting or denying the alleged violation. Corporate securities group accepted and consented to the entry of the following by the NASD. During 1997 and 1998, corporate securities group failed to establish an adequate supervisory system of follow-up and review to ensure review of active accounts and failed to devote sufficient resources to its supervisory system to detect and prevent unsuitable activity in customer accounts.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The acceptance, waiver and consent was made final on 9/17/2001. The firm was censured and fined $50,000.","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2726},{"d":"2001-07-02","di":"1999-10-06","dr":"2001-07-02","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Alleging Money Concepts Capital Corp. is vicariously responsible for an alleged sale of a security (promissory note) by an off- site independent contractor.","res":"Settled","sd":"Settlement in the amount of $50000.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2727},{"d":"2001-06-29","di":"1998-04-14","dr":"2001-06-29","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Clients of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropriation of assets by a deceassed principal of the third party adviser. Claimants seek recovery of alleged damages in excess of $1,015,341 jointly and severally from several parties including the firm.","res":"Settled","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2728},{"d":"2001-06-29","di":"1998-09-11","dr":"2001-06-29","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Clients of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropration of assets by a deceased principal of the third party adviser. Claimants seek recovery of alleged damages of $1,450,000 jointly and severally from several parties including the firm.","res":"Settled","sd":"See summary below (#14)","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2729},{"d":"2001-06-07","di":"2001-05-09","dr":"2001-06-07","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board of Options Exchange, Inc. (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2758.0,"dk":"N/A","al":"CBOE charged that GS violated rule 4.11, position limits.","res":"Settled","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2730},{"d":"2001-05-31","di":"2001-04-05","dr":"2001-05-31","k":"Regulatory Action","rg":"Other","reg":"International Securities Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"ISE NO. 2001-0406-01","al":"Hull Trading Company, L.L.C. Is alleged to have violated ise rule 412 (position limits)","res":"Other","ab":"Hull Trading Company,","firms":[361],"id":2731},{"d":"2001-05-25","di":"2000-05-30","dr":"2001-05-25","k":"Civil Judicial Action","san":"Restitution","st":"Final","fine":26000.0,"al":"Client of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropriation of assets by a deceased principal of the third party adviser. Claimant seek recovery of alleged damages of $99,000 jointly and severally from several parties including the firm.","res":"Settled","sd":"All claims dismissed with prejudice, no admission or finding of liability.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2732},{"d":"2001-03-08","di":"2000-08-03","dr":"2001-03-08","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":7000.0,"dk":"CMS010023","al":"First union brokerage services, inc. (BD#8112) merged into first union securities, inc. (BD#19616) on October 1, 2000 and form BDW was filed for first union brokerage services, inc. accordingly. During the time period of 9/27/1997 through 9/21/1998, first union brokerage services, inc. failed to file reports with the association of positions of 200 or more standardized option contracts held by 56 customer accounts. (Violation of NASD conduct rule 2860(b)(5)(a) for each report not filed.) First union brokerage services' failed to maintain adequate written supervisory procedures regarding the reporting of options positions. (Violation of NASD conduct rules 2110 and 3010.)","res":"Acceptance, Waiver & Consent(AWC)","sm":"First union brokerage services, inc. entered into an acceptance, waiver and consent order with the NASD Regulation, Inc. without admitting or denying the allegations stated above. This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2733},{"d":"2001-02-14","di":"2000-06-30","dr":"2001-02-14","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":32500.0,"dk":"CO5010010","al":"First union brokerage services, inc. (BD#8112) merged into first union securities, inc. (BD#19616) on October 1, 2000 and form BDW was filed for first union brokerage services, inc. accordingly. During the period from on or about 2/6/1995 through on or about 10/1/1999, first union brokerage services, inc. failed to establish and maintain adequate written procedures to supervise the sale of variable annuity contracts. During the period from on or about 2/6/1995 through on or about 8/31/1999, first union brokerage services, inc. failed to document or demonstrate that it had made reasonable efforts to obtain certain suitability information. During the period from on or about 9/24/1997 through on or about 4/22/1998, first union brokerage services, inc. allowed two individuals to perform duties as registered representatives while the registrations of these individuals were deemed inactive for failing to complete the regulatory element of the continuing education. During the period from on or about 3/13/1998 through on or about 4/15/1998, first union brokerage services, inc. failed and neglected to maintain a daily position record and documentation to support information filed in a short interest report.","res":"Acceptance, Waiver & Consent(AWC)","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2734},{"d":"2001-01-23","di":"1999-03-11","dr":"2001-01-23","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board of Options Exchange, Inc (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure and $15,000.00 fine.","st":"Final","fine":15000.0,"dk":"FILE NO. 00-0026","al":"Allegations of violations of CBOE rule 4.1 (just and equitable principles of trade) and rules 6.43, 6.74(b)(III), 6.9(d) and regulatory circular RG97-113, having to do with conduct on the floor rules, in connection with a series of trades on one business day.","res":"Decision & Order of Offer of Settlement","sm":"Matter settled without admitting or denying the violations attended.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2735},{"d":"2000-10-30","di":"2000-10-30","dr":"2000-10-30","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","dk":"C05000058","al":"The NASD alleged violations of sections 17(a)(2) and 17(a)(3) of the Securities Act and NASD rule 2110 concerning sales of portfolios of US Treasury securities for defeasance escrow at excessive, undisclosed markups to municipalities in connection with advance refundings. Further, the NASD alleged that the firm knew, or should have known, that the markups were not reasonably related to the prevailing wholesale market prices and thereby jeopardized the tax-exempt status of the bonds and diverted funds from the US Treasury.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2736},{"d":"2000-10-24","di":"2000-10-24","dr":"2000-10-24","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"First union securities, without admitting or denying any wrongdoing, was ordered to cease and desist from committing or","st":"Final","fine":100000.0,"dk":"REL. 34-43478, FILE NO. 3-10352","al":"First union securities, without admitting or denying the commission's findings, consented to a commission order finding that the firm violated the broker-dealer recordkeeping provisions of section 17a and rule 17A-3 thereunder.","res":"Consent","sm":"First union securities, without admitting or denying any wrongdoing, was ordered to cease and desist from committing or causing future violations of the broker-dealer recordkeeping provisions of the federal secuirities laws. The commission order finds that fusi failed to properly record certain terms of customer orders made in connection with the purchase and sale of U.S. Treasury securities issued through the noncompetative auction process from 1995 through 1998.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2737},{"d":"2000-10-10","di":"2000-07-24","dr":"2000-10-10","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":13000.0,"dk":"N/A","al":"Nasdr alleged that GS&co. violated NASD marketplace rule 4613(e) - locked and crossed - during the periods of June 1, 1997 through dec. 31, 1997 and July 1, 1999 through sept. 30, 1999.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2738},{"d":"2000-10-10","di":"2000-07-14","dr":"2000-10-10","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":13000.0,"dk":"CMS000202 AWC","al":"Alleged failure by GS as a market maker to make reasonable efforts to avoid a locked or crossed market by executing transactions with all market makers whose quotations would be locked or crossed, entered a bid or asked quotation which caused a locked or crosssed market condition to occur.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On July 14, 2000, GS consented to a censure and fine of $13,000 by signing a letter of acceptance, waiver and consent which was accepted on October 10, 2000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2739},{"d":"2000-10-01","di":"1998-10-15","dr":"2000-10-01","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Clients of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropriation of assets by deceased principal of the third party adviser. Claimants seek recovery of alleged damages of $95,000 jointly and severally from several parties including the firm.","res":"Dismissed","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2740},{"d":"2000-10-01","di":"2000-08-01","dr":"2000-10-01","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Client of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropriation of assets by a deceased principal of the third party adviser. Claimant seek recovery of alleged damages of $72,000 jointly and severally from several parties including the firm.","res":"Dismissed","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2741},{"d":"2000-07-24","di":"2000-07-24","dr":"2000-07-24","k":"Regulatory Action","rg":"Other","reg":"SGX-DT","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250.0,"dk":"N/A","al":"Goldman Sachs Futures Pte LTD. (a subsidiary of Goldman Sachs & Co.) failed to impose margins on one customer, violating SGX-DT rule 822-customer margins, SGX-DT rule 415(f)-failure to provide information in GSFS's monthly submission of its credit facilities obtained from financial institutions, and SGX-DT rule 3500-failure to obtain a dated disclaimer statement from one customer on SGX-DT msci taiwan stock index futures.","res":"Settled","sm":"Goldman Sachs Futures Pte LTD. (a subsidiary of Goldman Sachs & Co.) failed to impose margins on one customer, violating SGS-DT rule 822-customer margins, SGX-DT rule 415(f)-failure to provide information in GSFS's monthly submission of its credit facilities obtained from financial institutions, and SGX-DT rule 3500-failure to obtain a dated disclaimer statement from one customer on SGX-DT msci taiwan stock index futures.a 250 Singapore dollar fine was imposed for violation of SGX-DT rule 822. There were no fines imposed for violations of rules SGX-DT rule 415(f) and SGX-DT rule 3500.","ab":"Goldman Sachs Futures Pte","firms":[361],"id":2742},{"d":"2000-07-24","di":"2000-06-26","dr":"2000-07-24","k":"Regulatory Action","rg":"Other","reg":"Singapore Exchange Derivative Trading Limited","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":250.0,"al":"Goldman Sachs Futures (Singapore) pte LTD failed to impose margins on one customer, violating SGX-DT rule 822-customer margins, SGX-DT rule 415(f)-failure to provide information in the company's monthly submission of its credit facilities obtained from financial institutions, and SGX-DT rule 3500-failure to obtain a dated disclaimer statement from one customer on SGX-DT msci taiwan stock index futures.","res":"Settled","sm":"Without admitting or denying the allegations, Goldman Sachs Futures (Singapore) pte LTD paid a fine of s$250.00.","ab":"Goldman Sachs Futures","firms":[361],"id":2743},{"d":"2000-07-20","di":"2000-05-11","dr":"2000-07-20","k":"Regulatory Action","rg":"State regulator","reg":"State of Florida, Department of Banking and Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Cease and desist","st":"Final","fine":5000.0,"dk":"2970-S-6/00","al":"Southtrust securities, inc. (CRD# 17922 - merged into wachovia securities, LLC) failed to effect renewal of 7 existing registered offices with the state of Florida.","res":"Stipulation and Consent","sm":"Final order was accepted on 7/20/2000 by the state of Florida; all subject offices were promptly approved by the state.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2744},{"d":"2000-07-10","di":"2000-07-10","dr":"2000-07-10","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","os":"Fine of $7,500.","st":"Final","fine":7500.0,"dk":"C8A000039","al":"Alleged violation of NASD conduct rule 2110 and 3010(b).","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2745},{"d":"2000-06-14","di":"2000-04-17","dr":"2000-06-14","k":"Regulatory Action","rg":"Cboe","reg":"Chicago Board of Options Exchange, Inc. (\"CBOE\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"00-0015","al":"CBOE charged that GS allegedly violated exchange rule 4.1 by entering an order prior to disclosing the terms and conditions of the original order to the relevant trading crowd, as required by exchange rule 6.9(e)","res":"Settled","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2746},{"d":"2000-06-13","di":"2000-06-13","dr":"2000-06-13","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","os":"Fine of $350,000","st":"Final","fine":350000.0,"dk":"CAF000022","al":"NASD alleged that first union securities, inc. (f/k/a wheat first securities, inc.) violated section 17(a) of the Exchange Act and rules 17A-3 and 17A-4 thereunder and MSRB rules G-8, G-9 and G-27. First union's books and records failed to accurately reflect finders fees paid for municipal securities transactions over an eighteen month period from late 1991 through April, 1993.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2747},{"d":"2000-04-17","di":"2000-04-17","dr":"2000-04-17","k":"Regulatory Action","rg":"Other","reg":"Bus. Conduct Com. of the Chicago Board of Options Exchange, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"N/A","al":"CBOE charged that GS&co. allegedly violated exchange rule 4.1 by entering an order prior to disclosing the terms and conditions of the original order to the relevant trading crowd, as required by exchange rule 6.9(e).","res":"Settled","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2748},{"d":"2000-04-06","di":"2000-02-01","dr":"2000-04-06","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5204000.0,"dk":"95 CIV. 1363 (S.D.N..)(BSJ)","al":"This regulatory action was in connection with an industry-wide investigation by the SEC relating to the pricing of government securities in advance refunding transactions. Goldman, Sachs & co. was found to have violated sections 17(a)(2) and (3) of the Securities Act of 1933 in connection with pricing of government securities and was required to cease and desist from violating such provisions.","res":"Other","sm":"Goldman, Sachs & co. was ordered to make payments totaling approximately $5.1 million to the U.S. Treasury and $104,000 to two municipalities - payment was made in April 2000. Under the settlement, the lawsuit was dismissed with prejudice, and the Internal Revenue Service agreed not to challenge the tax-free nature of the refundings by virtue of the pricing of such securities.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2749},{"d":"2000-04-06","di":"2000-04-06","dr":"2000-04-06","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Cease and Desist","os":"In connection with the global settlement of an industry-wide investigation relating to the pricing of government securities in","st":"Final","fine":5204000.0,"dk":"RELS. NO. 33-7832,34-42636 FILE#3-10178","al":"As part of an industry-wide investigation relating to the pricing of government securities in advanced refunding transactions, GS joined in a global settlement pursuant to which GS, without admitting or denying the findings, consented to an SEC administrative order which found, inter alia, that GS violated sections 17(a)(2)and(3)of the Securities Exchange Act of 1933.","res":"Order","sm":"On April 6, 2000, GS joined in a global settlement resolving (I) an industry-wide investigation by the SEC relating to the pricing of government securities in advance refunding transactions, and (II) a related qui tam lawsuit purportedly brought on behalf of the U.S. entitled United States ex rel. Lissack v. Goldman, Sachs & co., et al., 95 civ. 1363 (S.D.N.Y.)(BSJ).","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2750},{"d":"2000-04-05","di":"2000-04-05","dr":"2000-04-05","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","dk":"C05000014","al":"The NASD alleged that fusi's predecessors, butcher & singer and wheat first securities, inc. violated sections 17(a)(2) and 17(a)(3) of the Securities Act and NASD rule 2001 concerning sales of portfolios of US Treasury securities for defeasance escrow at excessive, undisclosed markups to municipalities in connection with advance refundings. Further, the NASD alleged that the firm knew or should have known that the markups were not reasonably related to the prevailing wholesale market prices and thereby jeopardized the tax-exempt status of the bonds and diverted the funds from the US Treasury.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2751},{"d":"2000-02-25","di":"1999-07-29","dr":"2000-02-25","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois","san":"Other","st":"Final","fine":3000.0,"dk":"9800115","al":"The State of Illinois initiated an administrative proceding against jwgenesis financial services, inc. alleging failure to supervise registered representative, justyn feldman","res":"Settled","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2752},{"d":"2000-02-14","di":"1999-07-28","dr":"2000-02-14","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":17500.0,"dk":"N/A","al":"Nasdr alleged that GS&co. violated NASD marketplace rule 6620 and NASD conduct rules 2110 and 3010. The nasdr alleged that GS&co. untimely filed certain transactions in OTC equity securities on forms t with the NASD. The NASD also alleged that GS&co. failed to establish, maintain and enforce written supervisory procedures reasonably designed to achieve compliance with the applicable rules of the NASD relating to the reporting of transactions via form t.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On 7/28/99, nasdr alleged that GS&co. violated NASD marketplace rule 6620 and NASD conduct rules 2110 and 3010. The nasdr alleged that GS&co. untimely filed certain transactions in OTC equity securities on forms t with the NASD. The NASD also alleged that GS&co. failed to establish written procedures to achieve compliance with the applicable rules of the NASD relating to the reporting of transactions via form t. GS&co. consented to a censure and a $17,500 fine by signing an AWC on 7/28/99 - AWC was accepted on 2/14/2000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2753},{"d":"2000-02-14","di":"1999-07-28","dr":"2000-02-14","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"GS agreed to pay a $17,500.00 fine.","st":"Final","fine":17500.0,"dk":"CMS000016","al":"The NASD alleged that GS violated NASD marketplace rule 6620 and NASD conduct rules 2110 and 3010. The NASD alleged that GS untimely filed certain transactions in OTC equity securities on forms t with the NASD and GS failed to establish, maintain and enforce written supervisory procedures.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2754},{"d":"2000-02-01","di":"1999-04-15","dr":"2000-02-01","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Other","st":"Final","fine":2000.0,"dk":"E07990136","al":"Failure to sumitt 77 retail municipal securities trade reports to the MSRB during the period January 1 through April 30, 1999.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Jwgenesis Financial Group,","firms":[11025],"id":2755},{"d":"2000-01-24","di":"1999-09-15","dr":"2000-01-24","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"N/A","al":"Nasdr alleged that GS&co. violated NASD conduct rule 3360. The nasdr alleged that GS&co. failed to report its short interest position in one security.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On sept. 15, 1999, nasdr alleged that GS&co. violated NASD conduct rule 3360. The nasdr alleged that GS&co. failed to report its short interest position in one security. Without admitting or denying any violations, GS&co. consented to a $1,000 fine by signing a letter of AWC on sept. 15, 1999. The AWC was accepted on dec. 16, 1999.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2756},{"d":"2000-01-24","di":"1999-09-15","dr":"2000-01-24","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CMS990177","al":"Nasdr fined GS for alleged violations of NASD conduct rule 3360. GS allegedly failed to report its short interest position in one security.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2757},{"d":"2000-01-01","di":"2000-03-28","dr":"2000-01-01","k":"Civil Judicial Action","san":"Restitution","st":"Final","al":"Client of bankrupt third party investment adviser alleges negligence or breach of duty by applicant in connection with alleged misappropriation of assets by a deceased principal of the third party adviser. Claimant seeks recovery of alleged damages of $40,000 jointly and severally from several parties including the firm.","res":"Dismissed","sd":"None","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2758},{"d":"1999-12-17","di":"1998-02-10","dr":"1999-12-17","k":"Regulatory Action","rg":"SEC","reg":"SEC","st":"On appeal","fine":20000.0,"dk":"3-9688","al":"First union capital markets corp. (merged into wheat first securities, inc, which changed its name to first union capital markets CORP.-BD6124. First union capital markets corp. merged into the applicant.)Initially received a Wells call alleging violation of various rules and regulations in conection with execution by representatives of fucm of certifications of compliance with rule 9I-16 of the Florida administrative code. No damages are alleged. Administrative proceeding alleges failure by the firm to disclose a contingent fee arrangement with consultant in violation of financial advisory contract and Florida law and MSRB rule G-17.","res":"Decision","sm":"The decision was affirmed by the commission on August 20, 2003.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2759},{"d":"1999-12-16","di":"1999-11-08","dr":"1999-12-16","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"N/A","al":"Nasdr alleged that GS&co violated municipal securities rulemaking board (\"MSRB\") rules G-12 and G-14. The nasdr alleged that GS&co. failed to provide accurate and/or timely information regarding municipal securities trades to the national securities clearing corporation (\"NSCC\").","res":"Acceptance, Waiver & Consent(AWC)","sm":"On nov. 8, 1999, nasdr alleged that GS&co violated municipal securities rulemaking board (\"MSRB\") rules G-12 and G-14. The nasdr alleged that GS&co. failed to provide accurate and/or timely information regarding municipal securities trades to the national securities clearing corporation (\"NSCC\"). Without admitting or denying any violations, GS&co. consented to a $1,000 fine by signing an AWC. The AWC was accepted on dec. 16, 1999.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2760},{"d":"1999-12-16","di":"1999-11-08","dr":"1999-12-16","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CAF990036","al":"GS allegedly violated municipal securities rulemaking board rules G-12 and G-14. The nasdr alleged that GS failed to provide accurate and/or timely information regarding municipal securities trades to the national securities clearing corporation.","res":"Acceptance, Waiver & Consent(AWC)","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2761},{"d":"1999-12-15","di":"1998-03-09","dr":"1999-12-15","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Final","al":"Claimants alleged negligence and breach of duty by the firm in connection with alleged unsuitable investment recommendations by a principal of a third party investment adviser. Claimants seek to recoever $250,000 in damages, representing in part the unpaid balance of a judgement against thrid party investment adviser and its principals.","res":"Dismissed","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2762},{"d":"1999-09-28","di":"1999-09-28","dr":"1999-09-28","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","st":"Final","fine":3000.0,"dk":"CMS990132","al":"Respondent:entered priced orders into selectnet broadcast that were priced better than the firm's public quote without reflecting each such order in the firm's public quote;and failed to establish,maintain, and enforce adequate written supervisory procedures designed to achieve compliance with the applicable securities laws and regulations concerning the SEC's order handling rules and NASD marketplace rule 4613.(SEC rule 11AC1-1(c)(5)and NASD conduct rules 2110 and 3010).","res":"Acceptance, Waiver & Consent(AWC)","sd":"Fine of $3,000.00***04/11/2000 GS: $3,000.00 paid on 12/07/1999 - invoice NO.99-MS858.","sm":"None","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2763},{"d":"1999-08-19","di":"1999-04-23","dr":"1999-08-19","k":"Regulatory Action","rg":"Other","reg":"Securities/Futures Commission & Stock Exchange of Hong Kong","san":"Censure","os":"Prudential securities (\"PSI\") was fined HK$30,000 (approx. US $3,900). A PSI registered representative was fined HD$20,000 (approx","st":"Final","fine":6500.0,"dk":"DISCIPLINARY PROCEEDING NO. 50/99","al":"The stock exchange of Hong Kong, disciplinary committee (the\"committee\"). Disciplinary proceeding case no: 50/99. August 15, 1999. The committee and the Hong Kong securities and futures commission jointly charged prudential-bache securities (Hong Kong) limited (\"PPS(HK)\"), an affiliate of prudential securities and its dealing director, liu luk por for breach of the rules of the exchange. The substance of the charge was that during a period from December 15, 1997 to July 3, 1998, PBS(HK) had inadequate internal controls and failed to implement an appropriate system for deterring and detecting intra-day short selling by its staff, and that as a result, a former sales representative of PBS(HK), who was subsequently dismissed, had engaged in extensive short selling in his own account. The result was that the securities and futures commission issued a public reprimand to both PBS(HK) and MR. liu luk por and the stock exchange of Hong Kong issued a public censure plus a fine of HK$30,000 (approximately US$3,900) for PBS(HK) and a public censure plus a fine of HK$20,000 (approximately US$2,600) for MR. liu luk por.","res":"Other","ab":"Prudential-Bache (Hong","firms":[11025],"id":2764},{"d":"1999-08-19","di":"1999-04-23","dr":"1999-08-19","k":"Regulatory Action","rg":"Other","reg":"Securities/Futures Commission & Stock Exchange of Hong Kong","san":"Censure","os":"Prudential securities (\"PSI\") was fined HK$30,000 (approx US$3,900). A PSI registered representative was fined HK$20,000 (approx","st":"Final","fine":6500.0,"dk":"DISCIPLINARY PROCEEDING NO. 50/99","al":"The stock exchange of Hong Kong, diciplinary committee (the \"committe\"). Disciplinary proceeding case no: 50/99. August 15, 1999. The committee and the Hong Kong securities and futures commission jointly charged Prudential-Bache securities (Hong Kong) limited (\"PBS(HK)\"), an affiliate of prudential securities and its dealing director, liu luk por for breach of the rules of the exchange. The substance of the charge was that during a period from December 15, 1997 to July 3, 1998 PBS(HK)had inadequate internal controls and failed to implement an appropriate system for deterring and detecting intra-day short selling by its staff, and that as a result, a former sales representative of PBS(HK), who was subsequently dismissed, had engaged in extensive short selling in his own account. The result was that the securities and futures commission issued a public reprimand to both PBS(HK) and MR. liu luk por and the stock exchange of Hong Kong issued a public censure plus a find of HK$30,000 (approximately US$3,900) for PBS(HK) and a public censure plus a fine of HD$20,000 (approximately US$2,600) for MR. liu luk por.","res":"Other","ab":"Prudential-Bache","firms":[19616],"id":2765},{"d":"1999-07-14","di":"1999-06-01","dr":"1999-07-14","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange, Inc","san":"Censure","st":"Final","fine":120000.0,"dk":"HPD#99-91","al":"Everen securities, inc. (changed its name to first union securities, inc.) 1. Violated exchange rule 440 and SEC regs 240.17A-3 and A-4; 2. Violated rule 342.","res":"Stipulation and Consent","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2766},{"d":"1999-06-10","di":"1998-03-26","dr":"1999-06-10","k":"Civil Judicial Action","san":"Money Damages (Private/Civil Complaint)","st":"Final","fine":12211.0,"al":"Claimant allege that representative, murad zikri, made certain material misrepresentation inducing them to purchase four variable universal life insurance policies. The out of pocket losses include the lose of the first year annual premium payment of $14,142.70 for the policies. Claimant seeks to recover of alleged damages in the amount of $10,000,000.","res":"Settled","sd":"State of California arbitrator awarded the above amount.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2767},{"d":"1999-04-11","di":"1996-10-21","dr":"1999-04-11","k":"Regulatory Action","rg":"Other","reg":"Texas","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Consent order","st":"Final","fine":2500.0,"dk":"96-066","al":"The state of Texas alleged that Money Concepts Capital Corp. had failed to fully comply with rule 115.1(s) which requires all offices in Texas of a registered securities dealer where records are maintained or the supervision of registered persons take place must be registered as a branch office with the state.","res":"Withdrawn","sd":"While Money Concepts Capital Corp. had registered all representatives with the NASD, Money Concepts Capital Corp. failed to register each office as a branch office. Money Concepts Capital Corp. paid an administrative fine in the amount of $2,500. Money Concepts Capital Corp. immediately registered all offices that met the definition under rule 115.1(s) as a branch office. Money Concepts Capital Corp. further reviewed the internal compliance system to insure its compliance with Texas state operations.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2768},{"d":"1999-04-06","di":"1999-02-22","dr":"1999-04-06","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Censure and fine","st":"Final","fine":2500.0,"dk":"C02990004","al":"Respondent member executed settlement and release agreements with a public customer containing a confidentialityclause which precluded the customer from cooperating with any securities regulator absent a subpeona or court order and operated to prevent the nasdr from bringing a disciplinary action against one of the firm's former registered representatives because the customer could not cooperate with the nasdr.","res":"Acceptance, Waiver & Consent(AWC)","sm":"The AWC was accepted on 2/22/1999. The firm was censured and fined $2,500.00","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2769},{"d":"1999-03-30","di":"1999-03-03","dr":"1999-03-30","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Other","os":"Fine","st":"Final","fine":1000.0,"dk":"CMS990032AWC","al":"In three instances William Blair & Company failed to contemporaneously execute or partially execute a customer limit order after trading in the same security for its own account at prices that would have satisfied a customer limit order. Over 150 transactions were included in the review.","res":"Decision","sd":"The fine of $1000.00 was paid on May 6, 1999.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2770},{"d":"1999-03-02","di":"1999-02-25","dr":"1999-03-02","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","os":"Fine","st":"Final","fine":13000.0,"dk":"CMS990024AWC","al":"Alleged to have violated NASD conduct rules 2110 and 2320 with respect to the firm's failure to ascertain the best interdealer market in executing customer transactions. SEC rule 17A-4 and NASD conduct rule 3110 with respect to recordkeeping regulations. NASD conduct rules 2110 and IM-2110-2 with respect to execution of customer limit orders and SEC rule 11AC1-4 with respect to the firm's failure to display immediately customer limit orders.","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2771},{"d":"1998-07-31","di":"1998-07-31","dr":"1998-07-31","k":"Regulatory Action","rg":"Other","reg":"The Financial Supervisory Agency of Japan (\"Fsaj\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","dk":"FSAJ 199","al":"The fsaj instructed the Nomura Securities Co., Ltd. (\"Nomura tokyo\") and three other japanese securities companies and 9 leading japanese banks to strengthen their respective internal controls, following an industry-wide investigation by fsaj of the practice of excessively entertaining public officials. In particular fsaj instructed Nomura tokyo among others to take the following steps in order to strengthen its internal controls: (1) to enhance the awareness of compliance policies and procedures among its management and employees, (2) to implement measures designed to prevent the reoccurrence of excessive entertainment practices, (3) to improve its internal compliance systems and (4) to strengthen its internal controls on entertainment expenses. In this connection, fsaj further instructed Nomura tokyo to submit to fsaj a comprehensive operational plan setting forth specific measures in respect of (1) through (4) above and the time by with such measures would be implemented by September 30, 1998. The foregoing instructions of fsaj to Nomura tokyo were issued by way of administrative guidance based on fsaj's general supervisory power over securities companies licensed in Japan (including Nomura tokyo).","res":"Other","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2772},{"d":"1998-07-10","di":"1996-03-08","dr":"1998-07-10","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":5000.0,"dk":"C3A96009","al":"Failure to supervise, inadequate written supervisory procedures","res":"Settled","sm":"On August 8, 1997 district 3 entered a decision in which it issued a letter of caution to jwgenesis financial services, inc. the district determined that jwgenesis financial services, inc. reasonably supervised its branch managers but found that the firm did not have the requisite written supervisory procedures in place. On appeal, the national adjudicatory council reverse district 3 decision and found that jwgenesis financial services, inc. did not resonable supervise but did have proper written supervisory procedures","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2773},{"d":"1998-05-29","di":"1998-03-26","dr":"1998-05-29","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":3000.0,"dk":"C8A980036","al":"Nasdr alledged that William Blair & Company failed to file copies of final official statements and completed forms G-36(OS) with the MSRB on a timely basis; failed to accurately record certain dates of final agreements to purchase, offer or sell securities as an underwriter; failed to maintain records of the dates forms were mailed.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was notified on May 29, 1998 that the nasdr had accepted the acceptance, waiver and consent (AWC) to settle the complaint. Without admitting or denying the allegations contained in the complaint, William Blair & Company agreed to pay the fine of $3000 to settle the matter.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2774},{"d":"1998-05-29","di":"1998-03-30","dr":"1998-05-29","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":3000.0,"dk":"C8A980037","al":"Alleged violations of MSRB rule G36.","res":"Settled","sm":"3/23/2000 - corrected docket no. and date settled due to data entry error.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2775},{"d":"1998-04-23","di":"1998-04-07","dr":"1998-04-23","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":18500.0,"dk":"CMS980025","al":"Alleged violations of rules set forth under NASD conduct rules 2110 and 3010 and violations of NASD marketplace rule 4632(a).","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2776},{"d":"1998-04-01","di":"1998-04-01","dr":"1998-04-01","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":6250.0,"dk":"N/A","al":"G g y (y p p p ) nasdr alleged that GS&co. violated rule 11AC1-1(c) of the securities and Exchange Act of 1934, NASD marketplace rule 4613(b) and NASD conduct rules 2110 and 3320. The nasdr alleged that GS&co. failed to execute certain orders at GS&co.'s published bid or offer.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On April 1, 1998, nasdr censured and fined GS&co. for alleged violations of rule 11AC1-1(c) of the securities and Exchange Act of 1934, NASD marketplace rule 4613(b) and NASD conduct rules 2110 and 3320. The nasdr alleged that GS&co. failed to execute certain orders at GS&co.'s published bid or offer. Without admitting or denying any violations, GS&co. consented to a censure and $6,250 fine by signing a letter of acceptanc, waiver and consent on April 1, 1998. The AWC was accepted on April 1, 1998.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2777},{"d":"1998-04-01","di":"1997-07-03","dr":"1998-04-01","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":6250.0,"dk":"CMS 970010","al":"Nasdr alleged that GS violated rule 11AC1-1(c) of the securities and Exchange Act of 1934, NASD marketplace rule 4613(b) and NASD conduct rules 2110 and 3320. The nasdr alleged that GS failed to execute certain orders at GS published bid or offer.","res":"Settled","sm":"Without admitting or denying the allegations, GS agreed to a censure and a $6,250.00 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2778},{"d":"1998-01-13","di":"1998-01-13","dr":"1998-01-13","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Other","os":"Relief sought","st":"Final","fine":250.0,"dk":"C0970033","al":"N/a","res":"Acceptance, Waiver & Consent(AWC)","sm":"On January 13, 1998 district no. 5 notified respondent, southtrust securities,inc. (CRD 17322-merged into wachovia securities, LLC), that the letter of acceptance, waiver and consent no. C05970033 was accepted; therefore the firm was fined $250 - MSRB rule G-36 respondent member failed to file to the MSRB a Form G-36 in a timely manner and filed inaccurate forms G-36 to the MSRB ***$250.00 paid on 2/9/98, invoice no. 98-05-129***","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2779},{"d":"1997-12-15","dr":"1997-12-15","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation","san":"Civil and Administrative Penalt(ies) /Fine(s)","os":"Censure","st":"Final","fine":25000.0,"dk":"N/A","al":"Nasdr alleged that GS&co. violated municipal securities rulemaking board rule G-36 by failing to timely submit official statements and/or other documents to the MSRB as required from approximately sept. 1995 through sept. 1996.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On dec. 3, 1997, the nasdr censured and fined numerous municipal securities dealers for alleged violations of municipal securities rulemaking board rule G-36 by failing to timely submit official statements and/or other documents to the MSRB as required from approximately sept. 1995 through sept. 1996. Without admitting or denying any violations, GS&co. consented to a censure and a $25,000 fine by signing a letter of acceptance, waiver and consent on dec. 3, 1997. The AWC was accepted on dec. 15, 1997.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2780},{"d":"1997-12-15","di":"1997-11-15","dr":"1997-12-15","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":25000.0,"dk":"C10970188","al":"Goldman, Sachs & co. and numerous other municipal dealers allegedly violated municipal securities rulemaking board (\"MSRB\") rule G-36 by failing to submit required advanced refunding documentation to the MSRB and failing to timely submit official statements and/or other documents to the MSRB during the approximate period 9/95-9/96.","res":"Settled","sm":"Without admitting or denying any violations, Goldman, Sachs & co. consented to a $25,000.00 fine and a censure.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2781},{"d":"1997-12-15","di":"1995-11-14","dr":"1997-12-15","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Censure","st":"Final","fine":10000.0,"dk":"CAF970003","al":"First union capital markets corp. (merged into wheat first securities, inc., which changed its name to first union capital markets CORP.-BD6124, which merged into applicant)alleged to have violated MSRB rule G-36 by failing to submit advance refunding documents to the MSRB and by failing to timely submit official statements and/or other documents to the MSRB.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union capital markets corp's license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2782},{"d":"1997-10-07","di":"1997-09-11","dr":"1997-10-07","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"CMS970031 AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated NASD conduct rule 2110 and IM-2110-2 and SEC rule 10b - 10(a)(2).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying allegations, GS signed the AWC and paid a fine of $2000.00.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2783},{"d":"1997-07-30","di":"1997-07-30","dr":"1997-07-30","k":"Regulatory Action","rg":"Other","reg":"Ministry of Finance (\"Mof\") of Japan, Tokyo Stock Exchange and 7 Other Japanese Stock Exchanges.","san":"Other","os":"Monetary penalties/fines","st":"Final","al":"Alleged conferring of undue profits to a shareholder/client of Nomura tokyo, including discretionary securities trading for his benefit, for the purpose of rewarding him for cooperation with Nomura tokyo in ensuring the smooth conduct of an annual shareholders' meeting.","res":"Consent","sd":"On June 30, 1997, mof of Japan ordered the Nomura Securities Co., Ltd. (\"Nomura tokyo\") to suspend (1) equity related proprietary transactions including trades in stocks, warrants, convertible bonds, index futures and securities options (with certain exceptions) from August 6, 1997 to December 31, 1997, (2) all equity-related transactions (with certain exceptions) at the head office and all branch offices of Nomura tokyo from August 6, 1997 to August 12, 1997, (3) brokerage transactions in securities, index futures and securities options (with certain exceptions) by the corporate development and services department I of Nomura tokyo's head office from August 6, 1997 to December 5, 1997, (4) brokerage transactions in securities, index futures and securities options (with certain exceptions) by the sales department, corporate development and services department II, investment consulting department, and corporate services department of the head office from August 6, 1997 to September 5, 1997, (5) underwriting and bidding for japanese government bonds, municipal bonds, and bond guarantee by the japanese government (with certain exceptions) from August 6, 1997 to December 31, 1997. Also, the mof directed Nomura tokyo to implement measures to reinforce Nomura tokyo's compliance system and prevent the re occurrence of the events that led to these penalties and to report to the mof the status of implementation of such measures in writing not later than September 19, 1997. These actions were taken by the mof in view of its finding that Nomura tokyo violated Japan's securities and exchange law and the commercial code in connection with the conferring of undue profits to a shareholder/client of Nomura tokyo, including discretionary securities trading for his benefit, for the purpose of rewarding him for his cooperating with Nomura tokyo in ensuring the smooth conduct of an annual shareholders' meeting. Continued in #13...","sm":"Furthermore, on July 31, 1997, the tokyo stock exchange(\"TSE\") and seven other japanese stock exchanges similarly ordered Nomura tokyo to suspend the same transactions stated in (1) through (4) above on each such exchange for the respective same periods in light of the above-mentioned administrative sanctions imposed by the mof. Also, on August 8, 1997, the TSE fined Nomura tokyo 100 million yen for violations of the japanese securities exchange law and the commercial code. On the same date, the japanese securities dealers association (\"JSDA\") imposed a similar fine for violations of its articles of association. Both the TSE and JSDA also directed Nomura tokyo to submit reports as to the status od the implementation of the measures being taken for improving business operations and compliance.","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2784},{"d":"1997-07-02","di":"1997-03-01","dr":"1997-07-02","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","os":"Fine","st":"Final","fine":8000.0,"dk":"AWC NO. CMS970024","al":"Wheat first securities, inc. (predecessor to first union capital markets corp., which merged into the applicant) was alleged to have violated NASD conduct rules 2110, 2320 in that the firm failed to use reasonable diligence in getting a favorable price to purchase a security for a single client and violation of NASD conduct rules 2110 and 3110 in that the firm failed to create and maintain a record of the routed order in question.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to wheat first securities, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2785},{"d":"1997-06-19","di":"1997-04-15","dr":"1997-06-19","k":"Regulatory Action","rg":"State regulator","reg":"Massachusetts State Ethics Commission","san":"Civil and Administrative Penalt(ies) /Fine(s)","fine":3500.0,"dk":"N/A","al":"Massachusetts State Ethics Commission alleged that certain gifts and entertainment by Goldman, Sachs & co. personnel violated the state's conflict of interest law, G.L. C. 268a, 3 (a) - the commission found no evidence that the modest amounts involved were intended to influence any acts by the officials in question. 8 Cu e t Status e d g o ppea a","res":"Other","sm":"On June 19, 1997, the Massachusetts State Ethics Commission and Goldman, Sachs & co. (\"GS\") entered into a dispostion agreement with respect to the commission's allegations that certain gifts and entertainment by GS personnel violated the state's conflict of interest law, G.L. C. 268a, 3 (a). The commission assessed a fine of $3,500.00, although the commission expressly found no evidence that the modest amounts involved were intended to influence any acts by the officials in question.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2786},{"d":"1997-06-13","di":"1996-07-30","dr":"1997-06-13","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers Regulation, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000.0,"dk":"N/A","al":"Nasdr alleged that Goldman, Sachs & co. violated NASD marketplace rule 4613(d). The nasdr alleged that GS & co. entered quotations into the Nasdaq system that exceeded the maximum allowable spreads.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On July 30, 1996, the nasdr fined Goldman, Sachs & co. for alleged violations of NASD marketplace rule 4613(d). The nasdr alleged that GS & co. entered quotations into the Nasdaq system that exceeded the maximum allowable spreads. Without admitting or denying any violations, Goldman, Sachs & co. consented to a $4,000 fine by signing a letter of acceptance, waiver and consent on August 19, 1996. The AWC was accepted on June 13, 1997.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2787},{"d":"1997-06-11","di":"1997-04-23","dr":"1997-06-11","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CMS960195 AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated SEC rule 10B-6A","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying allegations, GS signed the AWC and paid a fine of $1000.00.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2788},{"d":"1997-05-13","di":"1995-12-22","dr":"1997-05-13","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"CMS960098AWC","al":"Alleged violation of rules set forth under part IV(a)4, (a)2(a), and part IV(a) and part IV(b) of fips rules and article III, section 1 of the association's rules of fair practice.","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2789},{"d":"1997-04-23","di":"1997-04-23","dr":"1997-04-23","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2000.0,"dk":"CMS960204 AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated marketplace rule 4613(e).","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying allegations, GS signed the AWC and paid a fine of $2000.00.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2790},{"d":"1997-04-23","di":"1996-12-12","dr":"1997-04-23","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"AWC NO. CMS960220","al":"Wheat first securities, inc. (predecessor to first union capital markets corp., which merged into the applicant) was alleged to have violated NASD conduct rules 2110 and IM-2110-2 by placing terms and conditions on a client order not imposed by the client when routing the order through its computer system.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to wheat first securities, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2791},{"d":"1997-01-15","di":"1997-01-15","dr":"1997-01-15","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia, State Corporation Commission","san":"Denial","st":"Final","dk":"N/A","al":"The affiliate was denied registration as an investment advisor by the Commonwealth of Virginia state corporation commission, division of securities and retail franchising, on January 15, 1997. This denial was based upon the fact that the statutory deadline for submitting all information that was necessary to complete applicant's application for registration had expired. Therefore, this denial was not based upon any misconduct or unlawful activity by the affiliate.","res":"Other","sm":"Application was never resubmitted.","ab":"American Skandia","firms":[11025,19616],"id":2792},{"d":"1996-12-27","di":"1996-09-17","dr":"1996-12-27","k":"Regulatory Action","rg":"Other","reg":"Idaho Department of Finance","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"1996-7-74","al":"First union brokerage services, inc. was alleged to have engaged in the offer and/or sale of securities to Idaho residents.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2793},{"d":"1996-11-06","di":"1993-12-09","dr":"1996-11-06","k":"Regulatory Action","rg":"State regulator","reg":"Pennsylvania Securities Commission","san":"Censure","os":"Bar for 30 days from selling limited partnership interests except publicly traded limited partnerships.","st":"Final","fine":100000.0,"dk":"9504-01LC","al":"Failure to supervise; violation of section 305(a)(VII) of the pa Securities Act.","res":"Consent","sd":"The fine of $100000.00 and costs of $28550.24 was paid 10/30/1998.","sm":"Janney Montgomery Scott, without admitting or denying the allegations, consented to the issuance of and accepted the findings of fact, conclusions of law and order of the Pennsylvania Securities Commission in connection with the sale to Pennsylvania residents of certin limited partnerships.","ab":"Janney Montgomery Scott LLC","self":true,"firms":[463],"id":2794},{"d":"1996-09-12","di":"1996-08-05","dr":"1996-09-12","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5000.0,"dk":"N/A","al":"NASD alleged that GS&co. violated marketplace rule 6240 and conduct rule no. 2110 by failing to report certain fips transactions during the period 5/1/95 - 4/18/96 and failing to report in a timely manner certain transactions during the time period 6/15/95 - 7/19/95.","res":"Consent","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2795},{"d":"1996-08-12","di":"1996-07-15","dr":"1996-08-12","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CMS960029AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated article III, section 1 and 42 of the NASD rules of fair practice.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying the allegations, GS signed the AWC and paid a fine of $ 1,000.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2796},{"d":"1996-07-31","di":"1996-06-17","dr":"1996-07-31","k":"Regulatory Action","rg":"Other","reg":"The Chicago Board of Trade (\"CBT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"FILE NO. 95-EX-24","al":"CBT alleged that Goldman, Sachs & co. violated CBT rules and regulations with respect to segregated and secured accounts maintained with third party banks for the custody of customer futures margin.","res":"Settled","sm":"Without admitting or denying any violations, Goldman, Sachs & co. consented to pay a $10,000.00 fine.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2797},{"d":"1996-07-17","di":"1996-06-13","dr":"1996-07-17","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Trade (\"CBT\")","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"FILE NO. 95-EX-24","al":"CBT alleged that Goldman, Sachs & co. violated CBT rules and regulations with respect to segregated and secured accounts maintained with third party banks for the custody of customer futures margin.","res":"Consent","sm":"On July 17, 1996, Goldman, Sachs & co. consented to pay the CBT a $10,000 fine for the alleged violation of CBT rules and regulations with respect to segregated and secured accounts maintained with third party banks for the custody of customer futures margin.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2798},{"d":"1996-05-07","di":"1996-05-07","dr":"1996-05-07","k":"Regulatory Action","rg":"Other","reg":"Singapore International Monetary Exchange Limited","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":11000.0,"dk":"N/A","al":"The simex determined that Goldman Sachs Futures Pte LTD. (a subsidiary of Goldman, Sachs & co.) violated rules 525 and 527 by failing to prepare and time stamp a customer order and being a party to a prearranged trade.","res":"Settled","sm":"On May 7, 1996, the simex determined that Goldman Sachs Futures Pte LTD. (a subsidiary of Goldman, Sachs & co.) violated rules 525 and 527 by failing to prepare and time stamp a customer order and being a party to a prearranged trade.Goldman Sachs Futures Pte ltd.was fined and paid 11,000 Singapore dollars.","ab":"Goldman Sachs Futures Pte","firms":[361],"id":2799},{"d":"1996-04-25","di":"1995-10-25","dr":"1996-04-25","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","st":"Final","fine":1000.0,"dk":"CMS950174AWC","al":"The complaint alleged that William Blair & Company violated section C3C of the rules of fair practice and procedure for soes and article III, section 1 of the NASD rules of fair practice by effecting 11 transactions via soes between February and June 1994, when trades were not eligible for such execution.","res":"Acceptance, Waiver & Consent(AWC)","sd":"The firm was notified on March 15, 1996 that the NASD had accepted the acceptance, waiver and consent to settle the complaint. Without admitting or denying the allegations contained in the complaint, William Blair & Company agreed to settle the matter. The fine was paid April 25, 1996","sm":"During a routine examination conducted in September 1994, district staff reviewed the soes trading. The NASD alleged that four series of transactions executed during that period were based on a single investment decision. The firm executed approximately 2000 soes transactions during the period in question.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2800},{"d":"1996-04-25","di":"1995-11-15","dr":"1996-04-25","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Censure","st":"Final","fine":8000.0,"dk":"CMS950122","al":"Alleged violation of rules set forth under part v, section 2(d) of schedule to the association's by-laws concerning quotations entered in the Nasdaq system that exceeded the parameters for the maximum allowable spread.","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2801},{"d":"1996-04-19","di":"1996-03-15","dr":"1996-04-19","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CMS950125 AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated article III, section 1 of the NASD rules of fair practice.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying allegations, GS signed the AWC and paid a fine of $1000.00.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2802},{"d":"1996-04-17","di":"1995-07-18","dr":"1996-04-17","k":"Regulatory Action","rg":"State regulator","reg":"State of Alabama","san":"Cease and Desist","st":"Final","fine":1500.0,"dk":"CD-95-0069","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which merged into first union capital markets corp., which merged with applicant)alleged to have violated section 8-6-3(a) of the code of Alabama of 1975 for transacting business in the state while unregistered.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2803},{"d":"1996-04-08","di":"1996-03-21","dr":"1996-04-08","k":"Regulatory Action","rg":"State regulator","reg":"Vermont Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5500.0,"dk":"96-026-S","al":"First union capital markest corp. (merged into wheat first securities, inc., which changed its name to first union capital markets CORP.-BD6124)alleged to have transacted business as an unregistered broker/dealer in the state under the mistaken belief that the Securities Act provided an exemption from broker/dealer registration for financial and institutional investor accounts.","res":"Consent","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union capital markets corp's license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2804},{"d":"1996-03-22","di":"1995-12-11","dr":"1996-03-22","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico","san":"Censure","st":"Final","fine":1000.0,"dk":"96-96-998","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which merged into first union capital markets corp., which merged into applicant)alleged to have failed to timely disclose a state action by Virginia on the form ADV. The amount of the fine was not shown.","res":"Consent","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2805},{"d":"1996-03-19","di":"1996-01-10","dr":"1996-03-19","k":"Regulatory Action","rg":"State regulator","reg":"State of New Jersey","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":10000.0,"dk":"N/A","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which merged into first union capital markets corp., which merged into applicant)alleged to have conducted securities transactions in or from the State of New Jersey without being properly registered.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2806},{"d":"1996-02-14","di":"1996-02-01","dr":"1996-02-14","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Massachusetts","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"R-95-269","al":"First union brokerage services, inc. was alleged to have engaged in the unsolicited offer and/or sale of securities to Massachusetts residents.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2807},{"d":"1995-12-15","di":"1995-09-20","dr":"1995-12-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Kansas","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1500.0,"dk":"96E055","al":"First union brokerage services,inc. was alleged to have engaged in the offer and sale of securities to Kansas residents prior to registration as a broker/dealer in the State of Kansas.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2808},{"d":"1995-11-08","di":"1995-11-08","dr":"1995-11-08","k":"Regulatory Action","rg":"Other","reg":"Commonwealth of Virginia","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":153000.0,"dk":"N/A","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which was merged into first union capital markets corp., which merged into applicant) alleged to have conducted sales of asset management services prior to registration as an investment advisor","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2809},{"d":"1995-10-31","di":"1995-09-25","dr":"1995-10-31","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"CMS940130AWC","al":"NASD alleged that Goldman, Sachs & co. (\"GS\") violated rule 11 AC1-1(c) of the Securities Exchange Act of 1934, part v, section 2(b) of schedule d and article III, sections 1 and 6 of NASD rules.","res":"Acceptance, Waiver & Consent(AWC)","sm":"Without admitting or denying allegations, GS signed the AWC and paid a fine of $1000.00.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2810},{"d":"1995-10-15","di":"1995-10-15","dr":"1995-10-15","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":5300.0,"dk":"N/A","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which merged into first union capital markets corp., which merged into applicant)alleged to have conducted sales of asset management services prior to registration as an investment advisor","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2811},{"d":"1995-09-25","di":"1995-06-01","dr":"1995-09-25","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":2500.0,"dk":"N/A","al":"NASD alleged that Goldman, Sachs & co. violated rule 11AC1-1(c) of the Securities Exchange Act of 1934, part v, section 2(b) of schedule d to the NASD by-laws and artcle III, section 1 and 6 of the NASD's rules of fair practice.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On June 1, 1995, without admitting or denying, Goldman, Sachs & co. submitted a letter of acceptance, waiver and consent to the NASD and later paid a fine of $2,500 for alleged violations of rule 11AC1-1(c) of the Securities Exchange Act of 1934, part v, section 2(b) of schedule d to the NASD by-laws and artcle III, section 1 and 6 of the NASD's rules of fair practice, on June 9, 1994 (CMS950026 AWC). The AWC was accepted by the NASD on sept. 25, 1995.","ab":"Goldman Sachs & Co. LLC","self":true,"firms":[361],"id":2812},{"d":"1995-09-18","di":"1995-03-01","dr":"1995-09-18","k":"Regulatory Action","rg":"State regulator","reg":"Texas State Securities Board","san":"Reprimand","os":"$12500 fine","st":"Final","fine":12500.0,"dk":"CEN-1056","al":"Rendered investment advice through use of unregistered agents","res":"Consent","sd":"Eagle consented to order and paid fine","ab":"Eagle Asset Management; Eagle Asset Management Inc","self":true,"firms":[110653,174904],"id":2813},{"d":"1995-08-09","di":"1994-12-14","dr":"1995-08-09","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Other","st":"Final","fine":1000.0,"dk":"C3A940061","al":"Failure to supervise, failure to timely file Form U-5","res":"Other","sm":"The claims against the firm for failure to supervise were dismissed in their entirety","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2814},{"d":"1995-05-12","di":"1994-09-28","dr":"1995-05-12","k":"Regulatory Action","rg":"Other","reg":"US Securities & Exchange Commission","san":"Cease and Desist","st":"Final","fine":30000.0,"dk":"3-8493","al":"Failure to reasonable supervise candia mauser, a broker, to prevent her from violating sections 15(a) of the Exchange Act.","res":"Settled","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2815},{"d":"1995-05-09","di":"1995-05-03","dr":"1995-05-09","k":"Regulatory Action","rg":"State regulator","reg":"State of New Mexico","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":835.0,"dk":"95-95-998-158(UN)","al":"First union brokerage services, inc. was alleged to have engaged in the unsolicited offer and/or sale of securities to New Mexico residents.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2816},{"d":"1995-05-05","di":"1995-05-05","dr":"1995-05-05","k":"Regulatory Action","rg":"State regulator","reg":"State of Minnesota","san":"Denial","st":"Final","fine":1500.0,"dk":"N/A","al":"Signet financial services, inc. (predecessor to bowles hollowell connor, which merged into first union capital markets corp., which merged into applicant)alleged deficiencies in broker/dealer application.","res":"Order","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to signet financial services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2817},{"d":"1995-04-18","di":"1995-04-18","dr":"1995-04-18","k":"Regulatory Action","rg":"Other","reg":"U S Securities & Exchange Commission","san":"Cease and Desist","st":"Final","dk":"3-8672","al":"Meridian Investment company (registered investment advisor) was alleged to have failed to take steps to fully disclose as certain the potential for conflict of interest between the firm and its clients in connection with an investment of client funds made by the firm.","res":"Settled","ab":"Meridian Investment","firms":[11025],"id":2818},{"d":"1995-02-23","di":"1995-02-23","dr":"1995-02-23","k":"Regulatory Action","rg":"State regulator","reg":"Vermont Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1350.0,"dk":"95-001-S","al":"First union brokerage services, inc. was alleged to have transacted business as an unregistered broker/dealer in the state.","res":"Settled","sm":"This DRP filed in error. Should not have been disclosed on BD19616. Disclosure relates to predecessor broker dealer whose BD was withdrawn. BD19616 did not succeed to first union brokerage services, inc.'s license.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2819},{"d":"1994-12-12","di":"1993-06-03","dr":"1994-12-12","k":"Regulatory Action","rg":"State regulator","reg":"Tennessee Securities Division","san":"Other","os":"Administrative","st":"Final","fine":20000.0,"al":"The division alleged that William Blair & Company's affiliate, William Blair Mutual funds, inc. sold unregistered mutual fund shares in Tennessee between July 1991 and October 1992. The value of the securities allegedly totalled $30,500 in 20 transactions.","res":"Settled","sd":"After disputing the division's allegations for a period of 18 months, William Blair & Company agreed to settle the matter and paid a fine of $20,000.","sm":"William Blair & Company vigorously opposed the divisions allegations that unregistered shares had been sold in Tennessee. An application was filed during the routine renewal process in advance of the funds expiration. Eight months after the renewal was submitted, the division deemed it incomplete for insufficient filing fees.","ab":"William Blair Mutual","firms":[1252],"id":2820},{"d":"1993-06-29","di":"1994-09-14","dr":"1993-06-29","k":"Regulatory Action","rg":"Other","reg":"Connecticut","san":"Other","st":"Final","fine":1000.0,"dk":"ST-93-2429-S","al":"Money Concepts Capital Corp. d/b/a Money concepts advisory service opened a single account in the dynamic asset allocation service to a client in Connecticut before registered in Connecticut as an investment adivsor as required by Connecticut section 36-474 (c) of the act.","res":"Stipulation and Consent","sd":"Money concepts agreed to review WSPS and compliance procedures to detect and prevent violations of the CT uniform Securities Act as required by section 36-474(c).","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2821},{"d":"1993-06-08","di":"1993-02-04","dr":"1993-06-08","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers","san":"Censure","st":"Final","fine":7000.0,"dk":"C8A930009","al":"The complaint alleged that the firm sold shares of hot issue securities to persons associated with a broker dealer in contravention of the NASD interpretation on free-riding and withholding. The sales allegedly violated article III, section 1 of the NASD rules of fair practice. The complaint did not identify any actual or alleged damages.","res":"Acceptance, Waiver & Consent(AWC)","sd":"An offer of settlement was submitted to the district business conduct committee. The offer was accepted and the firm was censured and fined $7,000. The fine was paid on June 8, 1993","sm":"The DBCC noted that the violations were not intentional and that the firm did not realize that the customers involved would be considered restricted under the interpretation.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2822},{"d":"1992-01-16","di":"1992-01-16","dr":"1992-01-16","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Other","os":"Civil and administrative penalty/fine","st":"Final","fine":10000.0,"dk":"NONE","al":"Violated applicable books and records requirements in connection with certain primary distributions of debt securities of one or more of the following government sponsored entities: FHLB, FFCBFC fnma, FHLMC, and student loan marketing association. Spedifically violated rules 17(a), 17(a)(3), and 17(a)(4) of the Securities Exchange Act of 1934.","res":"Settled","sm":"SEC instituted proceedings against southtrust securities, inc. (CRD# 17922 - merged into wachovia securities, LLC) and at least 97 other firms, each of which was a broker and/or dealer.","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2823},{"d":"1992-01-01","di":"1992-01-01","dr":"1992-01-01","k":"Regulatory Action","rg":"Other","reg":"U S Securities & Exchange Commission","san":"Cease and Desist","st":"Final","fine":100000.0,"dk":"N/A","al":"Violations of CFR part 404 promulgated pursuant to section 15c with the primary distribution of certain unsecured debt securities issued by governmental sponsored enterprises.","res":"Settled","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2824},{"d":"1991-12-31","di":"1991-12-31","dr":"1991-12-31","k":"Regulatory Action","rg":"Other","reg":"The Securities and Futures Authority","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":60000.0,"dk":"N/A","al":"The sfa alleged that between May 13, 1991 and October 2, 1991 affiliate and john brackley failed to comply with sfa principles of statements of principle. The affiliate was alleged to have engaged in a course of conduct in relation to property futures transactions traded on the London fox; brackley was alleged to have failed to act with due care, skill and diligence and to avoid in engaging in a course of conduct which did not conform with the high standards of market conduct.","res":"Settled","sm":"Without admitting or denying the alleged violations, the affiliate agreed to pay a fine in the amount of $60,000. John brackley was reprimanded. In addition, the sfa stated that there was no intention on the part of the affiliate to violate sfa rules, infringe applicable market standards or create any false impression of the market in property futures.","ab":"Bache Financial Deriatives","firms":[11025,19616],"id":2825},{"d":"1991-12-02","di":"1991-12-02","dr":"1991-12-02","k":"Regulatory Action","rg":"Other","reg":"The Fair Trade Commission of Japan","san":"Prohibition","st":"Final","dk":"N/A","al":"On December 2, 1991, The Fair Trade Commission of Japan imposed a prohibition on the Nomura Securities Co., Ltd. against future violations of article 19 of the antimonopoly law in connection with loss compensation.","res":"Other","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2826},{"d":"1991-11-06","di":"1991-07-26","dr":"1991-11-06","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"91-51","al":"The NYMEX alleged that affiliate had placed certain customer orders on the floor of the NYMEX which were improperly time- stamped, and had allegedly failed to maintain accurate records. As a result, the complaint alleged that affiliate had violated NYMEX rules 8.50(a) and 6.18(a).","res":"Settled","sm":"Affiliate settled this matter by agreeing to a fine of $15,000 and to update its policies and procedures designed to achieve compliance with aforementioned rules.","ab":"Dryden Nominees (Hong","firms":[19616],"id":2827},{"d":"1991-10-21","di":"1991-10-21","dr":"1991-10-21","k":"Regulatory Action","rg":"Other","reg":"The Japan Securities Dealers Association","san":"Other","os":"Monetary penalties/fines","st":"Final","fine":682157.28,"dk":"N/A","al":"Violations of article 24, paragraph 1, subparagraph 4 of the association's articles of association (principles of fair and equitable trade), in connection with excessive sales promotion and with loss compensation.","res":"Consent","sd":"In October 21, 1991, The Japan Securities Dealers Association (\"association\") imposed a fine of 75 million yen based upon the Nomura Securities Co., LTD (\"TNSC\") for violation of article 24, paragraph 1, subparagraph 4 of the association's articles of association (principles of fair and equitable trade), in connection with excessive sales promotion; and imposed a fine of 5 million yen upon TNSC for violation of article 24, paragraph 1, subparagraph 4 of the association's articles of association in connection with loss compensation. (Converted japanese yen to US dollars using conversion rate as of March 20, 2007.)","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2828},{"d":"1991-10-11","di":"1991-10-11","dr":"1991-10-11","k":"Regulatory Action","rg":"Other","reg":"The Tokyo Stock Exchange (\"Exchange\")","san":"Suspension","os":"Monetary penalties/fines","st":"Final","fine":468943.17,"dk":"N/A","al":"Violation of article 59 of the constitution of the exchange (violation of just and equitable principles of trade) in connection with loss compensation and in connection with excessive sales promotion.","res":"Consent","sd":"The exchange imposed a fine of 5 million yen upon the Nomura Securities Co., Ltd. (\"TNSC\") for violation of article 59 of the constitution of the exchange (violation of just and equitable principles of trade) in connection with loss compensation; and imposed a four week and a six week suspension upon certain branch offices and certain sales departments of TNSC and imposed a fine of 50 million yen in connection with excessive sales promotion. (Converted japanese yen to US dollars using conversion rate as of March 20, 2007.)","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2829},{"d":"1991-10-08","di":"1991-10-08","dr":"1991-10-08","k":"Regulatory Action","rg":"Other","reg":"The Ministry of Finance of Japan (\"Mof\")","san":"Suspension","st":"Final","dk":"N/A","al":"Violation of ministerial ordinance concerning rules, etc. of soundness of securities companies, article 3, paragraph 7 in connection with excessive sales promotion and for violation of directives from the director-general of securities bureau of mof dated December 26, 1989 in connection with loss compensation.","res":"Decision","sd":"The mof imposed a 4 week and a 6 week suspension upon certain branch offices and sales & research departments of the Nomura Securities Co., Ltd. (\"TNSC\") for violation ministerial ordinance concerning rules, etc. of soundness of securities companies, article 3, paragraph 7 in connection with excessive sales promotion and ordered TNSC to conduct a review of its internal measures; and imposed a one week suspension upon the corporate service division of TNSC for violation of directives from the director-general of the securities bureau of the mof dated December 26, 1989 in connection with loss compensation.","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2830},{"d":"1991-07-26","di":"1991-07-26","k":"Regulatory Action","rg":"Other","reg":"New York Mercantile Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":15000.0,"dk":"91-51","al":"The NYMEX alleged that affiliate had placed certain customer orders on the floor of the NYMEX which were improperly time- stamped, and had allegedly failed to maintain accurate records. As a result, the complaint alleged that affiliate had violated NYMEX rules 8.50(a) and 6.18(a).","res":"Settled","sm":"Affiliate settled this matter by agreeing to a fine of $15,000 and to update its policies and procedures designed to achieve compliance with aforementioned rules at affiliate.","ab":"Dryden Nominees (Hong","firms":[11025],"id":2831},{"d":"1991-07-10","di":"1991-07-10","dr":"1991-07-10","k":"Regulatory Action","rg":"Other","reg":"The Japan Securities Dealers Association (\"Association\")","san":"Other","os":"Monetary penalties/fines","st":"Final","fine":85295.12,"dk":"N/A","al":"Violation of article 8 of fair business practice regulations no. 9 (regulations concerning solicitation for investment and management of customer accounts by association members) and for violation of article 24, paragraph 1, subparagraph 4 of the association's articles of association (principles of fair and equitable trade) in connection with payments for loss compensation; and for violation of article 24 , paragraph 1, subparagraph 4 of the association's articles of association in connection with dealings with a japanese crime organization.","res":"Consent","sd":"On July 10, 1991, the association imposed a fine of 5 million yen upon the Nomura Securities Co., LTD (\"TNSC\") for violation of article 8 of fair business practice regulations no. 9 (regulations concerning solicitation for investment and management of customer accounts by association members) and for violation of article 24, paragraph 1, subparagraph 4 of the association's articles of association in connection with payments for loss compensation; and imposed a fine of 5 million yen upon TNSC for violation of article 24, paragraph 1, subparagraph 4 of the association's articles of association in connection with dealings with a japanese crime organization. (Converted japanese yen into US dollars using conversion rate as of March 20, 2007.)","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2832},{"d":"1991-07-08","di":"1991-07-08","dr":"1991-07-08","k":"Regulatory Action","rg":"Other","reg":"The Tokyo Stock Exchange","san":"Other","os":"Monetary penalties/fines","st":"Final","fine":42642.1,"dk":"N/A","al":"Violation of article 59 of the constitution of the exchange (violation of the just and equitable principles of trade).","res":"Consent","sd":"The Tokyo Stock Exchange imposed a fine of 5 million yen upon the Nomura Securities Co., Ltd. (converted japanese yen to US dollars using conversion rate as of March 20, 2007.)","sm":"The event or proceeding occurred more than ten years ago","ab":"Nomura Securities Co., Ltd.","firms":[7897],"id":2833},{"d":"1991-07-01","di":"1991-07-01","dr":"1991-07-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Maryland Securities Division","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"91-0115","al":"On 7/1/91, the State of Maryland Securities Division approved the application of Benjamin Securities, Inc. for registration as a BD upon the execution of a consent order and payment of an administrative fine of $1,000.00 for transacting securities in Maryland prior to registration.","res":"Consent","sd":"On 7/1/1991 the Maryland securities divison approved the application of Benjamin Securities, Inc. for registration as a BD upon the execution of a consent order and payment of an administrative fine of $1,000.00.","ab":"Benjamin Securities, Inc.","self":true,"firms":[7754],"id":2834},{"d":"1990-11-02","di":"1990-11-02","dr":"1990-11-02","k":"Regulatory Action","rg":"Other","reg":"National Association of Securities Dealers, Inc.","san":"Other","os":"Relief sought","st":"Final","fine":2500.0,"dk":"NEW-779-AWC","al":"Failure to develop written supervisory procedures.","res":"Acceptance, Waiver & Consent(AWC)","sm":"On November 2, 1990 the letter of acceptance, waiver and consent no. NEW-779-AWC (district no. 5) submitted by respondents southtrust securities, inc. (CRD#17922 - merged into wachovia securities, LLC),joseph c. Marfoglio, charles j. Smith and james d hooks was accepted; therefore they are censured and fined $2500 jointly and severally - (article III, sections 1, 21, 27 and 33, appendix 3 of the rules of fair practice and MSRB rule G-3 in that respondent member, acting through respondents marfoglio and smith, failed to make the required deposit in its special reserve bank account; failed to properly conduct a quarterly security examination, count and verification; failed to prepare and keep current an accurate securities position record; failed to prepare an accurate computation of net capital; respondent member, acting through respondent marfoglio, filed to develop and implement written supervisory procedures; and respondent member, acting through respondents marfoglio and hooks, failed to properly registere an individual as a municipal securities principal. ***$2,500 j&s paid on 11/20/90, invoice #90-05-1262***","ab":"Wells Fargo Clearing Services, LLC","self":true,"firms":[19616],"id":2835},{"d":"1990-09-26","di":"1990-09-26","dr":"1990-09-26","k":"Regulatory Action","rg":"State regulator","reg":"Commonwealth of Virginia, Division of Securities","san":"Other","os":"Compromise and settlement order","st":"Final","fine":1000.0,"al":"Firm allegedly failed to submit audited financial statements within ten days of publication as required by section 13.1-518.1 of the Virginia Securities Act.","res":"Other","sd":"Firm consented to a compromise and settlement order proposed by the division and was fined $1000.00.","sm":"William blair sent financials to the division on March 14, 1990 and again on July 24, 1990. On August 27, 1990 blair sent a thrid copy to the division at its request. On September 14, 1990, the division notified blair of the receipt and alleged that blair had violated section 13.1-518.1 of the Virginia Securities Act. Blair consented after the estimated expense exceeded the amount of the propsed fine. Regulatory action is over 10 years old.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2836},{"d":"1989-03-30","di":"1989-03-30","dr":"1989-03-30","k":"Regulatory Action","rg":"NYSE","reg":"New York Stock Exchange","st":"Final","fine":1000.0,"al":"Due to age of this filing no other informations were provided.","res":"Decision","sd":"Fine of $1000.00 on 03/30/1989","sm":"07/02/1990 SEC litigation, actions and proceedings bulletin for the quarter ending 06/30/1989 (volume 55,bulletin 02,page 256)discloses: the New York Stock Exchange fined Wedbush Morgan securities inc. $1,000.00 on March 30,1989 based on a violation of exchange rule 132.30 and failure to submit audit trail data in order to qualified clearing agency regarding stock transactions for the weeks of 9/12 and 10/17/88.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2837},{"d":"1989-03-29","di":"1989-03-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois","san":"Censure","st":"Final","dk":"NONE","al":"Failure to file ifs capital's financial condition report within the 60 day filing period.","res":"Consent","sd":"Ifs capital entered a stipulation to enter consent order of censure. Ifs capital received a consent order of censure whereby, we resolved the matter without formal hearing; we admitted to the jurisidiction of the secretary of state of il and consented to the entry of the consent order; we submit to the secretary of state a nortarized affidavit subscribing the steps and procedures implemented to prevent similiar violations of the act. The formal hearing on the matter was vacated without further procedding.","sm":"Ifs capital entered a stipulation to enter consent order of censure. Ifs capital received a consent order of censure whereby, we resolved the matter without formal hearing; we admitted to the jurisdiction of the secretary of state of il and consented to the entry of the consent order; we submit to the secretary of state a nortarized affidavit subscribing the steps and procedures implemented to prevent similiar violations of the act. The formal hearing on teh matter was vacated without further procedding.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2838},{"d":"1989-03-29","di":"1989-03-29","dr":"1989-03-29","k":"Regulatory Action","rg":"State regulator","reg":"State of Illinois","san":"Censure","st":"Final","fine":500.0,"dk":"H8900196","al":"Failure to file ifs capital's financial condition report within the 60 day filing period.","res":"Consent","sd":"Ifs capital entered a stipulation to enter consent order of censure. Ifs capital received a consent order of censure whereby, we resolved the matter without formal hearing; we admitted to the jurisidiction of the secretary of state of il and consented to the entry of the consent order; we submit to the secretary of state a nortarized affidavit subscribing the steps and procedures implemented to prevent similiar violations of the act. The formal hearing on the matter was vacated without further procedding.","ab":"Money Concepts Capital Corp","self":true,"firms":[12963],"id":2839},{"d":"1988-07-01","di":"1988-07-01","dr":"1988-07-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Oregon","san":"Cease and Desist","st":"Final","fine":1000.0,"dk":"E8-37","al":"State of Oregon alleged that three agents of WMS were not properly registered to conduct business in Oregon.","res":"Order","sd":"Disposition resulted in a fine of $1000.00 of which was paid in July 1988.","sm":"State of Oregon alleged that three agents of WMS were not properly registered to conduct business in state. WMS resolved the matter by consenting to the entry of a cease and desist order and a fine of $1,000.00","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2840},{"d":"1988-03-31","di":"1984-02-22","dr":"1988-03-31","k":"Regulatory Action","rg":"Other","reg":"National Associattion of Securities Dealers, Inc.","st":"Final","fine":50000.0,"dk":"SEA-334","al":"Failure to supervise","res":"Decision","sd":"$50,000 paid on 4/24/89 -deposit NO.009","sm":"5/29/85:complaint #SEA-334 filed 2/22/84 by district NO.1 alleging violations of article III,sections 1,2,15 article IV,section 5 of the rules of fair practice and MSRB rules G-17 and G-19 in that respondent member failed to comply with NASD's formal written requests for information made pursuant to article IV, section 5 of the rules of fair practice***decision rendered 4/4/85,wherein respondent member is censured,fined $50,000 and is directed to provide to the committee what supervisory procedures have been implemented to prevent a recurrence of the violations within 90 days from the date of the decision; allegations of violations of MSRB rules G-17 and G-19 as contained in the sixth cause of complaint were dismissed***4/18/85, appealed to board.***decision rendered 3/20/86,wherein sanctions as to the member, jones and parker are affirmed. Allegations of failure to supervise with regard to cause two and three are dismissed with regard to the respondents member and templeton in that the board determined that he purposely failed to inform the firm of his discretionay authority and that it was the branch manager's failure to supervise jones that prevented the firm from fulfilling its supervisory responsibility. 5/7/86 -applealed to the SEC. 4/12/88- SEC news digest issue 88-61 dated 3/31/88- the SEC affirmed sanctions imposed by the NASD on Wedbush. The SEC found, as had the NASD,that,in 1980-1982, the firm failed to exercise proper supervision over two salesmen in its bellevue, Washington branch office and that the firm improperly delayed furnishing the NASD with requested information during the NASD's investigationof the salesmen's activities.(REL.34-25504)***$50,000 paid on 4/24/89- deposit NO.009","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2841},{"d":"1987-11-30","di":"1987-11-30","dr":"1987-11-30","k":"Regulatory Action","rg":"State regulator","reg":"State of Idaho","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":4000.0,"dk":"1987-7-56","al":"WMS offered and sold securities in state without broker/dealer and agent registration; offered and sold securities in state which securities were not registered or exempt; failed to exercise sufficient compliance and supervision over its agents and activities in state.","res":"Order","sd":"WMS submitted broker/dealer and agent registration applications and paid fine of $4,000.00 within ten days of order.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2842},{"d":"1987-11-01","di":"1987-11-01","dr":"1987-11-01","k":"Regulatory Action","rg":"State regulator","reg":"State of Georgia","san":"Cease and Desist","st":"Final","fine":1250.0,"dk":"50-87-9561","al":"State of Georgia alleged that WMS and agent effect two sales transactions while the agent was not registered with the state.","res":"Order","sd":"Matter was resolved by WMS and the agent agreeing to an order to prohibition and settlement and reimbursement to the state of their $1,250.00 costs.","sm":"State of Georgia alleged that WMS and agent effected two sales transactions while the agent was not registered with the state. Matter was resolved by WMS and the agent agreeing to an order to prohibition and settlement and reimbursement to the state of their $1,250.00 costs.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2843},{"d":"1987-02-05","di":"1987-02-05","dr":"1987-02-05","k":"Regulatory Action","rg":"NASD","reg":"NASD (now FINRA)","san":"Other","st":"Final","fine":250.0,"dk":"MS-483-AWC (A)","al":"Failure to report its Nasdaq volume in 9 securities on May 28, 1986 and 11 securities on October 31, 1986","res":"Acceptance, Waiver & Consent(AWC)","ab":"Wells Fargo Advisors Financial Network, LLC","self":true,"firms":[11025],"id":2844},{"d":"1985-05-29","di":"1985-02-22","dr":"1985-05-29","k":"Regulatory Action","rg":"Other","reg":"Chicago Board of Options Exchange","san":"Civil and Administrative Penalt(ies) /Fine(s)","st":"Final","fine":1000.0,"dk":"CBOE FILE NUMBER 85-0011","al":"During the period from September 6, 1983 through June 28, 1984, William Blair & Company allegedly permitted ten public customers to engage in listed option transactions prior to their accounts being approved by a registered options principal","res":"Other","sd":"Fine was paid on May 29, 1985 in the amount of $1000.00.","ab":"William Blair & Company L.L.C.","self":true,"firms":[1252],"id":2845},{"d":"1979-03-09","di":"1978-02-06","dr":"1979-03-09","k":"Regulatory Action","rg":"State regulator","reg":"State of Colorado","san":"Cease and Desist","st":"Final","fine":2000.0,"dk":"7B9NRU204","al":"WMS's predecessor, Wedbush, noble, cook inc., was subject of a cease and desist order. Wedbush had failed to include in its registration renewal packet a copy of its latest audited financial statement and a check in the amount of $70.00. WMS's application for renewal had also included application for two employees who were domiciled in Colorado but inadvertently had failed to have their signatures notarized.","res":"Stipulation and Consent","sd":"As a result of these inadvertent failures to include all the necessary documents, the State of Colorado issued a cease and desist order until such documents were submitted and properly notarized. WMS provided documents and paid a fine of $2,000.00 on 3/14/1978.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2846},{"d":"1978-07-31","di":"1977-03-17","dr":"1978-07-31","k":"Regulatory Action","rg":"SEC","reg":"SEC","san":"Undertaking","st":"Final","dk":"3-5197","al":"The SEC alleged that from January 1977 through March 1978, First Options of Chicago, inc. (\"FOC\") extended credit to accounts that exceeded the equity in the accounts and failed to promptly liquidate existing positions in said accounts, in violation of sections 7(a), 7(b), 7(c) and 15(c)(3) of the Securities Exchange Act, and sections 3 and 4 of FRB regulation t.","res":"Order","sm":"Foc undertook to (1) maintain and implement procedures for compliance with regulation t, (2) comply with sections 7(c)(2), 15(c) (3) and 17(a)(3) of the Exchange Act and rules 17A-3, 15C3-1(c)(2)(x)(f) and (g) thereunder, and (3) adopt, maintain and implement procedures to assure that these undertakings are carried out.","ab":"First Options of Chicago,","firms":[361],"id":2847},{"d":"1978-01-23","di":"1978-01-23","dr":"1978-01-23","k":"Regulatory Action","rg":"State regulator","reg":"State of Washington","san":"Cease and Desist","st":"Final","dk":"SD-133-77","al":"State of Washington alleges Wedbush from offering unregistered securities in violation of RCW 21.20.140 by its policy of paying interest on its customers' free credit balances.","res":"Order","sd":"WMS and its agents will not engage in the general solicitation of customers by advertisement of its interest payment policy nor use said interest payment policy as an inducement to a prospective customer. Wedbush will include with current periodic statements reasonable perfunctory notice describing its interest payment policy.","sm":"In 1976 Wedbush advertised in the State of Washington that it paid interest on customer's balances intended for re-investment. The State of Washington deemed this advertising as an offering of unregistered securities. On January 23, 1978, the state and firm entered into a stipulation that the firm will not engaged in the general solicitation of customers by advertising of its interest payment policy and will include with current customer periodic statements reasonable perfunctory notice describing its interest payment policy.","ab":"Wedbush Securities Inc.","self":true,"firms":[877],"id":2848},{"k":"Regulatory Action","rg":"Other","reg":"( g g g y y )","ab":"Chapin, Kenneth, Edward; Laquey, Phillip, Brooks; Rubarth, Robert, Alan; Sherman, Christopher,; Wells Fargo Clearing Services, LLC","self":true,"firms":[793,19616,149777],"id":2849},{"k":"Regulatory Action","rg":"FINRA","reg":"FINRA","sm":"No Information Filed","ab":"Brokers Financial","firms":[137080],"id":2850}]}