Wells Fargo Advisors: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• In the past ten years, have you or any advisory affiliate: been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
• In the past ten years, have you or any advisory affiliate: been charged with any felony?
• In the past ten years, have you or any advisory affiliate: been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
• In the past ten years, have you or any advisory affiliate: been charged with a misdemeanor listed in Item 11.B.(1)?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have made a false statement or omission?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have made a false statement or omission?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?
• Has any self-regulatory organization or commodities exchange ever: disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
• F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?
• G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
• (1) Has any domestic or foreign court: in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
• (1) Has any domestic or foreign court: ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
• (1) Has any domestic or foreign court: ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?
• (1) Has any domestic or foreign court: Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?

Actions about the firm (189)

1. Apr 13, 2026
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure, undertaking · Fine: $125,000 · Begun Apr 13, 2026 · Resolved Apr 13, 2026 · Acceptance, Waiver & Consent(AWC) · Docket NO. 2019062519601

   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.

   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.

2. Jan 8, 2026
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $1.2M · Begun Jan 8, 2026 · Resolved Jan 8, 2026 · Acceptance, Waiver & Consent(AWC) · Docket NO. 2022073287901

   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.

   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.

3. Aug 11, 2025
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $275,000 · Begun Aug 11, 2025 · Resolved Aug 11, 2025 · Acceptance, Waiver & Consent(AWC) · Docket NO. 2023078410201

   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.

   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.

4. Jul 14, 2025
   Regulatory Action: State of California Department of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Examination costs · Fine: $2,500 · Begun Apr 28, 2025 · Resolved Jul 14, 2025 · Order · Docket FILE NO. PLBS 11444-C

   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.

   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.

5. May 19, 2025
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $150,000 · Begun May 19, 2025 · Resolved May 19, 2025 · Acceptance, Waiver & Consent(AWC) · Docket NO. 2021073472601

   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.

   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.

6. Dec 20, 2024
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $900,000 · Begun Dec 20, 2024 · Resolved Dec 20, 2024 · Acceptance, Waiver & Consent(AWC) · Docket NO. 2019062573101

   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.

   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.

7. Dec 20, 2024
   Regulatory Action: SEC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure · Fine: $900,000 · Begun Dec 20, 2024 · Resolved Dec 20, 2024 · Order · Docket FILE NO. 3-22373

   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.

   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.

8. Sep 12, 2024
   Regulatory Action: FINRA FinalSanctions: Disgorgement; Fine; censure; restitution; and applicable interest · Fine: $400,000 · Begun Sep 12, 2024 · Resolved Sep 12, 2024 · Acceptance, Waiver & Consent(AWC) · Docket 2019061442702

   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.

   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.

9. Sep 5, 2023
   Regulatory Action: State of Maine, Office of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,000 · Begun Sep 5, 2023 · Resolved Sep 5, 2023 · Consent · Docket 2023-46

   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.

   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.

10. May 20, 2022
    Regulatory Action: SEC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure · Fine: $7.0M · Begun May 20, 2022 · Resolved May 20, 2022 · Order · Docket ADMINISTRATIVE PROCEEDING FILE 3-20866

    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.

    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

11. Dec 20, 2021
    Regulatory Action: FINRA FinalSanctions: Censure; Restitution · Begun Dec 20, 2021 · Resolved Dec 20, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2016049188701

    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.

12. Dec 13, 2021
    Regulatory Action: FINRA FinalSanctions: Censure; Fine and restitution · Fine: $550,000 · Begun Dec 13, 2021 · Resolved Dec 13, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2016050947801

    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.

13. Dec 6, 2021
    Regulatory Action: FINRA FinalSanctions: Censure; Civil fine · Fine: $2.2M · Begun Dec 6, 2021 · Resolved Dec 6, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2020066327501

    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).

    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.

14. Nov 25, 2020
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $75,000 · Begun Nov 25, 2020 · Resolved Nov 25, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2017054001501

    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.

    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.

15. Nov 4, 2020
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $300,000 · Begun Nov 4, 2020 · Resolved Nov 4, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2016051352401

    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

16. Sep 2, 2020
    Regulatory Action: FINRA FinalSanctions: Censure; Restitution, other, and civil and administrative penalty/fines · Fine: $625,000 · Begun Sep 2, 2020 · Resolved Sep 2, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2016052124001

    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

    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.

17. Aug 28, 2020
    Regulatory Action: FINRA FinalSanctions: Restitution; Fine · Fine: $350,000 · Begun Aug 28, 2020 · Resolved Aug 28, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2015045713304

    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

    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.

18. Jan 29, 2020
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $175,000 · Resolved Jan 29, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2017053034301

    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.

19. Aug 26, 2019
    Regulatory Action: Massachusetts Securities Division FinalSanctions: Undertaking; Cease and desist, censure, civil and administrative fine · Fine: $450,000 · Begun Aug 26, 2019 · Resolved Aug 26, 2019 · Consent · Docket 2018-0090

    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.

20. Mar 11, 2019
    Regulatory Action: SEC FinalSanctions: Disgorgement; Censure, cease and desist · Begun Mar 11, 2019 · Resolved Mar 11, 2019 · Order · Docket 3-19102

    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.

    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.

21. Jun 25, 2018
    Regulatory Action: SEC FinalSanctions: Other; N/a · Fine: $4.0M · Begun Jun 25, 2018 · Resolved Jun 25, 2018 · Order · Docket 3-18556

    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.

    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.

22. Apr 13, 2018
    Regulatory Action: State of Nevada Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $8,000 · Begun Apr 13, 2018 · Resolved Apr 13, 2018 · Order · Docket CI15-011 AND CI15-013

    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

23. Dec 21, 2017
    Regulatory Action: State of Illinois, Illinois Securities Department FinalSanctions: Other; Notice of hearing · Begun Dec 17, 2017 · Resolved Dec 21, 2017 · Consent · Docket 1500252

    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.

    Notice of hearing was issued December 21, 2017. Consent order was issued December 21, 2017.

24. Dec 7, 2017
    Regulatory Action: FINRA FinalFine: $20,000 · Begun Dec 7, 2017 · Resolved Dec 7, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2016049334801

    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.

    The firm was censured and fined $20,000.

25. Nov 13, 2017
    Regulatory Action: SEC FinalSanctions: Cease and Desist; Censure, civil money penalty · Fine: $3.5M · Begun Nov 13, 2017 · Resolved Nov 13, 2017 · Order · Docket 3-18279

    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.

    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.

26. Nov 6, 2017
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $30,000 · Begun Nov 6, 2017 · Resolved Nov 6, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2016051812801

    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.

    The firm was censured and fined $30,000. Fines paid in full on November 17, 2017.

27. Apr 7, 2017
    Regulatory Action: FINRA FinalFine: $20,000 · Begun Apr 7, 2017 · Resolved Apr 7, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2016049925401

    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.

    The firm was censured, fined $20,000 and required to pay restitution in the total amount of $4,543.08, plus interest.

28. Feb 16, 2017
    Regulatory Action: Missouri FinalSanctions: Other; Monetary fine - $24,672.17 to the Missouri secretary of state investor education and protection fund · Fine: $25,672 · Begun Feb 16, 2017 · Resolved Feb 16, 2017 · Consent · Docket AP-17-01

    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)

    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.

29. Oct 20, 2016
    Regulatory Action: FINRA FinalFine: $42,500 · Begun Oct 20, 2016 · Resolved Oct 20, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2015046578401

    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.

    N/a

30. Jun 28, 2016
    Regulatory Action: Vermont Department of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $300,000 · Begun Jun 28, 2016 · Resolved Jun 28, 2016 · Consent · Docket 16-25-S

    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).

    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.

31. Sep 11, 2015
    Regulatory Action: Commonwealth of Virginia FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $150,000 · Begun Sep 11, 2015 · Resolved Sep 11, 2015 · Order · Docket SEC-2014-00035

    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.

32. Aug 3, 2015
    Regulatory Action: FINRA FinalSanctions: Censure; Fine · Fine: $500,000 · Begun Aug 3, 2015 · Resolved Aug 3, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2012033568901

    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

33. Jul 6, 2015
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Begun Jul 6, 2015 · Resolved Jul 6, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2014042689901

    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.

34. May 6, 2015
    Regulatory Action: FINRA FinalFine: $35,000 · Begun May 6, 2015 · Resolved May 6, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2012035222801

    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.

    The firm was censured, fined $35,000, and undertakes to revise its WSPS to address the deficiencies described in the AWC.

35. Dec 18, 2014
    Regulatory Action: FINRA FinalBegun Jul 15, 2014 · Resolved Dec 18, 2014 · Other · Docket 20100212725

    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.

    ******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.

36. Sep 22, 2014
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $5.0M · Begun Sep 22, 2014 · Resolved Sep 22, 2014 · Order · Docket 3-16153

    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.

    See sanction details in 12.b.

37. Jul 15, 2014
    Regulatory Action: FINRA FinalFine: $10,000 · Begun Jul 15, 2014 · Resolved Jul 15, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2012033330501

    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.

38. Jun 2, 2014
    Regulatory Action: FINRA FinalFine: $25,000 · Begun Jun 2, 2014 · Resolved Jun 2, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2010023976502

    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.

39. Dec 23, 2013
    Regulatory Action: FINRA FinalFine: $20,000 · Begun Dec 23, 2013 · Resolved Dec 23, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2009020171701

    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.

40. Nov 18, 2013
    Regulatory Action: FINRA FinalFine: $5,000 · Begun Nov 18, 2013 · Resolved Nov 18, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2011028036801

    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.

41. Sep 12, 2013
    Regulatory Action: FINRA FinalFine: $150,000 · Begun Sep 12, 2013 · Resolved Sep 12, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2012031047501

    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.

42. Jul 2, 2013
    Regulatory Action: FINRA FinalFine: $35,000 · Begun Jul 2, 2013 · Resolved Jul 2, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2011026083001

    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.

43. Jun 4, 2013
    Regulatory Action: FINRA FinalSanctions: Other; NA · Fine: $1.2M · Begun Jun 4, 2013 · Resolved Jun 4, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2008014350501

    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.

44. Apr 9, 2013
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and undertaking · Fine: $50,000 · Begun Apr 9, 2013 · Resolved Apr 9, 2013 · Acceptance, Waiver & Consent(AWC) · Docket 2010022380001

    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.

45. Feb 27, 2013
    Regulatory Action: New York Department of Financial Services FinalSanctions: Other; Stipulation · Fine: $50,000 · Begun Feb 27, 2013 · Resolved Feb 27, 2013 · Stipulation and Consent · Docket 2012-0184-S

    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.

46. Feb 12, 2013
    Regulatory Action: Florida Office of Financial Regulation ("Ofr") FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $30,000 · Begun Feb 12, 2013 · Resolved Feb 12, 2013 · Order · Docket 0672-S-9/12

    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.

47. May 1, 2012
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure restitution · Fine: $2.1M · Begun May 1, 2012 · Resolved May 1, 2012 · Acceptance, Waiver & Consent(AWC) · Docket 20090191139

    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.

48. Mar 12, 2012
    Regulatory Action: State of Maryland Attorney General - Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $50,000 · Begun Mar 12, 2012 · Resolved Mar 12, 2012 · Consent · Docket 2011-0312 (AMENDED)

    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.

49. Oct 24, 2011
    Regulatory Action: FINRA FinalSanctions: Censure; Monetary fine of $350,000.00 · Fine: $350,000 · Begun Oct 24, 2011 · Resolved Oct 24, 2011 · Acceptance, Waiver & Consent(AWC) · Docket 20090206307

    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.

    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.

50. Sep 27, 2011
    Regulatory Action: FINRA FinalSanctions: Other; Please archive / withdraw this amendment no sanctions were proposed. · Fine: $3.2M · Begun Sep 27, 2011 · Resolved Sep 27, 2011 · Withdrawn · Docket 20090184210

    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.

    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

51. Sep 20, 2011
    Regulatory Action: Pennsylvania Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Wachovia securities, LLC is ordered to pay $150,000.00 to the commonwealth of Pennsylvania within 30 days of the date of this · Fine: $150,000 · Begun Sep 20, 2011 · Resolved Sep 20, 2011 · Settled · Docket 2010-03-23

    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.

    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.

52. Jun 21, 2011
    Regulatory Action: Florida Office of Financial Regulation FinalSanctions: Cease and Desist; Administrative fine · Fine: $65,000 · Begun Jun 21, 2011 · Resolved Jun 21, 2011 · Stipulation and Consent · Docket 0154-SR-5/11

    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.

    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.

53. Jun 17, 2011
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $20,000 · Begun Jun 17, 2011 · Resolved Jun 17, 2011 · Acceptance, Waiver & Consent(AWC) · Docket 2009020728001

    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.

54. May 4, 2011
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure undertakings · Fine: $1.0M · Begun May 4, 2011 · Acceptance, Waiver & Consent(AWC) · Docket 2010022921801

    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.

    AWC accepted on May 4, 2011

55. May 2, 2011
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $23,000 · Begun May 2, 2011 · Resolved May 2, 2011 · Acceptance, Waiver & Consent(AWC) · Docket 2006005324201

    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.

    The firm sent the $23,000.00 fine to FINRA on 05/13/2011.

56. May 2, 2011
    Regulatory Action: State of New Hampshire Department of State Bureau of Securities Regulations FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $289,022 · Begun May 2, 2011 · Resolved May 2, 2011 · Consent · Docket ADMINISTRATIVE CONSENT ORDER: INV- 2009000015

    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.

57. Apr 28, 2011
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $58,000 · Begun Apr 28, 2011 · Resolved Apr 28, 2011 · Acceptance, Waiver & Consent(AWC) · Docket 2007008011601

    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.

    The firm sent the $58,000.00 fine to FINRA on 05/11/2011.

58. Mar 23, 2011
    Regulatory Action: State of Ohio Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $814,455 · Begun Mar 23, 2011 · Resolved Mar 23, 2011 · Consent · Docket ADMINISTRATIVE CONSENT ORDER - DIVISION ORDER NO. 11-015

    The state of Ohio has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

59. Mar 1, 2011
    Regulatory Action: State of Mississippi, Office of the Secretary of State, Securitties and Charities Division (Division) FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,000 · Begun Mar 1, 2011 · Resolved Mar 1, 2011 · Other · Docket MOU 03/01/2011

    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.

    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.

60. Jan 21, 2011
    Regulatory Action: State of Delawre Department of Justice Division of Securities FinalSanctions: Undertaking · Fine: $1,746 · Begun Jan 21, 2011 · Resolved Jan 21, 2011 · Settled · Docket CASE NO. 09-03-03

    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

61. Dec 29, 2010
    Regulatory Action: Connecticut FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $75,000 · Begun Dec 29, 2010 · Resolved Dec 29, 2010 · Consent · Docket CO-10-7710-S

    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

62. Dec 20, 2010
    Regulatory Action: FINRA FinalSanctions: Other · Fine: $12,500 · Begun Dec 20, 2010 · Resolved Dec 20, 2010 · Acceptance, Waiver & Consent(AWC) · Docket 20080155897-01

    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.

63. Nov 18, 2010
    Regulatory Action: Indiana Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution to nancy moore in the amount of $495.84 · Fine: $8,000 · Begun Nov 18, 2010 · Resolved Nov 18, 2010 · Consent · Docket 10-0271 CA

    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).

    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.

64. Oct 19, 2010
    Regulatory Action: State of Alaska; Department Commerce, Community, and Economic Development; Division of Banking and Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $129,131 · Begun Oct 19, 2010 · Resolved Oct 19, 2010 · Consent · Docket ADMINISTRATIVE CONSENT ORDER NO. 10-07-S

    The state of Alaska has alleged that wachovia securities misrepresented the sale of auction rate securities to customers

65. Jul 15, 2010
    Regulatory Action: State of Conecticut Department of Banking FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $863,341 · Begun Jul 15, 2010 · Resolved Jul 15, 2010 · Consent · Docket CO-10-7568-S

    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.

66. Jul 14, 2010
    Regulatory Action: State of Hawaii Department of Commerce and Consumer Affairs FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $211,620 · Begun Jul 14, 2010 · Resolved Jul 14, 2010 · Consent · Docket SEU-2008-069

    State of Hawaii alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

67. Jun 18, 2010
    Regulatory Action: State of Louisiana - Office of Financial Institutions - Commissioner of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $596,363 · Begun Jun 18, 2010 · Resolved Jun 18, 2010 · Consent · Docket OIF-2010-001

    Stateof Louisiana has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

68. May 11, 2010
    Regulatory Action: FINRA FinalSanctions: Censure; Monetary fine · Fine: $25,000 · Begun May 11, 2010 · Resolved May 11, 2010 · Acceptance, Waiver & Consent(AWC) · Docket 2007009356502

    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.

    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

69. Mar 29, 2010
    Regulatory Action: Office of the Secretary of State Illinois Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.7M · Begun Mar 29, 2010 · Resolved Mar 29, 2010 · Consent · Docket 08-00202

    The state of Illinois has alleged that wachovia securities misrepresented the sale of auction rate securities (ARS) to customers.

70. Mar 11, 2010
    Regulatory Action: State of Arkansas Securities Commissioner FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $238,386 · Begun Mar 11, 2010 · Resolved Mar 11, 2010 · Consent · Docket S-09-024-09-CO01

    Stateof Arkansas has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

71. Jan 15, 2010
    Regulatory Action: State of Wisconsin Department of Financial Institutions Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $457,904 · Begun Jan 15, 2010 · Resolved Jan 15, 2010 · Decision · Docket S-09137(EX)

    State of Wisconsin has alleged that wachovia securities misrepresented the sale of auction rate securities (ARS) to customers.

72. Jan 4, 2010
    Regulatory Action: U.S. Virgin Islands - Office of the Lieutenant Governor - Division of Banking and Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $116,748 · Begun Jan 4, 2010 · Resolved Jan 4, 2010 · Consent · Docket 01-09

    U.S. virgin islands has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

73. Nov 3, 2009
    Regulatory Action: State of West Virginia Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $170,767 · Begun Nov 3, 2009 · Resolved Nov 3, 2009 · Consent · Docket 98-44964

    The state of West Virginia has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

74. Sep 17, 2009
    Regulatory Action: Division of Securities Utah Department of Commerce FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $247,273 · Begun Sep 17, 2009 · Resolved Sep 17, 2009 · Consent · Docket SD-09-0043

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

75. Sep 16, 2009
    Regulatory Action: District of Columbia Department of Insurance and Banking FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $311,765 · Begun Sep 16, 2009 · Resolved Sep 16, 2009 · Consent · Docket SB-09-02

    The District of Columbia has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

76. Aug 28, 2009
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $350,000 · Begun Aug 28, 2009 · Resolved Aug 28, 2009 · Acceptance, Waiver & Consent(AWC) · Docket 2005002169202

    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.

77. Aug 18, 2009
    Regulatory Action: State of New Mexico Regulation and Licensing Department Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $221,610 · Begun Aug 18, 2009 · Consent · Docket 09-09-007040

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.

78. Aug 12, 2009
    Regulatory Action: Commonwealth of Virginia State Corporation Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Resolved Aug 12, 2009 · Consent · Docket SEC-20900044 ARS

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.

79. Aug 11, 2009
    Regulatory Action: Pennsylvania Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.5M · Begun Aug 11, 2009 · Resolved Aug 11, 2009 · Consent · Docket 2008-04-16

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.

80. Aug 8, 2009
    Regulatory Action: State of South Dakota Department of Revenue & Regulation Division of Securities FinalSanctions: Other; Order to show cause · Fine: $21,000 · Begun Aug 7, 2008 · Resolved Aug 8, 2009 · Consent · Docket N/A

    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.

    By letter dated 9/1/2010 wfa notified the state that it had completed all of its obligations under the consent order.

81. Aug 8, 2009
    Regulatory Action: State of South Dakota Department of Revenue & Regulation Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Payment of cost of investigation · Fine: $21,000 · Begun Aug 8, 2009 · Resolved Aug 8, 2009 · Consent · Docket CONSENT ORDER

    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.

    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.

82. Jul 30, 2009
    Regulatory Action: Iowa Insurance Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $191,289 · Begun Jul 30, 2009 · Resolved Jul 30, 2009 · Consent · Docket 64477

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer.

83. Jun 29, 2009
    Regulatory Action: State of Oregon Division of Finance and Corporate Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $397,235 · Begun Jun 29, 2009 · Resolved Jun 29, 2009 · Consent · Docket S-09-0022

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

84. Jun 23, 2009
    Regulatory Action: State of Wyoming Secretary of State Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $176,315 · Begun Jun 23, 2009 · Resolved Jun 23, 2009 · Consent · Docket 09-05

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

85. Jun 22, 2009
    Regulatory Action: State of Idaho FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $191,049 · Begun Jun 22, 2009 · Resolved Jun 22, 2009 · Consent · Docket 2009-7-08

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

86. Jun 18, 2009
    Regulatory Action: State of Illinois FinalSanctions: Other · Fine: $50,000 · Begun May 18, 2007 · Resolved Jun 18, 2009 · Order · Docket 0600669

    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

    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

87. Jun 9, 2009
    Regulatory Action: State of Kansas FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $633,090 · Begun Jun 9, 2009 · Resolved Jun 9, 2009 · Consent · Docket 09 E 012

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

88. Jun 4, 2009
    Regulatory Action: State of Nebraska FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $298,818 · Begun Jun 4, 2009 · Resolved Jun 4, 2009 · Consent · Docket N/A

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

89. May 26, 2009
    Regulatory Action: Alabama Securities Commission FinalSanctions: Other; Consent order · Fine: $683,141 · Begun May 26, 2009 · Resolved May 26, 2009 · Consent · Docket CO-2009-0011

    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

90. May 22, 2009
    Regulatory Action: Tennessee Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $449,851 · Begun May 22, 2009 · Resolved May 22, 2009 · Consent · Docket 09-003 SI 2008-010

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

91. May 14, 2009
    Regulatory Action: Commonwealth of Kentucky FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $315,300 · Begun May 14, 2009 · Resolved May 14, 2009 · Consent · Docket NO. 2009-AH-032

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

92. May 11, 2009
    Regulatory Action: Minnesota Department of Commerce FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $387,791 · Begun May 11, 2009 · Resolved May 11, 2009 · Consent · Docket FILE 11200

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

93. May 6, 2009
    Regulatory Action: State of Indiana Office of the Secretary of State Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $509,629 · Begun May 6, 2009 · Resolved May 6, 2009 · Consent · Docket 09-0082 CO

    The state of Indiana has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

94. May 1, 2009
    Regulatory Action: FINRA FinalFine: $1.4M · Begun May 1, 2009 · Resolved May 1, 2009 · Acceptance, Waiver & Consent(AWC) · Docket 2007010181101

    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.

95. Apr 22, 2009
    Regulatory Action: State of Rhode Island FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $131,566 · Begun Apr 22, 2009 · Resolved Apr 22, 2009 · Consent · Docket 09-110

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

96. Apr 20, 2009
    Regulatory Action: State of Colorado Securities Commissioner FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $664,614 · Begun Apr 20, 2009 · Resolved Apr 20, 2009 · Consent · Docket 09-L-11

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

97. Apr 17, 2009
    Regulatory Action: State of Florida Office of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.7M · Begun Apr 17, 2009 · Resolved Apr 17, 2009 · Consent · Docket 0420-S-2/09

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

98. Apr 14, 2009
    Regulatory Action: State of Maine Department of Professional and Financial Regulation Office of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $237,916 · Begun Apr 14, 2009 · Resolved Apr 14, 2009 · Consent · Docket ADMINISTRATIVE CONSENT ORDER

    The state of Maine has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

99. Apr 13, 2009
    Regulatory Action: State Commissioner of South Carolina FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $772,958 · Begun Apr 13, 2009 · Resolved Apr 13, 2009 · Consent · Docket 08018

    The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

100. Apr 3, 2009
     Regulatory Action: State of Oklahoma Department of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $478,287 · Begun Apr 3, 2009 · Resolved Apr 3, 2009 · Consent · Docket 09-087

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

101. Apr 1, 2009
     Regulatory Action: State of North Dakota Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $121,409 · Begun Apr 1, 2009 · Resolved Apr 1, 2009 · Consent

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

102. Mar 31, 2009
     Regulatory Action: The Securities Commisioner of the State of Delaware FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $309,118 · Begun Mar 31, 2009 · Resolved Mar 31, 2009 · Consent · Docket 09-2-2

     The state of Delaware has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

103. Mar 27, 2009
     Regulatory Action: State of Michigan Office of Financial and Insurance Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $653,981 · Begun Mar 27, 2009 · Resolved Mar 27, 2009 · Consent

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

104. Mar 24, 2009
     Regulatory Action: State of Arizona - Arizona Corporation Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $642,280 · Begun Mar 24, 2009 · Resolved Mar 24, 2009 · Consent · Docket S-20655A-09-0071

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

105. Mar 24, 2009
     Regulatory Action: State of Washington Financial Institutions Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $491,557 · Begun Mar 24, 2009 · Resolved Mar 24, 2009 · Consent · Docket S08-229-09-CO01

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

106. Mar 18, 2009
     Regulatory Action: State of Vermont Department of Banking, Insurance, Securities and Health Care Administration FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $166,923 · Begun Mar 18, 2009 · Resolved Mar 18, 2009 · Consent · Docket 09-039-S

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

107. Mar 16, 2009
     Regulatory Action: Texas State Securities Board FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $4.0M · Begun Mar 16, 2009 · Resolved Mar 16, 2009 · Consent · Docket IC09-CDO-06

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customer

108. Mar 11, 2009
     Regulatory Action: State of Maryland - Office of the Attorney General - Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $810,624 · Begun Mar 11, 2010 · Resolved Mar 11, 2009 · Consent · Docket 2009-0164

     The state of Maryland has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

109. Mar 9, 2009
     Regulatory Action: State of California - Department of Corporations FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.5M · Begun Mar 9, 2009 · Resolved Mar 9, 2009 · Consent

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers

110. Mar 5, 2009
     Regulatory Action: Office of the Commissioner of Financial Institutions Commonwealth of Puerto Rico FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $103,739 · Begun Mar 5, 2009 · Resolved Mar 5, 2009 · Consent · Docket C09-V-001

     Alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

111. Mar 3, 2009
     Regulatory Action: Office of the Mississippi Secretary of State FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $317,668 · Begun Mar 3, 2009 · Resolved Mar 3, 2009 · Consent · Docket S-09-0086

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

112. Feb 24, 2009
     Regulatory Action: State of North Carolina Department of the Secretary of State Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.7M · Begun Feb 24, 2009 · Resolved Feb 24, 2009 · Consent · Docket 09SEC029

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

113. Feb 24, 2009
     Regulatory Action: State of Georgia Commissioner of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.1M · Begun Feb 24, 2009 · Resolved Feb 24, 2009 · Consent · Docket ENSC-1465

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

114. Feb 19, 2009
     Regulatory Action: Common Wealth of Massachusetts Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $782,322 · Begun Feb 19, 2009 · Resolved Feb 19, 2009 · Consent · Docket E-2008-0053

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

115. Feb 19, 2009
     Regulatory Action: State of South Dakota Department of Revenue and Regulation Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $155,069 · Begun Feb 19, 2009 · Resolved Feb 19, 2009 · Consent · Docket ADMINISTRATIVE CONSENT ORDER

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

116. Feb 17, 2009
     Regulatory Action: Montana Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $148,812 · Begun Feb 17, 2009 · Resolved Feb 17, 2009 · Consent · Docket CASE NO. SEC-2009-5

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

117. Feb 17, 2009
     Regulatory Action: State of Nevada Office of the Secretary of State Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $839,327 · Begun Feb 17, 2009 · Resolved Feb 17, 2009 · Consent · Docket FILE NO. I09-038

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

118. Feb 17, 2009
     Civil Judicial Action FinalSanctions: Injunction; Undertakings: the settlement, which is subject to court approval, provides, among other things, that: wachovia will offer · Begun Feb 5, 2009 · Resolved Feb 17, 2009 · Judgment Rendered

     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.

     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.

119. Feb 12, 2009
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $4.4M · Begun Feb 12, 2009 · Resolved Feb 12, 2009 · Acceptance, Waiver & Consent(AWC) · Docket E9A2005013001

     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.

120. Feb 4, 2009
     Regulatory Action: Attorney General of the State of New York Investor Protection Bureau FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $50.0M · Begun Feb 4, 2009 · Resolved Feb 4, 2009 · Consent · Docket ASSURANCE NO. 08-179

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers

121. Dec 8, 2008
     Regulatory Action: State of Maryland FinalSanctions: Undertaking; Fine · Fine: $50,000 · Begun Jan 1, 2006 · Resolved Dec 8, 2008 · Stipulation and Consent · Docket 2008-0268

     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.

     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.

122. Dec 8, 2008
     Regulatory Action: Office of the Secretary of State State of Missouri FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.8M · Begun Dec 8, 2008 · Resolved Dec 8, 2008 · Consent · Docket AP-08-28

     The state has alleged that wachovia securities misrepresented the sale of auction rate securities to customers.

123. Oct 30, 2008
     Regulatory Action: FINRA FinalFine: $75,000 · Begun Oct 30, 2008 · Resolved Oct 30, 2008 · Acceptance, Waiver & Consent(AWC) · Docket 2007010115401

     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.

124. Oct 6, 2008
     Regulatory Action: New Jersey Bureau of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $400,000 · Begun Mar 28, 2007 · Resolved Oct 6, 2008 · Consent · Docket 2007-010

     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

125. Jul 23, 2008
     Regulatory Action: FINRA PendingBegun Jul 23, 2008 · Docket 2007010115401

     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.

     This DRP should be combined with occurence 1426665

126. Feb 26, 2008
     Regulatory Action: FINRA FinalFine: $7,500 · Begun Feb 26, 2008 · Resolved Feb 26, 2008 · Acceptance, Waiver & Consent(AWC) · Docket 20050001452-03

     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.

127. Jan 25, 2008
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,000 · Begun Jan 25, 2008 · Resolved Jan 25, 2008 · Acceptance, Waiver & Consent(AWC) · Docket 20050032155-01

     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.

128. Jun 21, 2007
     Regulatory Action: NASD (now FINRA) FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and remediation to clients · Fine: $2.0M · Begun Dec 13, 2004 · Resolved Jun 21, 2007 · Acceptance, Waiver & Consent(AWC) · Docket AWC# EAF0400840001

     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.

     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.

129. Jun 19, 2007
     Regulatory Action: North Dakota Securities Commissioner FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $75,000 · Begun Jun 19, 2007 · Consent · Docket 06-556

     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.

     WSLLC agreed to correspond with certain former clients and to address any complaints through its normal dispute resolution process.

130. Jun 18, 2007
     Regulatory Action: New York Stock Exchange Division of Enforcement FinalSanctions: Censure; Fine of $90,000. · Fine: $90,000 · Begun May 30, 2007 · Resolved Jun 18, 2007 · Stipulation and Consent · Docket HBD# 07-90

     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.

131. Apr 6, 2007
     Regulatory Action: New York Stock Exchange, Inc., Division of Enforcement FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $100,000 · Begun Feb 12, 2007 · Resolved Apr 6, 2007 · Stipulation and Consent · Docket HBD# 07-034

     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.

132. Feb 26, 2007
     Regulatory Action: NASD (now FINRA) FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $25,000 · Begun Feb 26, 2007 · Resolved Feb 26, 2007 · Acceptance, Waiver & Consent(AWC) · Docket AWC #E8A2003062017

     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.

133. Dec 18, 2006
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Monetary fine · Fine: $50,000 · Begun Dec 18, 2006 · Resolved Dec 18, 2006 · Acceptance, Waiver & Consent(AWC) · Docket AWC NO. 2005001720503

     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.

134. Oct 9, 2006
     Regulatory Action: New York Stock Exchange, Division of Enforcement FinalFine: $300,000 · Begun Aug 25, 2006 · Resolved Oct 9, 2006 · Stipulation and Consent · Docket HDB# 06-172

     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.

135. Jan 18, 2006
     Regulatory Action: New York Stock Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7,500 · Begun Jan 18, 2006 · Resolved Jan 18, 2006 · Other

     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.

136. Jun 13, 2005
     Regulatory Action: Missouri Securities Division FinalSanctions: Cease and Desist; Payment of $300,000 to the Missouri investor education and protection fund. · Fine: $300,000 · Begun Jun 13, 2005 · Resolved Jun 13, 2005 · Consent · Docket CASE NO. AP-05-20

     The firm was alleged to have violated securities laws by failing to adequately supervise its agents in the state of Missouri.

137. Apr 25, 2005
     Regulatory Action: State of Maine, Office of Securities FinalSanctions: Censure; Administrative fine of $27,000 · Fine: $27,000 · Begun Apr 25, 2005 · Resolved Apr 25, 2005 · Consent · Docket 05-026-CAG

     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.

138. Apr 13, 2005
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure; Fine of $25,000 · Fine: $25,000 · Begun Apr 13, 2005 · Resolved Apr 13, 2005 · Acceptance, Waiver & Consent(AWC) · Docket AWC CE2050007

     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.

139. Jan 10, 2005
     Civil Judicial Action FinalSanctions: Other; Civ - civil complaint filed · Begun Sep 30, 2003 · Resolved Jan 10, 2005 · Dismissed

     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.

140. Nov 30, 2004
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure · Fine: $650,000 · Begun Nov 30, 2004 · Resolved Nov 30, 2004 · Acceptance, Waiver & Consent(AWC) · Docket AWC NO. CAF040089

     The firm was alleged to have failed to file Form U4 and U5 amendments in a timely manner from January, 2002 to March, 2004.

141. Nov 12, 2004
     Regulatory Action: State of California, Department of Corporations FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $250,000 · Begun Sep 30, 2003 · Resolved Nov 12, 2004 · Order

     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.

142. Sep 16, 2004
     Regulatory Action: State of Maine, Office of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,500 · Begun Sep 16, 2004 · Resolved Sep 16, 2004 · Consent · Docket 04-063-CAG

     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.

143. Aug 13, 2004
     Regulatory Action: New York Stock Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Fine of $250,000 · Fine: $250,000 · Begun Jul 8, 2004 · Resolved Aug 13, 2004 · Consent · Docket HPD# 04-115

     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.

144. Jun 28, 2004
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution of $19,486.25 · Fine: $20,000 · Begun Jun 28, 2004 · Resolved Jun 28, 2004 · Acceptance, Waiver & Consent(AWC) · Docket C05040043

     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).

145. Feb 12, 2004
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Monetary fine and undertakings · Fine: $2.4M · Begun Feb 12, 2004 · Resolved Feb 12, 2004 · Acceptance, Waiver & Consent(AWC) · Docket CAF040008

     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.

     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.

146. Feb 12, 2004
     Regulatory Action: SEC FinalSanctions: Cease and Desist; Censure, monetary fine and disgorgement, plus prejudgment interest · Fine: $2.4M · Begun Feb 12, 2004 · Resolved Feb 12, 2004 · Decision & Order of Offer of Settlement · Docket 3-11410

     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.

     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.

147. Jan 23, 2004
     Regulatory Action: State of Connecticut FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,500 · Begun Jan 23, 2004 · Resolved Jan 23, 2004 · Stipulation and Consent · Docket ST-03-6927-S

     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.

148. Mar 19, 2003
     Regulatory Action: State of New Hampshire FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,000 · Begun Mar 19, 2003 · Order · Docket INV03-010

     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.

     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).

149. Oct 30, 2002
     Regulatory Action: National Association of Securities Dealers, Inc. FinalFine: $10,000 · Begun Oct 30, 2002 · Resolved Oct 30, 2002 · Acceptance, Waiver & Consent(AWC) · Docket CMS020202

     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.

150. Oct 24, 2002
     Regulatory Action: National Association of Securities Dealers, Inc. FinalFine: $5,000 · Begun Oct 24, 2002 · Resolved Oct 24, 2002 · Acceptance, Waiver & Consent(AWC) · Docket CMS020193

     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.

151. Feb 7, 2002
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Fine of $5,000 · Fine: $5,000 · Begun Apr 3, 2000 · Resolved Feb 7, 2002 · Acceptance, Waiver & Consent(AWC) · Docket C07020006-AWC

     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.

     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.

152. Jan 28, 2002
     Regulatory Action: New York Stock Exchange, Inc. FinalSanctions: Censure; Fine of $145,000 · Fine: $145,000 · Begun Apr 1, 2000 · Resolved Jan 28, 2002 · Consent · Docket 01-232

     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.

153. Dec 26, 2001
     Regulatory Action: Indiana FinalSanctions: Cease and Desist · Begun Nov 7, 2001 · Resolved Dec 26, 2001 · Vacated · Docket 01-0215 CD

     A cease and desist order was placed agains JW genesis in connection with alleged unauthorized trade by a registered representative of the firm.

     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).

154. Mar 8, 2001
     Regulatory Action: NASD (now FINRA) FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $7,000 · Begun Aug 3, 2000 · Resolved Mar 8, 2001 · Acceptance, Waiver & Consent(AWC) · Docket CMS010023

     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.)

     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.

155. Feb 14, 2001
     Regulatory Action: NASD (now FINRA) FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $32,500 · Begun Jun 30, 2000 · Resolved Feb 14, 2001 · Acceptance, Waiver & Consent(AWC) · Docket CO5010010

     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.

     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.

156. Oct 30, 2000
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Begun Oct 30, 2000 · Resolved Oct 30, 2000 · Acceptance, Waiver & Consent(AWC) · Docket C05000058

     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.

157. Oct 24, 2000
     Regulatory Action: SEC FinalSanctions: Cease and Desist; First union securities, without admitting or denying any wrongdoing, was ordered to cease and desist from committing or · Fine: $100,000 · Begun Oct 24, 2000 · Resolved Oct 24, 2000 · Consent · Docket REL. 34-43478, FILE NO. 3-10352

     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.

     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.

158. Jul 20, 2000
     Regulatory Action: State of Florida, Department of Banking and Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist · Fine: $5,000 · Begun May 11, 2000 · Resolved Jul 20, 2000 · Stipulation and Consent · Docket 2970-S-6/00

     Southtrust securities, inc. (CRD# 17922 - merged into wachovia securities, LLC) failed to effect renewal of 7 existing registered offices with the state of Florida.

     Final order was accepted on 7/20/2000 by the state of Florida; all subject offices were promptly approved by the state.

159. Jul 10, 2000
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure; Fine of $7,500. · Fine: $7,500 · Begun Jul 10, 2000 · Resolved Jul 10, 2000 · Acceptance, Waiver & Consent(AWC) · Docket C8A000039

     Alleged violation of NASD conduct rule 2110 and 3010(b).

160. Jun 13, 2000
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure; Fine of $350,000 · Fine: $350,000 · Begun Jun 13, 2000 · Resolved Jun 13, 2000 · Acceptance, Waiver & Consent(AWC) · Docket CAF000022

     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.

161. Apr 5, 2000
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Begun Apr 5, 2000 · Resolved Apr 5, 2000 · Acceptance, Waiver & Consent(AWC) · Docket C05000014

     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.

162. Dec 17, 1999
     Regulatory Action: SEC On appealFine: $20,000 · Begun Feb 10, 1998 · Resolved Dec 17, 1999 · Decision · Docket 3-9688

     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.

     The decision was affirmed by the commission on August 20, 2003.

163. Jul 14, 1999
     Regulatory Action: New York Stock Exchange, Inc FinalSanctions: Censure · Fine: $120,000 · Begun Jun 1, 1999 · Resolved Jul 14, 1999 · Stipulation and Consent · Docket HPD#99-91

     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.

164. Mar 2, 1999
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Fine · Fine: $13,000 · Begun Feb 25, 1999 · Resolved Mar 2, 1999 · Settled · Docket CMS990024AWC

     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.

165. May 29, 1998
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Fine: $3,000 · Begun Mar 30, 1998 · Resolved May 29, 1998 · Settled · Docket C8A980037

     Alleged violations of MSRB rule G36.

     3/23/2000 - corrected docket no. and date settled due to data entry error.

166. Apr 23, 1998
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Fine: $18,500 · Begun Apr 7, 1998 · Resolved Apr 23, 1998 · Settled · Docket CMS980025

     Alleged violations of rules set forth under NASD conduct rules 2110 and 3010 and violations of NASD marketplace rule 4632(a).

167. Jan 13, 1998
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Other; Relief sought · Fine: $250 · Begun Jan 13, 1998 · Resolved Jan 13, 1998 · Acceptance, Waiver & Consent(AWC) · Docket C0970033

     N/a

     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***

168. Dec 15, 1997
     Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Fine: $10,000 · Begun Nov 14, 1995 · Resolved Dec 15, 1997 · Settled · Docket CAF970003

     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.

     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.

169. Jul 2, 1997
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure; Fine · Fine: $8,000 · Begun Mar 1, 1997 · Resolved Jul 2, 1997 · Settled · Docket AWC NO. CMS970024

     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.

     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.

170. May 13, 1997
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,500 · Begun Dec 22, 1995 · Resolved May 13, 1997 · Settled · Docket CMS960098AWC

     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.

171. Apr 23, 1997
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,000 · Begun Dec 12, 1996 · Resolved Apr 23, 1997 · Settled · Docket AWC NO. CMS960220

     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.

     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.

172. Dec 27, 1996
     Regulatory Action: Idaho Department of Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,000 · Begun Sep 17, 1996 · Resolved Dec 27, 1996 · Settled · Docket 1996-7-74

     First union brokerage services, inc. was alleged to have engaged in the offer and/or sale of securities to Idaho residents.

     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.

173. Apr 25, 1996
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure · Fine: $8,000 · Begun Nov 5, 1995 · Resolved Apr 25, 1996 · Settled · Docket CMS950180

     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.

174. Apr 25, 1996
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Censure · Fine: $8,000 · Begun Nov 15, 1995 · Resolved Apr 25, 1996 · Settled · Docket CMS950122

     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.

175. Apr 17, 1996
     Regulatory Action: State of Alabama FinalSanctions: Cease and Desist · Fine: $1,500 · Begun Jul 18, 1995 · Resolved Apr 17, 1996 · Settled · Docket CD-95-0069

     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.

     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.

176. Apr 8, 1996
     Regulatory Action: Vermont Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,500 · Begun Mar 21, 1996 · Resolved Apr 8, 1996 · Consent · Docket 96-026-S

     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.

     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.

177. Mar 22, 1996
     Regulatory Action: State of New Mexico FinalSanctions: Censure · Fine: $1,000 · Begun Dec 11, 1995 · Resolved Mar 22, 1996 · Consent · Docket 96-96-998

     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.

     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.

178. Mar 19, 1996
     Regulatory Action: State of New Jersey FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10,000 · Begun Jan 10, 1996 · Resolved Mar 19, 1996 · Settled · Docket N/A

     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.

     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.

179. Feb 14, 1996
     Regulatory Action: Commonwealth of Massachusetts FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15,000 · Begun Feb 1, 1996 · Resolved Feb 14, 1996 · Settled · Docket R-95-269

     First union brokerage services, inc. was alleged to have engaged in the unsolicited offer and/or sale of securities to Massachusetts residents.

     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.

180. Dec 15, 1995
     Regulatory Action: State of Kansas FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,500 · Begun Sep 20, 1995 · Resolved Dec 15, 1995 · Settled · Docket 96E055

     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.

     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.

181. Nov 8, 1995
     Regulatory Action: Commonwealth of Virginia FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $153,000 · Begun Nov 8, 1995 · Resolved Nov 8, 1995 · Settled · Docket N/A

     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

     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.

182. Oct 15, 1995
     Regulatory Action: State of Maryland FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,300 · Begun Oct 15, 1995 · Resolved Oct 15, 1995 · Settled · Docket N/A

     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

     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.

183. May 9, 1995
     Regulatory Action: State of New Mexico FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $835 · Begun May 3, 1995 · Resolved May 9, 1995 · Settled · Docket 95-95-998-158(UN)

     First union brokerage services, inc. was alleged to have engaged in the unsolicited offer and/or sale of securities to New Mexico residents.

     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.

184. May 5, 1995
     Regulatory Action: State of Minnesota FinalSanctions: Denial · Fine: $1,500 · Begun May 5, 1995 · Resolved May 5, 1995 · Order · Docket N/A

     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.

     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.

185. Feb 23, 1995
     Regulatory Action: Vermont Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,350 · Begun Feb 23, 1995 · Resolved Feb 23, 1995 · Settled · Docket 95-001-S

     First union brokerage services, inc. was alleged to have transacted business as an unregistered broker/dealer in the state.

     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.

186. Jan 16, 1992
     Regulatory Action: SEC FinalSanctions: Other; Civil and administrative penalty/fine · Fine: $10,000 · Begun Jan 16, 1992 · Resolved Jan 16, 1992 · Settled · Docket NONE

     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.

     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.

187. Jan 1, 1992
     Regulatory Action: U S Securities & Exchange Commission FinalSanctions: Cease and Desist · Fine: $100,000 · Begun Jan 1, 1992 · Resolved Jan 1, 1992 · Settled · Docket N/A

     Violations of CFR part 404 promulgated pursuant to section 15c with the primary distribution of certain unsecured debt securities issued by governmental sponsored enterprises.

188. Nov 2, 1990
     Regulatory Action: National Association of Securities Dealers, Inc. FinalSanctions: Other; Relief sought · Fine: $2,500 · Begun Nov 2, 1990 · Resolved Nov 2, 1990 · Acceptance, Waiver & Consent(AWC) · Docket NEW-779-AWC

     Failure to develop written supervisory procedures.

     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***

189. No date
     Regulatory Action: ( g g g y y )

Actions about affiliates (117)

1. Jan 17, 2025
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo AdvisorsSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure · Fine: $28.0M · Begun Jan 17, 2025 · Resolved Jan 17, 2025 · Order · Docket FILE NO. 3-22430

   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.

   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.

2. Jan 16, 2025
   Regulatory Action: Bloomberg SEF LLC FinalAbout an affiliate: Wells Fargo Bank,Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,250 · Begun Jan 16, 2025 · Resolved Jan 16, 2025 · Other · Docket N/A

   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.

   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.

3. Aug 25, 2023
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo AdvisorsSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist censure · Fine: $35.0M · Begun Aug 25, 2023 · Resolved Aug 25, 2023 · Order · Docket FILE NO. 3-21580

   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.

   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.

4. Aug 8, 2023
   Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, undertaking · Fine: $75.0M · Resolved Aug 8, 2023 · Order · Docket DOCKET NO. 23-36

   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.

   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.

5. Aug 8, 2023
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo Securities,Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, undertaking · Fine: $125.0M · Begun Aug 8, 2023 · Resolved Aug 8, 2023 · Order · Docket FILE NO. 3-21552

   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.

   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.

6. Mar 30, 2023
   Regulatory Action: Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $67.8M · Begun Mar 30, 2023 · Resolved Mar 30, 2023 · Order · Docket 22-011-CMP-HC

   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 non-US bank constitutes unsafe and unsound practices.

   The Board of Governors assessed a civil money penalty on Wells Fargo & Company for unsafe and unsound practices in respect of failures in its risk-management 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.

7. Dec 20, 2022
   Regulatory Action: Consumer Financial Protection Bureau FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Remediation, process changes · Fine: $1.7B · Begun Dec 20, 2022 · Resolved Dec 20, 2022 · Stipulation and Consent · Docket 2022-CFPB-0011

   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.

   The order is final and the penalty has been paid.

8. Sep 27, 2021
   Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil Penalty(ies)/Fine(s); Civil asset forfeiture · Fine: $37.3M · Begun Sep 27, 2021 · Resolved Sep 27, 2021 · Settled

   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.

   Restitution of $35,337,319.90 was paid to affected consumers.

9. Sep 7, 2021
   Regulatory Action: Office of Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $250.0M · Begun Sep 7, 2021 · Resolved Sep 7, 2021 · Other · Docket AA-ENF-2021-29 & AA-ENF-2021-20

   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.

   N/a

10. Jun 15, 2020
    Regulatory Action: Office of Attorney General, State of Maryland FinalAbout an affiliate: Wells Fargo & CompanySanctions: Restitution · Fine: $20.0M · Begun Jun 15, 2020 · Resolved Jun 15, 2020 · Settled · Docket 2016-0833

    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.

11. Feb 27, 2020
    Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo AdvisorsSanctions: Cease and Desist · Fine: $35.0M · Begun Feb 27, 2020 · Resolved Feb 27, 2020 · Order · Docket FILE NO. 3-19714

    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).

    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.

12. Feb 21, 2020
    Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo & CompanySanctions: Cease and Desist; Civil and administrative penalty(IES)/fine(s)" · Fine: $500.0M · Begun Feb 21, 2020 · Resolved Feb 21, 2020 · Order · Docket NO. 3-19704

    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

    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

13. Nov 8, 2019
    Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank, N. A..Sanctions: Cease and Desist; Civil and administrative penalty(IES), undertakings, and restitution. · Fine: $10.0M · Begun Nov 8, 2019 · Resolved Nov 8, 2019 · Order · Docket CFTC DOCKET NO 20-08

    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.

14. Aug 9, 2019
    Regulatory Action: National Futures Association FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.5M · Begun Aug 9, 2019 · Resolved Aug 9, 2019 · Decision · Docket 19-BCC-010

    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

15. Jan 2, 2019
    Regulatory Action: California Department of Insurance FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Other; Administrative proceeding initiated · Fine: $10.3M · Begun Nov 30, 2017 · Resolved Jan 2, 2019 · Settled · Docket LA2016000665-AP

    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.

16. Dec 28, 2018
    Regulatory Action: State Attorney General - Ohio FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $3.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

17. Dec 28, 2018
    Regulatory Action: State Attorney General - North Dakota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

18. Dec 28, 2018
    Regulatory Action: State Attorney General - North Carolina FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

19. Dec 28, 2018
    Regulatory Action: State Attorney General - Kansas FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

20. Dec 28, 2018
    Regulatory Action: State Attorney General - Iowa FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

21. Dec 28, 2018
    Regulatory Action: State Attorney General - Indiana FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

22. Dec 28, 2018
    Regulatory Action: State Attorney General - Illinois FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

23. Dec 28, 2018
    Regulatory Action: State Attorney General - Idaho FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket CV01-18-23986

    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.

24. Dec 28, 2018
    Regulatory Action: State Attorney General - Connecticut FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

25. Dec 28, 2018
    Regulatory Action: ( g g g y y ) FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

26. Dec 28, 2018
    Regulatory Action: State Attorney General - West Virginia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

27. Dec 28, 2018
    Regulatory Action: State Attorney General - Texas FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $47.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket D-1-GN-18-007683

    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.

28. Dec 28, 2018
    Regulatory Action: State Attorney General - Tennessee FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.0M · Begun Dec 28, 2018 · Settled · Docket 19C69

    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.

29. Dec 28, 2018
    Regulatory Action: State Attorney General - South Dakota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

30. Dec 28, 2018
    Regulatory Action: State Attorney General - South Carolina FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

31. Dec 28, 2018
    Regulatory Action: State Attorney General - Rhode Island FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket PC-2018-9401

    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.

32. Dec 28, 2018
    Regulatory Action: State Attorney General - Pennsylvania FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

33. Dec 28, 2018
    Regulatory Action: State Attorney General - Oregon FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $9.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

34. Dec 28, 2018
    Regulatory Action: State Attorney General - New York FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $11.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

35. Dec 28, 2018
    Regulatory Action: State Attorney General - New Mexico FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket D-101-CV-2018-02395

    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.

36. Dec 28, 2018
    Regulatory Action: State Attorney General - New Jersey FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $17.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

37. Dec 28, 2018
    Regulatory Action: State Attorney General - New Hampshire FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 217-2018-CV-00811

    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.

38. Dec 28, 2018
    Regulatory Action: State Attorney General - Nevada FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $13.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

39. Dec 28, 2018
    Regulatory Action: State Attorney General - Nebraska FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

40. Dec 28, 2018
    Regulatory Action: State Attorney General - Montana FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

41. Dec 28, 2018
    Regulatory Action: State Attorney General - Mississippi FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

42. Dec 28, 2018
    Regulatory Action: State Attorney General - Missouri FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18AC-CC00516

    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.

43. Dec 28, 2018
    Regulatory Action: State Attorney General - Minnesota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 62-CV-18-8322

    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.

44. Dec 28, 2018
    Regulatory Action: State Attorney General - Michigan FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Settled

    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.

45. Dec 28, 2018
    Regulatory Action: State Attorney General - Maryland FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

46. Dec 28, 2018
    Regulatory Action: State Attorney General - Massachusetts FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

47. Dec 28, 2018
    Regulatory Action: State Attorney General - Maine FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

48. Dec 28, 2018
    Regulatory Action: State Attorney General - Louisiana FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

49. Dec 28, 2018
    Regulatory Action: State Attorney General - Kentucky FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $3.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

50. Dec 28, 2018
    Regulatory Action: State Attorney General - Wyoming FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

51. Dec 28, 2018
    Regulatory Action: State Attorney General - Wisconsin FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $8.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

52. Dec 28, 2018
    Regulatory Action: State Attorney General - Washington FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18-2-06490-34

    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.

53. Dec 28, 2018
    Regulatory Action: State Attorney General - Alaska FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

54. Dec 28, 2018
    Regulatory Action: State Attorney General - Virginia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $11.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

55. Dec 28, 2018
    Regulatory Action: State Attorney General - Vermont FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

56. Dec 28, 2018
    Regulatory Action: State Attorney General - Utah FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

57. Dec 28, 2018
    Regulatory Action: State Attorney General - Hawaii FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

58. Dec 28, 2018
    Regulatory Action: State Attorney General - Georgia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

59. Dec 28, 2018
    Regulatory Action: State Attorney General - Florida FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $28.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

60. Dec 28, 2018
    Regulatory Action: State Attorney General - District of Columbia FinalAbout an affiliate: Wells Fargo & CompanySanctions: p · Fine: $1.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

61. Dec 28, 2018
    Regulatory Action: State Attorney General - Delaware FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

62. Dec 28, 2018
    Regulatory Action: State Attorney General - Colorado FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $21.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

63. Dec 28, 2018
    Regulatory Action: State Attorney General - California FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $148.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18-ST-CV-09856

    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.

64. Dec 28, 2018
    Regulatory Action: State Attorney General - Arizona FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $37.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

65. Dec 28, 2018
    Regulatory Action: ( g g g y y ) FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

66. Dec 28, 2018
    Regulatory Action: State Attorney General - Alabama FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    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.

67. Nov 27, 2018
    Regulatory Action: Office of Attorney General, State of Illinois FinalAbout an affiliate: Wells Fargo & CompanySanctions: Restitution · Fine: $17.2M · Begun Nov 27, 2018 · Resolved Nov 27, 2018 · Settled · Docket N/A

    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.

68. Oct 18, 2018
    Regulatory Action: Office of Attorney General, State of New York FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $65.0M · Begun Oct 18, 2018 · Resolved Oct 18, 2018 · Settled · Docket 18/121

    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.

69. Aug 1, 2018
    Regulatory Action: U.S. Department of Justice FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.1B · Begun Aug 1, 2018 · Resolved Aug 1, 2018 · Settled

    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.

70. Apr 20, 2018
    Regulatory Action: Bureau of Consumer Financial Protection FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution disgorgement cease and desist · Fine: $500.0M · Begun Apr 20, 2018 · Resolved Apr 20, 2018 · Consent · Docket 2018-BCFP-0001

    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.

71. Apr 20, 2018
    Regulatory Action: Office of the Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution disgorgement cease and desist · Fine: $500.0M · Begun Apr 20, 2018 · Resolved Apr 20, 2018 · Consent · Docket AA-EC-2018-15 & AA-EC-2018-16

    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.

72. Feb 2, 2018
    Regulatory Action: Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo & CompanySanctions: Cease and Desist; Independent reviews · Begun Feb 2, 2018 · Resolved Feb 2, 2018 · Consent · Docket 18-007-B-HC

    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 approval, 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.

73. Oct 16, 2017
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo Advisors; the full record is on the affiliate's own Form ADVSanctions: Other; N/a · Begun Oct 16, 2017 · Resolved Oct 16, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014042465601

    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.

    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.

74. Dec 21, 2016
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo AdvisorsSanctions: Other; N/a · Fine: $1.5M · Begun Dec 21, 2016 · Resolved Dec 21, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2016050274801

    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 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, with one of the other firms, failed to retain certain communications, including 77,280 reject letters and 78,200 fulfillment letters. FINRA found 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 also found that the firm failed to implement an audit system for those records they failed to maintain in worm format. In addition, FINRA determined that the firm failed to provide its third-party vendors full access to, and the ability to download information from, its electronic storage systems. Moreover, FINRA found 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.

75. Dec 5, 2016
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo AdvisorsFine: $1.0M · Begun Dec 5, 2016 · Resolved Dec 5, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2015043740201

    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.

76. Sep 29, 2016
    Regulatory Action: Office of the Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program and · Fine: $20.0M · Begun Sep 29, 2016 · Resolved Sep 29, 2016 · Order · Docket AA-EC-2016-68 & AA-EC-2016-69

    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.

    N/a

77. Sep 29, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil Penalty(ies)/Fine(s); Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program. · Fine: $60,000 · Begun Sep 29, 2016 · Resolved Sep 29, 2016 · Consent

    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.

    $60,000.00 fine paid

78. Sep 27, 2016
    Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Cease and Desist; Civil monetary fine of $400,000. · Fine: $400,000 · Begun Sep 27, 2016 · Resolved Sep 27, 2016 · Order · Docket CFTC DOCKET NO 16-32

    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.

    N/a

79. Sep 13, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Injunction; Mediate current or former California customers who incurred fees or were harmed as a result of the unauthorized · Fine: $50.0M · Begun May 4, 2015 · Resolved Sep 13, 2016 · Judgment Rendered

    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.

    Fine of $50,000,000.00 paid

80. Sep 6, 2016
    Regulatory Action: Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist; Compliance and risk management plan; pay reimbursement to affected consumers; civil money penalty. · Fine: $35.0M · Begun Sep 6, 2016 · Resolved Sep 6, 2016 · Consent · Docket AA-EC-2016-66 AND AA-EC-2016-67

    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.

81. Sep 4, 2016
    Regulatory Action: Consumer Financial Protection Bureau (CFPB) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Civil money penalties of $100,000,000.00; compliance and redress plans; independent consultant review, pay redress to affected · Fine: $100.0M · Begun Sep 4, 2016 · Resolved Sep 4, 2016 · Consent · Docket 2016-CFPB-0015

    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.

82. Aug 20, 2016
    Regulatory Action: Consumer Financial Protection Bureau (CFPB) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist; Compliance plan, remediation to borrowers, pay civil money penalties of $3,600,000 and provide a quarterly/annual tracking · Fine: $3.6M · Begun Aug 20, 2016 · Resolved Aug 20, 2016 · Consent · Docket 2016-CFPB-0013

    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.

83. May 24, 2016
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $70.0M · Begun Mar 31, 2011 · Resolved May 24, 2016 · Stipulation and Consent · Docket 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

    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.

84. Apr 8, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, NASanctions: Money Damages (Private/Civil Complaint); Civil penalties · Fine: $1.2B · Begun Oct 9, 2012 · Resolved Apr 8, 2016 · Settled

    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.

    Monetary fine of 1,200,000,000.00 100% leveled against the affiliate.

85. Feb 2, 2016
    Regulatory Action: Securities Exchange Commission FinalAbout an affiliate: Wells Fargo Bank, N.A.,Sanctions: Cease and Desist; Monetary fine of $440,000.00 · Fine: $440,000 · Begun Feb 2, 2016 · Resolved Feb 2, 2016 · Consent · Docket 3-17096

    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.

    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.

86. Dec 18, 2015
    Regulatory Action: U.S.A., Department of the Treasury, Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist · Begun Dec 18, 2015 · Resolved Dec 18, 2015 · Consent · Docket AA-EC-2015-79

    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)).

87. Jun 3, 2015
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.ASanctions: Cease and Desist; Civil money penalties and customer remediation · Fine: $4.0M · Begun Jun 3, 2015 · Resolved Jun 3, 2015 · Stipulation and Consent · Docket AA-EC-2015-06 AND AA-EC-2015-13

    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.

88. Feb 4, 2015
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Money Damages (Private/Civil Complaint); Compliance plan to ensure compliance with the order and administration of payments to redress affected consumers. · Fine: $21.0M · Begun Jan 22, 2015 · Resolved Feb 4, 2015 · Judgment Rendered

    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.

    Restitution of $10,809,807.71 to be provided to affected consumers. Any funds remaining will be deposited in US Treasury as disgorgement.

89. Jan 22, 2015
    Regulatory Action: United States of America Consumer Financial Protection Bureau FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Other; Consent order with conduct provision and order distribution and acknowledgement. · Begun Jan 22, 2015 · Resolved Jan 22, 2015 · Consent · Docket 2015-CFPB-0002

    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.

    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.

90. Jan 15, 2015
    Regulatory Action: New York State Department of Financial Services FinalAbout an affiliate: Wells Fargo Bank, N.A. onSanctions: Civil and Administrative Penalt(ies) /Fine(s); Customer remediation and restitution · Fine: $2.0M · Begun Jan 15, 2015 · Resolved Jan 15, 2015 · Consent · Docket NONE

    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.

91. Dec 18, 2014
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo AdvisorsSanctions: Other; N/a · Fine: $1.5M · Begun Dec 18, 2014 · Resolved Dec 18, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2012034123501

    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).

    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).

92. Oct 29, 2014
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank N.A.Sanctions: Injunction; Restitution · Begun May 14, 2013 · Resolved Oct 29, 2014 · Judgment Rendered

    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.

    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

93. Jun 2, 2014
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo Investments,Fine: $25,000 · Begun Jun 2, 2014 · Resolved Jun 2, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2010023976502

    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.

    ### Please remove this filing was made in error. Period of time in question (August 2009 to August 2010) was prior to the succession of wfi to wfa (12-13-2010). ###

94. Sep 20, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, NASanctions: Injunction; Monetary damages; pre-judgment interest on monetary damages; and a civil penalty · Fine: $175.0M · Begun Sep 20, 2012 · Resolved Sep 20, 2012 · Consent

    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.

    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.

95. May 24, 2012
    Regulatory Action: ComisiÓN Nacional de Valores FinalAbout an affiliate: Wachovia SecuritiesSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $27,500 · Begun May 24, 2012 · Resolved May 24, 2012 · Other

    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.

    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.

96. May 24, 2012
    Regulatory Action: ComisiÓN Nacional de Valores FinalAbout an affiliate: Wachovia SecuritiesSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $27,500 · Begun May 24, 2012 · Resolved May 24, 2012 · Other

    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.

97. Mar 12, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Money Damages (Private/Civil Complaint); Compliance with servicing standards and payment of monetary amounts · Begun Mar 12, 2012 · Resolved Mar 12, 2012 · Consent

    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.

    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.

98. Mar 12, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Money Damages (Private/Civil Complaint); Payment of compensatory damages · Begun Mar 12, 2012 · Resolved Mar 12, 2012 · Consent

    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.

    Compensatory damages in the amount of $3,769,569.70

99. Feb 22, 2012
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist undertaking · Fine: $83.0M · Begun Feb 22, 2012 · Resolved Feb 22, 2012 · Stipulation and Consent · Docket 2012-042

    Wells Fargo Bank, N.A. engaged in unsafe or unsound banking practices in connection with residential mortgage foreclosures.

100. Feb 9, 2012
     Regulatory Action: Federal Reserve FinalAbout an affiliate: Wells Fargo and CompanySanctions: p; Cease and desist · Fine: $87.0M · Begun Feb 9, 2012 · Resolved Feb 9, 2012 · Consent · Docket 12-010-CMP-HC

     Federal Reserve consent order re: bank's mortgage foreclosure practices.

101. Dec 8, 2011
     Regulatory Action: Office of the Comptroller of the Currency ("OCC") FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20.0M · Begun Dec 8, 2011 · Resolved Dec 8, 2011 · Consent · Docket # 2011 - 174; AA - EC - 11-97

     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.

     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.

102. Dec 8, 2011
     Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil Penalty(ies)/Fine(s); Disgorgement injunction · Fine: $25.0M · Begun Dec 8, 2011 · Resolved Dec 8, 2011 · Consent

     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.

     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 to the entities and in the amounts directed by the court within 60 days of entry of the final judgment.

103. Jul 20, 2011
     Regulatory Action: The Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo and CompanySanctions: Cease and Desist; Civil and administrative penalt(IES) / fine(s) restitution · Fine: $85.0M · Begun Jul 20, 2011 · Resolved Jul 20, 2011 · Settled · Docket 11-094-B-HC1; 11-094-B-HC2; 11-094-I-HC1; 11-094-I-HC2

     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.

     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.

104. Apr 4, 2011
     Regulatory Action: Federal Reserve FinalAbout an affiliate: Wells Fargo and CompaanySanctions: Cease and Desist · Begun Apr 4, 2011 · Consent · Docket 11-025-B-HC

     Federal Reserve consent order re: bank's mortgage foreclosure practices.

     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.

105. Mar 31, 2011
     Regulatory Action: Office of the Comptrollerof the Currency ("OCC") FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $70.0M · Begun Mar 31, 2011 · Stipulation and Consent · Docket 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

     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.

106. Mar 12, 2010
     Regulatory Action: Department of the Treasury - Financial Crimes Enforcement Network FinalAbout an affiliate: Wachovia Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $110.0M · Begun Mar 12, 2010 · Resolved Mar 12, 2010 · Order · Docket 2010-1

     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.

     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.

107. Mar 12, 2010
     Regulatory Action: Department of the Treasury - Comptroller of the Currency FinalAbout an affiliate: Wachovia Bank; N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist - undertaking · Fine: $50.0M · Begun Mar 12, 2010 · Resolved Mar 12, 2010 · Order · Docket AA-EC-10-16;AA-EC.-10-17

     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.

     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.

108. Nov 21, 2008
     Regulatory Action: State of Massachusetts FinalAbout an affiliate: A. G. Edwards & Sons, Inc.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Begun Dec 5, 2007 · Resolved Nov 21, 2008 · Decision · Docket E-2005-0001

     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.

109. Jul 14, 2008
     Regulatory Action: Texas State Securities Board FinalAbout an affiliate: A. G. Edwards & Sons, Inc.Sanctions: Undertaking · Fine: $5,000 · Begun Jul 14, 2008 · Resolved Jul 14, 2008 · Order · Docket IC08-CAF-05

     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.

110. Jun 27, 2008
     Regulatory Action: FINRA FinalAbout an affiliate: A. G. Edwards & Sons, Inc.Sanctions: Censure; Fine in the amount of $300,0000 · Fine: $300,000 · Begun Jun 27, 2008 · Resolved Jun 27, 2008 · Acceptance, Waiver & Consent(AWC) · Docket NO.2007011877401

     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.

111. Sep 19, 2007
     Regulatory Action: SEC FinalAbout an affiliate: Evergreen Investment; the full record is on the affiliate's own Form ADVSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure,cease and desist · Fine: $500,000 · Begun Sep 19, 2007 · Resolved Sep 19, 2007 · Decision & Order of Offer of Settlement · Docket ADMIN PROCEEDING FILE NO. 3-12805

     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.

112. Aug 26, 2006
     Regulatory Action: New York Stock Exchange, Inc., Division of Enforcement FinalAbout an affiliate: First Clearing, LLC; the full record is on the affiliate's own Form ADVSanctions: Censure · Fine: $2.2M · Begun Jul 6, 2006 · Resolved Aug 26, 2006 · Stipulation and Consent · Docket HBD#06-151

     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.

113. Aug 17, 2006
     Civil Judicial Action FinalAbout an affiliate: Wachovia Bank, N.A.Sanctions: Disgorgement · Begun Oct 4, 1996 · Resolved Aug 17, 2006 · Settled

     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.

     See item 14.

114. Aug 19, 1999
     Regulatory Action: Securities/Futures Commission & Stock Exchange of Hong Kong FinalAbout an affiliate: Prudential-BacheSanctions: Censure; Prudential securities ("PSI") was fined HK$30,000 (approx US$3,900). A PSI registered representative was fined HK$20,000 (approx · Fine: $6,500 · Begun Apr 23, 1999 · Resolved Aug 19, 1999 · Other · Docket DISCIPLINARY PROCEEDING NO. 50/99

     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.

115. Jan 15, 1997
     Regulatory Action: Commonwealth of Virginia, State Corporation Commission FinalAbout an affiliate: American SkandiaSanctions: Denial · Begun Jan 15, 1997 · Resolved Jan 15, 1997 · Other · Docket N/A

     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 affiliate's application for registration had expired, therefore, this denial was not based upon any misconduct or unlawful activity by the affiliate.

116. Dec 31, 1991
     Regulatory Action: The Securities and Futures Authority FinalAbout an affiliate: Bache Financial DeriativesSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $60,000 · Begun Dec 31, 1991 · Resolved Dec 31, 1991 · Settled · Docket N/A

     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.

     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 TH emarket in property futures.

117. Nov 6, 1991
     Regulatory Action: New York Mercantile Exchange FinalAbout an affiliate: Dryden Nominees (HongSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15,000 · Begun Jul 26, 1991 · Resolved Nov 6, 1991 · Settled · Docket 91-51

     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).

     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.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 20 criminal disclosures about the firm
• 7 regulatory action disclosures about A. G. Edwards & Sons, Inc.
• 6 regulatory action disclosures about the firm
• 5 regulatory action disclosures about Pruco Securities, LLC.
• 4 regulatory action disclosures about Daggs, Charles Willard III
• 3 regulatory action disclosures about Wachovia Capital Markets,
• 2 regulatory action disclosures about Wells Fargo Securities,
• 1 criminal disclosure about Espinoza, Mauricio
• 1 criminal disclosure about Ambrose, Nancy, R
• 1 criminal disclosure about Holtz, Maria, Louise
• 1 criminal disclosure about Hopper, Michael, Hamilton
• 1 criminal disclosure about Moore, Waynette, Marie
• 1 criminal disclosure about Ficklen, Ruby
• 1 criminal disclosure about Wachovia Bank, N.A.
• 1 regulatory action disclosure about Katz, Sanford, Michael
• 1 regulatory action disclosure about Amundson, Michael
• 1 regulatory action disclosure about Graham, Jonathan
• 1 regulatory action disclosure about Laporte, Ted, B
• 1 regulatory action disclosure about Wells Fargo Advisors
• 1 regulatory action disclosure about First Union Securities
• 1 regulatory action disclosure about Prudential Investment
• 1 regulatory action disclosure about Metropolitan West
• 1 regulatory action disclosure about Pru Global Securities, LLC
• 1 regulatory action disclosure about Global Alternative
• 1 regulatory action disclosure about American Skandia
• 1 regulatory action disclosure about Wells Fargo Brokerage
• 1 regulatory action disclosure about Yersin, Lincoln Blaine
• 1 regulatory action disclosure about Wells Fargo Investments,
• 1 regulatory action disclosure about H.D. Vest Advisory
• 1 regulatory action disclosure about H.D. Vest Investment
• 1 regulatory action disclosure about Wells Fargo Institutional
• 1 regulatory action disclosure about Merlin Securities, LLC
• 1 regulatory action disclosure about Wells Fargo Funds
• 1 civil judicial action disclosure about Wachovia Capital Markets,
• 1 civil judicial action disclosure about The Prudential Insurance
• 1 civil judicial action disclosure about Wells Fargo Securities,

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.