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BrokerCheck Report
RAYMOND JAMES & ASSOCIATES, INC.
Section Title
Report Summary
Firm History
CRD# 705
1
10
Firm Profile 2 - 9
Page(s)
Firm Operations 11 - 25
Disclosure Events 26
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RAYMOND JAMES & ASSOCIATES,INC.
CRD# 705
SEC# 8-10999
Main Office Location
880 CARILLON PARKWAYST. PETERSBURG, FL 33716Regulated by FINRA Florida Office
Mailing Address
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:
Business Telephone Number
727-567-1000
https://www.adviserinfo.sec.gov
Report Summary for this Firm
This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.
Disclosure Events
Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.
Are there events disclosed about this firm? Yes
The following types of disclosures have beenreported:
Type Count
Regulatory Event 121
Arbitration 73
Firm Profile
This firm is classified as a corporation.
This firm was formed in Florida on 02/19/1969.
Its fiscal year ends in September.
Firm History
Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.
Firm Operations
Is this brokerage firm currently suspended with anyregulator? No
This firm conducts 23 types of businesses.
This firm is affiliated with financial or investmentinstitutions.
This firm does not have referral or financialarrangements with other brokers or dealers.
This firm is registered with:
• the SEC• 8 Self-Regulatory Organizations• 53 U.S. states and territories
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This firm is classified as a corporation.
This firm was formed in Florida on 02/19/1969.
CRD#
This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.
Firm Profile
Firm Names and Locations
Its fiscal year ends in September.
RAYMOND JAMES & ASSOCIATES, INC.
SEC#
705
8-10999
Main Office Location
Mailing Address
Business Telephone Number
Doing business as RAYMOND JAMES & ASSOCIATES, INC.
727-567-1000
Regulated by FINRA Florida Office
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
2©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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This section provides information relating to all direct owners and executive officers of the brokerage firm.
Direct Owners and Executive Officers
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
RAYMOND JAMES FINANCIAL, INC.
HOLDING COMPANY
75% or more
Yes
Domestic Entity
02/1972
Yes
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
JAMES, THOMAS ALAN
DIRECTOR/CHAIRMAN OF THE BOARD
5% but less than 10%
No
Individual
01/1972
Yes
257119
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
ARIYAN, GERALD HAIG
PRESIDENT, ALEX. BROWN DIVISION
Less than 5%
Individual
09/2016
2326282
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
3©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Percentage of Ownership
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
Less than 5%
No
Yes
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
BARKO, SHAWN JOSEPH
CHIEF COMPLIANCE OFFICER
Less than 5%
No
Individual
12/2017
Yes
2690394
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
CAMPAGNOLI, VINCENT JOHN
CHIEF INFORMATION OFFICER
Less than 5%
No
Individual
06/2016
No
1421076
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
ELWYN, TASHTEGO SPRING
2319098
Legal Name & CRD# (if any):
4©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
PRESIDENT - PRIVATE CLIENT GROUP/DIRECTOR
Less than 5%
No
Individual
02/2014
Yes
2319098
Is this a domestic or foreignentity or an individual?
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
JULIEN, JEFFREY PAUL
DIRECTOR
Less than 5%
No
Individual
01/2004
Yes
1453432
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
OLLIA, MARSHALL FARROKH
PRINCIPAL FINANCIAL OFFICER / FINOP
Less than 5%
Individual
04/2018
Yes
3195972
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
5©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
No
Yes
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
SANTELLI, JONATHAN
CHIEF LEGAL OFFICER / SECRETARY
Less than 5%
No
Individual
05/2016
No
6306997
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
SHOUKRY, PAUL MARONE
TREASURER
Less than 5%
No
Individual
04/2018
Yes
5804809
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
THURSTON, CHRISTOPHER S
Individual
3112696
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
6©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
RIA CHIEF COMPLIANCE OFFICER
Less than 5%
No
Individual
02/2018
No
Is this a domestic or foreignentity or an individual?
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
TREMAINE, THOMAS ROBERT
EXECUTIVE VICE PRESIDENT, DIRECTOR, CHIEF OPERATIONS OFFICER
Less than 5%
No
Individual
05/2004
Yes
1524109
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
ZANK, DENNIS WILLIAM
CHIEF EXECUTIVE OFFICER/DIRECTOR
Less than 5%
Individual
05/2004
Yes
871971
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
7©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
No
Yes
8©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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This section provides information relating to any indirect owners of the brokerage firm.
Indirect Owners
Firm Profile
No information reported.
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Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
10©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.
This firm is currently registered with the SEC, 8 SROs and 53 U.S. states and territories.
SEC Registration Questions
This firm is registered with the SEC as:
A broker-dealer:
A broker-dealer and government securities broker or dealer:
A government securities broker or dealer only:
This firm has ceased activity as a government securities broker or dealer:
Yes
Yes
No
No
Federal Regulator Status Date Effective
SEC Approved 08/31/1962
Self-Regulatory Organization Status Date Effective
FINRA Approved 08/21/1964
Chicago Stock Exchange Approved 10/01/1995
NYSE American LLC Approved 02/25/1988
NYSE Arca, Inc. Approved 06/05/2013
Nasdaq ISE, LLC Approved 03/28/2013
Nasdaq PHLX LLC Approved 08/31/1962
Nasdaq Stock Market Approved 07/12/2006
New York Stock Exchange Approved 01/01/1973
11©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
Registrations (continued)
U.S. States &Territories
Status Date Effective
Alabama Approved 10/24/1981
Alaska Approved 11/21/1985
Arizona Approved 01/16/1980
Arkansas Approved 09/19/1979
California Approved 09/12/1978
Colorado Approved 02/01/1983
Connecticut Approved 09/25/1979
Delaware Approved 10/06/1981
District of Columbia Approved 03/20/1980
Florida Approved 04/27/1983
Georgia Approved 09/22/1981
Hawaii Approved 04/24/1986
Idaho Approved 11/30/1984
Illinois Approved 09/14/1978
Indiana Approved 10/21/1981
Iowa Approved 07/14/1983
Kansas Approved 03/31/1983
Kentucky Approved 07/16/1982
Louisiana Approved 07/25/1983
Maine Approved 09/06/1984
Maryland Approved 10/03/1981
Massachusetts Approved 07/31/1981
Michigan Approved 02/03/1983
Minnesota Approved 02/16/1984
Mississippi Approved 10/14/1981
Missouri Approved 07/18/1983
Montana Approved 04/20/1983
Nebraska Approved 10/08/1981
Nevada Approved 07/19/1983
New Hampshire Approved 08/19/1983
New Jersey Approved 07/14/1983
New Mexico Approved 06/01/1984
New York Approved 01/02/1985
U.S. States &Territories
Status Date Effective
North Carolina Approved 07/15/1982
North Dakota Approved 05/09/1983
Ohio Approved 07/16/1982
Oklahoma Approved 05/27/1983
Oregon Approved 09/06/1983
Pennsylvania Approved 12/09/1969
Puerto Rico Approved 09/01/1984
Rhode Island Approved 12/13/1985
South Carolina Approved 10/28/1981
South Dakota Approved 04/23/1985
Tennessee Approved 08/17/1981
Texas Approved 07/25/1983
Utah Approved 04/21/1983
Vermont Approved 02/13/1984
Virgin Islands Approved 04/11/2005
Virginia Approved 09/22/1981
Washington Approved 10/31/1983
West Virginia Approved 09/30/1981
Wisconsin Approved 08/30/1976
Wyoming Approved 10/31/1985
12©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.
This firm currently conducts 23 types of businesses.
Types of Business
Exchange member engaged in exchange commission business other than floor activities
Broker or dealer making inter-dealer markets in corporation securities over-the-counter
Broker or dealer retailing corporate equity securities over-the-counter
Broker or dealer selling corporate debt securities
Underwriter or selling group participant (corporate securities other than mutual funds)
Mutual fund underwriter or sponsor
Mutual fund retailer
U S. government securities dealer
U S. government securities broker
Municipal securities dealer
Municipal securities broker
Broker or dealer selling variable life insurance or annuities
Solicitor of time deposits in a financial institution
Put and call broker or dealer or option writer
Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals)
Investment advisory services
Broker or dealer selling tax shelters or limited partnerships in primary distributions
Trading securities for own account
Private placements of securities
Broker or dealer selling interests in mortgages or other receivables
Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union
Broker or dealer involved in a networking, kiosk or similar arrangment with a: insurance company or agency
Other - MUNICIPAL ADVISORY ACTIVITIES.
INVESTMENT BANKING - INCLUDING UNDERWRITING PUBLIC OFFERINGS OF SECURITIES AND MERGERSAND ACQUISITIONS ADVICE.
13©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Other Types of Business
This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.
Non-Securities Business Description: TO COMPLY WITH SWAP REGISTRATION REQUIREMENTS ASSOCIATEDWITH DODD FRANK, RAYMOND JAMES & ASSOCIATES, INC. WASAPPROVED AS A SWAP FIRM ON 04/28/2014.
14©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
Clearing Arrangements
This firm does hold or maintain funds or securities or provide clearing services for other broker-dealer(s).
Introducing Arrangements
This firm does not refer or introduce customers to other brokers and dealers.
15©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
Industry Arrangements
This firm does not have books or records maintained by a third party.
This firm does have accounts, funds, or securities maintained by a third party.
This firm does not have customer accounts, funds, or securities maintained by a third party.
This firm does not have individuals who control its management or policies through agreement.
This firm does not have individuals who wholly or partly finance the firm's business.
Control Persons/Financing
Name: CREDIT SUISSE SECURITIES (USA) LLC
Business Address: 1 MADISON AVENUE, 2ND FLOORNEW YORK, NY 10010
CRD #: 816
Effective Date: 07/21/2010
Description: RAYMOND JAMES & ASSOCIATES, INC. ENTERED INTO AN AGREEMENTWITH CREDIT SUISSE SECURITIES (USA) LLC ("CSSU") WHEREBY CSSUIS RESPONSIBLE SOLELY FOR THE EXECUTION, CLEARING AND/ORCARRYING OF ACCOUNTS OF FUTURES CONTRACTS. CSSU ACTS ASAGENT AND NOT AS PRINCIPAL IN THE EXECUTION OF FUTURESCONTRACTS.
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Firm Operations
Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.
This firm is, directly or indirectly:
· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.
Yes
No
CANADA
Yes
09/01/2016
SUITE 26001000 DE LA GAUCHETIERE W.MONTREAL, CANADA H3B 4W5
128324
RAYMOND JAMES INVESTMENT COUNSEL LTD. is under common control with the firm.
RAYMOND JAMES INVESTMENT COUNSEL LTD. IS A WHOLLY-OWNEDSUBSIDIARY OF RAYMOND JAMES LTD.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
Yes
No
No
07/07/2015
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
174904
CARILLON TOWER ADVISERS, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANTDescription:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANTDescription:
Yes
No
No
12/24/2012
3611 VALLEY CENTRE DRIVESUITE 100SAN DIEGO, CA 92130
139785
CLARIVEST ASSET MANAGEMENT LLC is under common control with the firm.
AFFILIATE OF EAGLE ASSET MANAGEMENT, INC., A WHOLLY-OWNEDSUBSIDIARY OF THE PARENT OF APPLICANT.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
Yes
No
CANADA
Yes
04/30/2015
357 BAY STREETSUITE #1001TORONTO, CANADA M5H 2T7
109439
COUGAR GLOBAL INVESTMENTS is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
No
10/01/2013
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
121221
RAYMOND JAMES INSURANCE GROUP, INC. is under common control with the firm.
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
No
Yes
No
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
No
No
No
04/02/2012
50 NORTH FRONT STREETMEMPHIS, TN 38103
MK HOLDING, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
FRANCE
Yes
09/18/2001
40 RUE DE LA BOETIEPARIS, FRANCE 75008
RAYMOND JAMES EURO EQUITIES SAS is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
149018
RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC is under common control with the firm.
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
Yes
No
No
12/18/2008
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
No
Yes
No
11/01/2008
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
EAGLE FUND SERVICES, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
No
07/13/2006
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
139749
CARILLON FUND DISTRIBUTORS, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
RAYMOND JAMES TRUST COMPANY is under common control with the firm.
Business Address:20©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Operations
Organization Affiliates (continued)
No
Yes
No
05/28/1992
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
CANADA
Yes
04/01/1998
601 WEST HASTINGS ST., SUITE 800VANCOUVER, B.C., CANADA V6B 5E2
RAYMOND JAMES LTD. (CANADA) is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
ENGLAND
Yes
09/16/2002
77 CORNHILLLONDON, ENGLAND EC3V 3QQ
RAYMOND JAMES INVESTMENT SERVICES LTD. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PATENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
RAYMOND JAMES GLOBAL SECURITIES, LTD. is under common control with the firm.
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Firm Operations
Organization Affiliates (continued)
No
Yes
BRITISH VIRGIN ISLANDS
Yes
01/31/2001
ROMASCO PLACE WICKHAMS CAY 1P.O. BOX 3140, ROAD TOWNTORTOLA, BRITISH VIRGIN ISLANDS
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
TURKEY
Yes
05/12/1999
NISPETIYE CAD. SEHIT ALBAY NAIL GONENLI SOKAK NO:6ETILER ISTANBUL, TURKEY 80630
RAYMOND JAMES YATIRIM MENKUL KIYMETLER, A.S. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
Yes
Yes
CANADA
Yes
11/09/2001
40 KING STREET WEST, SUITE 5300P.O. BOX 415 SCOTIA PLAZATORONTO ONTARIO, CANADA M5H 3Y2
25853
RAYMOND JAMES (USA) LTD. is under common control with the firm.
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
Yes
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
No
Yes
LONDON, ENGLAND
Yes
11/16/1995
BISHOPSGATE COURT4-12 NORTON FOLGATELONDON, ENGLAND E16DB
RAYMOND JAMES FINANCIAL INTERNATIONAL, LTD. (UK) is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF RAYMOND JAMES INTERNATIONALHOLDINGS, INC., WHICH IS A WHOLLY-OWNED SUBSIDIARY OF THEPARENT OF APPLICANT.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
Yes
No
No
12/07/2007
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
EAGLE BOSTON INVESTMENT MANAGEMENT, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
02/08/1984
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
110653
EAGLE ASSET MANAGEMENT INC is under common control with the firm.
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
Yes
No
No
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Yes
Yes
No
09/12/1973
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
6694
RAYMOND JAMES FINANCIAL SERVICES, INC. is under common control with the firm.
WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
This firm is directly or indirectly, controlled by the following:
· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank
Effective Date:
Business Address:
Description: WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANT.
RAYMOND JAMES BANK N.A. is a National Bank and controls the firm.
02/01/2012
710 CARILLON PARKWAYST. PETERSBURG, FL 33716
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Firm Operations
Organization Affiliates (continued)
Effective Date:
Business Address:
Description: PARENT OF APPLICANT.
RAYMOND JAMES FINANCIAL, INC. is a Bank Holding Company and controls the firm.
02/01/2012
880 CARILLON PARKWAYST. PETERSBURG, FL 33716
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Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.
Final On AppealPending
Regulatory Event 1 120 0
Arbitration N/A 73 N/A
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Disclosure Event Details
What you should know about reported disclosure events:
1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.
2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a
particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:
o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.
4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.
§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently
being appealed.§ A "final" event has been concluded and its resolution is not subject to change.
o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,
or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.
§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.
§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.
5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.
Regulatory - Final
This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.
Disclosure 1 of 120
Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THATIT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONSPOSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATECERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE,THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCESWITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS INAPPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVEREDQUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATEACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORTPOSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTEDPOSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTEDPOSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTEDPOSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATEQUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTINGOF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPRSUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTSACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRMALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITHRESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS,INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER,FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.
Current Status: Final
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Initiated By: NYSE ARCA, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/08/2018
Docket/Case Number: 20160501987
Principal Product Type: Options
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THATIT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONSPOSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATECERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE,THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCESWITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS INAPPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVEREDQUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATEACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORTPOSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTEDPOSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTEDPOSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTEDPOSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATEQUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTINGOF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPRSUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTSACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRMALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITHRESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS,INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER,FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.
Resolution: Decision & Order of Offer of Settlement 28©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Resolution Date: 05/08/2018
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH$200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAININGAMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT AWRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALLTHE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THEDECISION.
Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,NYSE ARCA CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OFEXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TOCONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTINGSYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESEFINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADETO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORYPRACTICES AND PROCEDURES.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $200,000.00
Decision & Order of Offer of Settlement
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THATIT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONSPOSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATECERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE,THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCESWITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS INAPPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVEREDQUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATEACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORTPOSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTEDPOSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTEDPOSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTEDPOSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATEQUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTINGOF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPRSUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTSACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRMALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITHRESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS,INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER,FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.
Current Status: Final
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Initiated By: NYSE ARCA, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
MONETARY FINE & UNDERTAKING
Date Initiated: 05/08/2018
Docket/Case Number: 20160501987
Principal Product Type: Options
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THATIT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONREPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONSPOSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATECERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE,THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCESWITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS INAPPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVEREDQUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATEACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORTPOSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTEDPOSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTEDPOSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTEDPOSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATEQUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTINGOF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPRSUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTSACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRMALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITHRESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS,INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER,FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.
Resolution Date: 05/08/2018
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH$200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAININGAMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT AWRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALLTHE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THEDECISION.
Sanctions Ordered: CensureMonetary/Fine $200,000.00
Decision & Order of Offer of Settlement
30©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH$200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAININGAMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT AWRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALLTHE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THEDECISION.
Firm Statement IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,NYSE ARCA CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OFEXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TOCONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTINGSYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESEFINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADETO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORYPRACTICES AND PROCEDURES.
Disclosure 2 of 120
i
Reporting Source: Regulator
Initiated By: NASDAQ ISE, LLC
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/17/2017
Docket/Case Number: 2016048918401
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HADIMPROPERLY USED THE INTERNATIONAL SECURITIES EXCHANGE'S (ISE)SOLICITED ORDER MECHANISM (SOM) AND FAILED TO ADEQUATELYSUPERVISE IN CONNECTION WITH ITS USE.
THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM IMPROPERLY USEDTHE SOM TO CROSS ORDERS THAT DID NOT INVOLVE SOLICITED CONTRAORDERS ON 23 OCCASIONS DURING THE REVIEW PERIOD. THE FIRMFAILED TO HAVE ANY SUPERVISORY SYSTEMS AND CONTROLS IN PLACE,INCLUDING WRITTEN SUPERVISORY PROCEDURES AND SEPARATESYSTEMS OF FOLLOW-UP AND REVIEW, WHICH WERE DESIGNED TOENSURE COMPLIANCE WITH ISE RULES RELATED TO THE PROPER USE OFTHE SOM.
Current Status: Final
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Other Sanction(s)/ReliefSought:
Resolution Date: 07/17/2017
Resolution:
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000.
Regulator Statement ASSOCIATED MATTER INCLUDES ISE FILE NOS. 2015-265, 2016-036, AND2016-247
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $20,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: NASDAQ ISE, LLC
Principal Sanction(s)/ReliefSought:
Date Initiated: 03/17/2017
Docket/Case Number: 2016048918401
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HADIMPROPERLY USED THE INTERNATIONAL SECURITIES EXCHANGE'S (ISE)SOLICITED ORDER MECHANISM (SOM) AND FAILED TO ADEQUATELYSUPERVISE IN CONNECTION WITH ITS USE. THE FINDINGS STATED THATSPECIFICALLY, THE FIRM IMPROPERLY USED THE SOM TO CROSSORDERS THAT DID NOT INVOLVE SOLICITED CONTRA ORDERS ON 23OCCASIONS DURING THE REVIEW PERIOD. THE FIRM FAILED TO HAVE ANYSUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING WRITTENSUPERVISORY PROCEDURES AND SEPARATE SYSTEMS OF FOLLOW-UPAND REVIEW, WHICH WERE DESIGNED TO ENSURE COMPLIANCE WITH ISERULES RELATED TO THE PROPER USE OF THE SOM.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 07/17/2017
Resolution:
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000.00.
Firm Statement ASSOCIATED MATTER INCLUDES ISE FILE NOS. 2015-265, 2016-036, AND2016-247.
Sanctions Ordered: CensureMonetary/Fine $20,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 3 of 120
i
Reporting Source: Regulator
Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 03/09/2017
Docket/Case Number: 65556-S
URL for Regulatory Action:
Principal Product Type: No Product
Other Product Type(s):
Allegations: N/A
Current Status: Final
Resolution Date: 03/09/2017
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Order
33©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Other Sanctions Ordered: N/A
Sanction Details: 03/09/2017 - $10,000 ADMINISTRATIVE FINE PAID IN FULL.
Regulator Statement ON MARCH 9, 2017, THE OFFICE OF FINANCIAL REGULATION ENTERED AFINAL ORDER AGAINSTRAYMOND JAMES & ASSOCIATES, INC., ADOPTING THE STIPULATION ANDCONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES &ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC., ACCEPTS ANDCONSENTS, WITHOUT ADMITTING OR DENYING THE FINDINGS BY THEOFFICE. THE OFFICE FOUND THAT RAYMOND JAMES & ASSOCIATES, INC.,FAILED TO ENFORCE, CREATE AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES RELATING TO NON-REGISTERED RESIDENTIAL LOCATIONS.RAYMOND JAMES & ASSOCIATES, INC., AGREED TO PAY ANADMINISTRATIVE FINE OF $10,000.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $10,000.00Cease and Desist/Injunction
iReporting Source: Firm
Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 03/09/2017
Docket/Case Number: 65556-S
Principal Product Type: No Product
Other Product Type(s):
Allegations: N/A
Current Status: Final
Resolution Date: 03/09/2017
Resolution: Order
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Resolution Date: 03/09/2017
Other Sanctions Ordered: N/A
Sanction Details: 03/09/2017 - $10,000 ADMINISTRATIVE FINE PAID IN FULL.
Firm Statement ON MARCH 9, 2017, THE OFFICE OF FINANCIAL REGULATION ENTERED AFINAL ORDER AGAINST RAYMOND JAMES & ASSOCIATES, INC., ADOPTINGTHE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OFRAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES,INC., ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THEFINDINGS BY THE OFFICE. THE FINDINGS BY THE OFFICE OF FINANCIALREGULATION INCLUDE A FAILURE TO EXAMINE A NON-REGISTEREDRESIDENCE LOCATION ("NRL"), CREATE AND MAINTAIN WSPS FOR SUCHNRL, AND MAINTAIN WRITTEN REPORTS OF ITS INSPECTION AND REVIEWOF ITS NRLS.
Sanctions Ordered: Monetary/Fine $10,000.00Cease and Desist/Injunction
Disclosure 4 of 120
i
Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT LACKED AREASONABLE SUPERVISORY SYSTEM, INCLUDING WRITTENSUPERVISORY PROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS,INCLUDING ONGOING REVIEWS OF DAILY TRADE BLOTTERS OF ITSCONVERTIBLE BONDS DESK FOR A SPECIFIC TRADING PATTERN, AS WELLAS COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS, INCLUDING SECTION 206(3) OF THE INVESTMENTSADVISERS ACT OF 1940. THE FINDINGS STATED THAT THE FIRM'SCONVERTIBLE BONDS DESK, IN 99 INSTANCES, SOLD BONDS TO ANOTHERBROKER-DEALER IN A PRINCIPAL CAPACITY AND CONCURRENTLY (WITHINA FEW MINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OFBONDS FROM THE BROKER-DEALER IN AN AGENCY CAPACITY FOR A FIRMADVISORY CLIENT OR CLIENTS, OR PURCHASED THE SAME AMOUNT OFBONDS FROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR ANADVISORY CLIENT OR ADVISORY CLIENTS OF THE FIRM'S AFFILIATE.SINCE THE FIRM'S CONVERTIBLE BONDS WERE OFFERED ON ACONDITIONAL BASIS, ITS CONVERTIBLE BONDS DESK NEEDED TOMANUALLY ACCEPT ANY ATTEMPT BY A THIRD PARTY TO LIFT ITS OFFEROFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THECONVERTIBLE BONDS DESK KNEW THAT THERE WAS AN ATTEMPT TO LIFTTHE FIRM'S INVENTORY FOR THE EXACT SAME QUANTITY OF THE SAMECONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TOBUY SUCH BONDS FOR AN ADVISORY CLIENT. WHILE THE FIRM'S WSPSPERTAINING TO MANAGED ACCOUNTS GENERALLY PROHIBITEDPRINCIPAL TRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION)AND ESTABLISHED TRADING SYSTEM FUNCTIONALITY LIMITATIONS TOPRECLUDE PRINCIPAL FILLS DIRECTLY FOR ADVISORY CLIENTS, THEFIRM'S SUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDSTRADING DID NOT INCLUDE, AMONG OTHER THINGS, ONGOING REVIEWSOF DAILY TRADE BLOTTERS THAT MIGHT DETECT POTENTIALLY VIOLATIVECONDUCT SUCH AS THE SPECIFIC TRADING PATTERN AT ISSUE.
Current Status: Final
35©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/02/2017
Docket/Case Number: 2011030345701
Principal Product Type: No Product
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT LACKED AREASONABLE SUPERVISORY SYSTEM, INCLUDING WRITTENSUPERVISORY PROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS,INCLUDING ONGOING REVIEWS OF DAILY TRADE BLOTTERS OF ITSCONVERTIBLE BONDS DESK FOR A SPECIFIC TRADING PATTERN, AS WELLAS COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDREGULATIONS, INCLUDING SECTION 206(3) OF THE INVESTMENTSADVISERS ACT OF 1940. THE FINDINGS STATED THAT THE FIRM'SCONVERTIBLE BONDS DESK, IN 99 INSTANCES, SOLD BONDS TO ANOTHERBROKER-DEALER IN A PRINCIPAL CAPACITY AND CONCURRENTLY (WITHINA FEW MINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OFBONDS FROM THE BROKER-DEALER IN AN AGENCY CAPACITY FOR A FIRMADVISORY CLIENT OR CLIENTS, OR PURCHASED THE SAME AMOUNT OFBONDS FROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR ANADVISORY CLIENT OR ADVISORY CLIENTS OF THE FIRM'S AFFILIATE.SINCE THE FIRM'S CONVERTIBLE BONDS WERE OFFERED ON ACONDITIONAL BASIS, ITS CONVERTIBLE BONDS DESK NEEDED TOMANUALLY ACCEPT ANY ATTEMPT BY A THIRD PARTY TO LIFT ITS OFFEROFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THECONVERTIBLE BONDS DESK KNEW THAT THERE WAS AN ATTEMPT TO LIFTTHE FIRM'S INVENTORY FOR THE EXACT SAME QUANTITY OF THE SAMECONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TOBUY SUCH BONDS FOR AN ADVISORY CLIENT. WHILE THE FIRM'S WSPSPERTAINING TO MANAGED ACCOUNTS GENERALLY PROHIBITEDPRINCIPAL TRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION)AND ESTABLISHED TRADING SYSTEM FUNCTIONALITY LIMITATIONS TOPRECLUDE PRINCIPAL FILLS DIRECTLY FOR ADVISORY CLIENTS, THEFIRM'S SUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDSTRADING DID NOT INCLUDE, AMONG OTHER THINGS, ONGOING REVIEWSOF DAILY TRADE BLOTTERS THAT MIGHT DETECT POTENTIALLY VIOLATIVECONDUCT SUCH AS THE SPECIFIC TRADING PATTERN AT ISSUE.
Resolution Date: 03/02/2017
Resolution:
Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS
Sanction Details: THE FIRM WAS CENSURED, FINED $180,000 AND UNDERTAKES TO REVISETHE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESSTRAINING OF ASSOCIATED PERSONS. FINES PAID IN FULL ON 4/1/17.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $180,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT LACKED A REASONABLE SUPERVISORYSYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS, INCLUDINGONGOING REVIEWS OF DAILY TRADEBLOTTERS OF ITS CONVERTIBLE BONDS DESK FOR SPECIFIC TRADINGPATTERNS. THE FINDINGS STATED THAT THE FIRM'S CONVERTIBLEBONDS DESK, IN 99 INSTANCES,SOLD BONDS TO ANOTHER BROKER-DEALER IN A PRINCIPAL CAPACITYAND CONCURRENTLY (WITHIN A FEWMINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OF BONDSFROM THE BROKER-DEALER IN ANAGENCY CAPACITY FOR A FIRM ADVISORY CLIENT OR CLIENTS, ORPURCHASED THE SAME AMOUNT OF BONDSFROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR AN ADVISORYCLIENT OR ADVISORY CLIENTS OF THEFIRM'S AFFILIATE. SINCE THE FIRM'S CONVERTIBLE BONDS WEREOFFERED ON A CONDITIONAL BASIS, ITSCONVERTIBLE BONDS DESK NEEDED TO MANUALLY ACCEPT ANYATTEMPT BY A THIRD PARTY TO LIFT ITS OFFEROFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THECONVERTIBLE BONDS DESK KNEW THATTHERE WAS AN ATTEMPT TO LIFT THE FIRM'S INVENTORY FOR THE EXACTSAME QUANTITY OF THE SAMECONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TOBUY SUCH BONDS FOR AN ADVISORYCLIENT. WHILE THE FIRM'S WSPS PERTAINING TO MANAGED ACCOUNTSGENERALLY PROHIBITED PRINCIPALTRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION) ANDESTABLISHED TRADING SYSTEMFUNCTIONALITY LIMITATIONS TO PRECLUDE PRINCIPAL FILLS DIRECTLYFOR ADVISORY CLIENTS, THE FIRM'SSUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDS TRADING DIDNOT INCLUDE, AMONG OTHER THINGS,ONGOING REVIEWS OF DAILY TRADE BLOTTERS THAT MIGHT DETECTPOTENTIALLY VIOLATIVE CONDUCT SUCHAS THE SPECIFIC TRADING PATTERN AT ISSUE.
Current Status: Final
36©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Date Initiated: 03/02/2017
Docket/Case Number: 2011030345701
Principal Product Type: No Product
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT LACKED A REASONABLE SUPERVISORYSYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS, INCLUDINGONGOING REVIEWS OF DAILY TRADEBLOTTERS OF ITS CONVERTIBLE BONDS DESK FOR SPECIFIC TRADINGPATTERNS. THE FINDINGS STATED THAT THE FIRM'S CONVERTIBLEBONDS DESK, IN 99 INSTANCES,SOLD BONDS TO ANOTHER BROKER-DEALER IN A PRINCIPAL CAPACITYAND CONCURRENTLY (WITHIN A FEWMINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OF BONDSFROM THE BROKER-DEALER IN ANAGENCY CAPACITY FOR A FIRM ADVISORY CLIENT OR CLIENTS, ORPURCHASED THE SAME AMOUNT OF BONDSFROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR AN ADVISORYCLIENT OR ADVISORY CLIENTS OF THEFIRM'S AFFILIATE. SINCE THE FIRM'S CONVERTIBLE BONDS WEREOFFERED ON A CONDITIONAL BASIS, ITSCONVERTIBLE BONDS DESK NEEDED TO MANUALLY ACCEPT ANYATTEMPT BY A THIRD PARTY TO LIFT ITS OFFEROFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THECONVERTIBLE BONDS DESK KNEW THATTHERE WAS AN ATTEMPT TO LIFT THE FIRM'S INVENTORY FOR THE EXACTSAME QUANTITY OF THE SAMECONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TOBUY SUCH BONDS FOR AN ADVISORYCLIENT. WHILE THE FIRM'S WSPS PERTAINING TO MANAGED ACCOUNTSGENERALLY PROHIBITED PRINCIPALTRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION) ANDESTABLISHED TRADING SYSTEMFUNCTIONALITY LIMITATIONS TO PRECLUDE PRINCIPAL FILLS DIRECTLYFOR ADVISORY CLIENTS, THE FIRM'SSUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDS TRADING DIDNOT INCLUDE, AMONG OTHER THINGS,ONGOING REVIEWS OF DAILY TRADE BLOTTERS THAT MIGHT DETECTPOTENTIALLY VIOLATIVE CONDUCT SUCHAS THE SPECIFIC TRADING PATTERN AT ISSUE.
37©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Other Product Type(s):
Resolution Date: 03/02/2017
Resolution:
Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS.
Sanction Details: THE FIRM WAS CENSURED, FINED $180,000 AND UNDERTAKES TO REVISETHE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESSTRAINING OF ASSOCIATED PERSONS. THE FINE WAS PAID ON MARCH 24,2017.
Sanctions Ordered: CensureMonetary/Fine $180,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 5 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Date Initiated: 09/20/2016
Docket/Case Number: 2014042145301
Principal Product Type: Other
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER ORDERS TRADED FOR ITS OWN ACCOUNT ATPRICES THAT WOULD HAVE SATISFIED THE CUSTOMER ORDERS, ANDFAILED TO EXECUTE OR IMMEDIATELY EXECUTE THE CUSTOMER ORDERSIN OVER-THE COUNTER (OTC) SECURITIES UP TO THE SIZE AND AT THESAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT ABETTER PRICE. THE FINDINGS STATED THAT IN SEVERAL INSTANCES THEFIRM FAILED TO MAKE EVERY EFFORT TO CROSS A MARKETABLECUSTOMER ORDER WITH ANOTHER ORDER RECEIVED BY THE FIRM ONTHE OPPOSITE SIDE OF THE MARKET. FURTHER, ON MULTIPLEOCCASIONS INVOLVING EITHER A TRADING AHEAD AND/OR CROSSINGFAILURE, THE FIRM FAILED TO EXECUTE A MARKETABLE CUSTOMERORDER FULLY AND PROMPTLY.
Current Status: Final
38©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type: Other
Other Product Type(s): OTC SECURITIES
Resolution Date: 09/20/2016
Resolution:
Other Sanctions Ordered: INTEREST
Sanction Details: THE FIRM WAS FINED $5,000, AND ORDERED TO PAY $601.83, PLUSINTEREST IN RESTITUTION TO CUSTOMERS.FINE PAID IN FULL ON OCTOBER 5, 2016.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $5,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: FINRA
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER ORDERS TRADED FOR ITSOWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMERORDERS, AND FAILED TO EXECUTE OR IMMEDIATELY EXECUTE THECUSTOMER ORDERS IN OVER-THE COUNTER (OTC)SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH ITTRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGSSTATED THAT IN SEVERAL INSTANCES THE FIRMFAILED TO MAKE EVERY EFFORT TO CROSS A MARKETABLE CUSTOMERORDER WITH ANOTHER ORDER RECEIVED BY THE FIRM ON THEOPPOSITE SIDE OF THE MARKET. FURTHER, ON MULTIPLEOCCASIONS INVOLVING EITHER A TRADING AHEAD AND/OR CROSSINGFAILURE, THE FIRM FAILED TO EXECUTE A MARKETABLE CUSTOMERORDER FULLY AND PROMPTLY.
Current Status: Final
39©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/20/2016
Docket/Case Number: 2014042145301
Principal Product Type: Other
Other Product Type(s): OTC SECURITIES
Resolution Date: 09/20/2016
Resolution:
Other Sanctions Ordered: INTEREST
Sanction Details: THE FIRM WAS FINED $5000.00, AND ORDERED TO PAY $601.83, PLUSINTEREST IN RESTITUTION TO CUSTOMERS. THE FINE WAS PAID ON10/4/16.
Sanctions Ordered: Monetary/Fine $5,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 6 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Date Initiated: 09/12/2016
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZEOF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITYSECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULDHAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTENSUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THEMINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDINGFINRA RULE 6460.
Current Status: Final
40©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/12/2016
Docket/Case Number: 2014043168701
Principal Product Type: Equity - OTC
Other Product Type(s):
Resolution Date: 09/12/2016
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE FIRM WAS CENSURED, FINED $30,000 AND UNDERTAKES TO REVISEITS WSPS WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, ANDWITHIN 30 BUSINESS DAYS OF THE AWC, A REGISTERED PRINCIPLE OFTHE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATED LETTER, OR AN E-MAIL PROVIDING THE FOLLOWING INFORMATION: A REFERENCE TO THISMATTER; A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS, TOADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC; AND, THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED.FINED PAID IN FULL ON OCTOBER 3, 2016.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $30,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZEOF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITYSECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULDHAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTENSUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THEMINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDINGFINRA RULE 6460.
Current Status: Final
41©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/12/2016
Docket/Case Number: 2014043168701
Principal Product Type: Equity - OTC
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZEOF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITYSECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULDHAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTENSUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THEMINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDINGFINRA RULE 6460.
Resolution Date: 09/12/2016
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE FIRM WAS CENSURED, FINED $30,000 AND UNDERTAKES TO REVISEITS WSPS WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, ANDWITHIN 30 BUSINESS DAYS OF THE AWC, A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATED LETTER, OR AN E-MAIL PROVIDING THE FOLLOWING INFORMATION: A REFERENCE TO THISMATTER; A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS, TOADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC; AND, THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED. PAYMENT WAS SENTON 9/28/16.
Sanctions Ordered: CensureMonetary/Fine $30,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 7 of 120
i
Reporting Source: Regulator
Allegations: SEC IA RELEASE 4525/SEPTEMBER 8, 2016: THE SECURITIES ANDEXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE THATCEASE AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF1940 (ADVISERS ACT), AGAINST RAYMOND JAMES & ASSOCIATES, INC.THIS MATTER ARISES FROM THE FIRM'S FAILURE TO ADOPT ANDIMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT VIOLATIONS OF THE ADVISERS ACT RELATING TO TRADINGCOMMISSIONS CHARGED TO ADVISORY CLIENTS IN THE FIRM'SCONSULTING SERVICES PROGRAM. UNDER THE CONSULTING SERVICESPROGRAM, THE FIRM'S ADVISORY CLIENTS SELECT A PARTICIPATING SUB-ADVISER TO DEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELYMANAGED ACCOUNT. THE FIRM CHARGES THE CONSULTING SERVICESPROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THEWRAP FEE, ADVISORY CLIENTS ALSO PAID COMMISSIONS ON EQUITYTRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITHTHE FIRM. ALTHOUGH THE FIRM'S FORM ADV PART 2A BROCHURESDISCLOSE THAT A SUB-ADVISER MAY DIRECT ITS TRADING TO FIRMSUNAFFILIATED WITH THE FIRM AND THAT THE COMMISSIONS ASSOCIATEDWITH SUCH TRANSACTIONS WILL BE IN ADDITION TO THE WRAP FEE, THEFIRM DID NOT OBTAIN INFORMATION REGARDING THE AMOUNT OFCOMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THATAMOUNT WAS MATERIAL. INSTEAD, THE FIRM RECEIVED INFORMATIONREGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITHTHE EQUITY COMMISSION COST INCLUDED IN THE PRICE OF THESECURITY. THE CONSULTING SERVICES PROGRAM CLIENTS ALSO WEREUNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING AWAYBECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICESCHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATIONABOUT COMMISSIONS FROM ANY OTHER SOURCE. THE FIRM FAILED TOADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLYDESIGNED TO ALLOW IT TO DETERMINE WHETHER THE CONSULTINGSERVICES PROGRAM OR PARTICULAR SUB-ADVISERS WERE SUITABLEFOR ITS PROSPECTIVE AND EXISTING ADVISORY CLIENTS, SUCH ASCOLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDINGCOMMISSIONS ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRMHAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO CONSULTINGSERVICES PROGRAM CLIENTS THE SUB-ADVISERS' TRADING AWAYPRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTSDID NOT NECESSARILY HAVE ADEQUATE INFORMATION: (I) TO NEGOTIATEMEANINGFULLY THE WRAP FEE WITH THE FIRM; (II) TO ASSESS THE TOTALCOSTS OF THE CONSULTING SERVICES PROGRAM; AND (III) TODETERMINE WHICH CONSULTING SERVICES PROGRAM SUB-ADVISERS TOSELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRMVIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7THEREUNDER.
Current Status: Final
42©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
SEC IA RELEASE 4525/SEPTEMBER 8, 2016: THE SECURITIES ANDEXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE THATCEASE AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF1940 (ADVISERS ACT), AGAINST RAYMOND JAMES & ASSOCIATES, INC.THIS MATTER ARISES FROM THE FIRM'S FAILURE TO ADOPT ANDIMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT VIOLATIONS OF THE ADVISERS ACT RELATING TO TRADINGCOMMISSIONS CHARGED TO ADVISORY CLIENTS IN THE FIRM'SCONSULTING SERVICES PROGRAM. UNDER THE CONSULTING SERVICESPROGRAM, THE FIRM'S ADVISORY CLIENTS SELECT A PARTICIPATING SUB-ADVISER TO DEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELYMANAGED ACCOUNT. THE FIRM CHARGES THE CONSULTING SERVICESPROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THEWRAP FEE, ADVISORY CLIENTS ALSO PAID COMMISSIONS ON EQUITYTRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITHTHE FIRM. ALTHOUGH THE FIRM'S FORM ADV PART 2A BROCHURESDISCLOSE THAT A SUB-ADVISER MAY DIRECT ITS TRADING TO FIRMSUNAFFILIATED WITH THE FIRM AND THAT THE COMMISSIONS ASSOCIATEDWITH SUCH TRANSACTIONS WILL BE IN ADDITION TO THE WRAP FEE, THEFIRM DID NOT OBTAIN INFORMATION REGARDING THE AMOUNT OFCOMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THATAMOUNT WAS MATERIAL. INSTEAD, THE FIRM RECEIVED INFORMATIONREGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITHTHE EQUITY COMMISSION COST INCLUDED IN THE PRICE OF THESECURITY. THE CONSULTING SERVICES PROGRAM CLIENTS ALSO WEREUNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING AWAYBECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICESCHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATIONABOUT COMMISSIONS FROM ANY OTHER SOURCE. THE FIRM FAILED TOADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLYDESIGNED TO ALLOW IT TO DETERMINE WHETHER THE CONSULTINGSERVICES PROGRAM OR PARTICULAR SUB-ADVISERS WERE SUITABLEFOR ITS PROSPECTIVE AND EXISTING ADVISORY CLIENTS, SUCH ASCOLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDINGCOMMISSIONS ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRMHAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO CONSULTINGSERVICES PROGRAM CLIENTS THE SUB-ADVISERS' TRADING AWAYPRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTSDID NOT NECESSARILY HAVE ADEQUATE INFORMATION: (I) TO NEGOTIATEMEANINGFULLY THE WRAP FEE WITH THE FIRM; (II) TO ASSESS THE TOTALCOSTS OF THE CONSULTING SERVICES PROGRAM; AND (III) TODETERMINE WHICH CONSULTING SERVICES PROGRAM SUB-ADVISERS TOSELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRMVIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7THEREUNDER.
43©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 09/08/2016
Docket/Case Number: 3-17531
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Resolution Date: 09/08/2016
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE FIRM WAS ORDERED TO CEASE AND DESIST, FINED $600,000 ANDORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THEORDER.
Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING ACEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBEDABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, ANDRULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THECOMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONSAGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDEREDTHAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRMSHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE ORDER.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: Monetary/Fine $600,000.00Cease and Desist/Injunction
Order
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IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING ACEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBEDABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, ANDRULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THECOMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONSAGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDEREDTHAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRMSHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE ORDER.
iReporting Source: Firm
Allegations: THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURESRELATING TO TRADING COMMISSIONS CHARGED TO CLIENTSPARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS")SEPARATELY MANAGED ACCOUNT PROGRAM. UNDER THE RJCSPROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TODEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELY MANAGEDACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE, RJA CLIENTS ALSO WEREASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONSEXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA. ALTHOUGHRJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENTMANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH RJAAND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILLBE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOTOBTAIN INFORMATION REGARDING THE AMOUNT OF COMMISSIONSCHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WASMATERIAL. INSTEAD, RJA RECEIVED INFORMATION REGARDING THESESECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITYCOMMISSION COST INCLUDED IN THE PRICE OF THE SECURITY. RJCSPROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUALCOMMISSIONS INCURRED FOR TRADING AWAY BECAUSE THEIR ACCOUNTSTATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITYTRADE AND THEY DID NOT RECEIVE INFORMATION ABOUT COMMISSIONSFROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT ANDIMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TOALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULARINVESTMENT MANAGERS WERE SUITABLE FOR ITS PROSPECTIVE ANDEXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING ANDDISCLOSING INFORMATION REGARDING COMMISSIONS ASSOCIATED WITHTRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES ANDPROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THEINVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATEDCOSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVEADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAPFEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM;AND (III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERSTO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRMVIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7THEREUNDER.
Current Status: Final
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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 09/08/2016
Docket/Case Number: 3-17531
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURESRELATING TO TRADING COMMISSIONS CHARGED TO CLIENTSPARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS")SEPARATELY MANAGED ACCOUNT PROGRAM. UNDER THE RJCSPROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TODEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELY MANAGEDACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE, RJA CLIENTS ALSO WEREASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONSEXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA. ALTHOUGHRJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENTMANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH RJAAND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILLBE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOTOBTAIN INFORMATION REGARDING THE AMOUNT OF COMMISSIONSCHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WASMATERIAL. INSTEAD, RJA RECEIVED INFORMATION REGARDING THESESECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITYCOMMISSION COST INCLUDED IN THE PRICE OF THE SECURITY. RJCSPROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUALCOMMISSIONS INCURRED FOR TRADING AWAY BECAUSE THEIR ACCOUNTSTATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITYTRADE AND THEY DID NOT RECEIVE INFORMATION ABOUT COMMISSIONSFROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT ANDIMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TOALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULARINVESTMENT MANAGERS WERE SUITABLE FOR ITS PROSPECTIVE ANDEXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING ANDDISCLOSING INFORMATION REGARDING COMMISSIONS ASSOCIATED WITHTRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES ANDPROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THEINVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATEDCOSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVEADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAPFEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM;AND (III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERSTO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRMVIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7THEREUNDER.
Resolution Date: 09/08/2016
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLYWITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WASPAID ON 10/12/16.
Firm Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING ACEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBEDABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, ANDRULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THECOMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONSAGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDEREDTHAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRMSHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE ORDER.
Sanctions Ordered: Monetary/Fine $600,000.00Cease and Desist/Injunction
Order
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IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING ACEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBEDABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, ANDRULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THECOMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONSAGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDEREDTHAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRMSHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE ORDER.
Disclosure 8 of 120
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Reporting Source: Firm
Initiated By: STATE OF VERMONT, DEPARTMENT OF FINANCIAL REGULATION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST ORDER
Date Initiated: 06/29/2016
Docket/Case Number: 16-026-S
Principal Product Type: No Product
Other Product Type(s):
Allegations: VIOLATION OF 9 VERMONT SECURITIES ACT (VSA) 5412(D)(9)
Current Status: Final
Resolution Date: 06/29/2016
Resolution:
Other Sanctions Ordered:
Sanction Details: RJA SHALL CEASE AND DESIST FROM VIOLATING SECTION 5412(D)(9) OFTHE VERMONT UNIFORM SECURITIES ACT (VUSA) AND WILL COMPLY WITHALL APPLICABLE PROVISIONS OF THE VUSA. WITHIN TEN (10) BUSINESSDAYS OF THE DATE OF THIS ORDER, RJA SHALL PAY TO THE DEPARTMENTOF FINANCIAL REGULATION (DFR) THE SUM OF $1,450,0000, OF WHICH$1,250,000 REPRESENTS AN ADMINISTRATIVE PENALTY AND $200,000SHALL REIMBURSE THE OFR FOR ITS COSTS. THE COMMISSIONERDIRECTS THAT WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THISORDER RJA PAY $4,500,000 TO THE RECEIVER APPOINTED IN THE MATTERENTITLED SEC V. QUIROS, NO.1:16-CV-21301-DPG (S.D. FLA.) FOR THESOLE PURPOSE OF REIMBURSINGCLAIMS BY THE EB-5 INVESTORS. THE SUM OF $2,750,000 REPRESENTSTHE TOTAL REVENUES EARNED BY RJA AND THE REGISTEREDREPRESENTATIVE IN CONNECTION WITH THE QUIROS-CONTROLLEDACCOUNTS, AND THE BALANCE REPRESENTS RESTITUTION. THE FINESWERE PAID ON JULY 7, 2016.
Sanctions Ordered: Monetary/Fine $5,950,000.00Disgorgement/RestitutionCease and Desist/Injunction
Order
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RJA SHALL CEASE AND DESIST FROM VIOLATING SECTION 5412(D)(9) OFTHE VERMONT UNIFORM SECURITIES ACT (VUSA) AND WILL COMPLY WITHALL APPLICABLE PROVISIONS OF THE VUSA. WITHIN TEN (10) BUSINESSDAYS OF THE DATE OF THIS ORDER, RJA SHALL PAY TO THE DEPARTMENTOF FINANCIAL REGULATION (DFR) THE SUM OF $1,450,0000, OF WHICH$1,250,000 REPRESENTS AN ADMINISTRATIVE PENALTY AND $200,000SHALL REIMBURSE THE OFR FOR ITS COSTS. THE COMMISSIONERDIRECTS THAT WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THISORDER RJA PAY $4,500,000 TO THE RECEIVER APPOINTED IN THE MATTERENTITLED SEC V. QUIROS, NO.1:16-CV-21301-DPG (S.D. FLA.) FOR THESOLE PURPOSE OF REIMBURSINGCLAIMS BY THE EB-5 INVESTORS. THE SUM OF $2,750,000 REPRESENTSTHE TOTAL REVENUES EARNED BY RJA AND THE REGISTEREDREPRESENTATIVE IN CONNECTION WITH THE QUIROS-CONTROLLEDACCOUNTS, AND THE BALANCE REPRESENTS RESTITUTION. THE FINESWERE PAID ON JULY 7, 2016.
Disclosure 9 of 120
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Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/15/2016
Docket/Case Number: 2013037852901
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT OVERREPORTED TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITYSECURITIES TO THE OVER THE COUNTER REPORTING FACILITY (OTCRF)THAT WERE EXECUTED IN CANADA AND ALSO REPORTED TO THEREGULATOR OF SECURITIES MARKETS FOR THAT COUNTRY. THEFINDINGS STATED THAT THE UNDERLYING SECURITIES WERE DUALLYLISTED IN THE UNITED STATES AND IN CANADA. THE FINDINGS ALSOSTATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDTHE RULES OF FINRA, CONCERNING TRADE REPORTING OFTRANSACTIONS INVOLVING SECURITIES THAT ARE DUALLY LISTED IN THEUNITED STATES AND ANOTHER COUNTRY.
Current Status: Final
Resolution Date: 07/15/2016
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES (WSPS).
Sanction Details: THE FIRM WAS CENSURED, FINED $12,500, AND UNDERTAKES TO REVISEITS WSPS. FINE PAID IN FULL ON AUGUST 1, 2016.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $12,500.00
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/15/2016
Docket/Case Number: 2013037852901
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT OVERREPORTED TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITYSECURITIES TO THE OVER THE COUNTER REPORTING FACILITY (OTCRF)THAT WERE EXECUTED IN CANADA AND ALSO REPORTED TO THEREGULATOR OF SECURITIES MARKETS FOR THAT COUNTRY. THEFINDINGS STATED THAT THE UNDERLYING SECURITIES WERE DUALLYLISTED IN THE UNITED STATES AND IN CANADA. THE FINDINGS ALSOSTATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDTHE RULES OF FINRA, CONCERNING TRADE REPORTING OFTRANSACTIONS INVOLVING SECURITIES THAT ARE DUALLY LISTED IN THEUNITED STATES AND ANOTHER COUNTRY.
Current Status: Final
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Resolution Date: 07/15/2016
Resolution:
Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES (WSPS).
Sanction Details: THE FIRM WAS CENSURED, FINED $12,500, AND UNDERTAKES TO REVISEITS WSPS. THE FINE WAS PAID ON 7/28/16, AND WSPS WERE REVISED ON4/6/2015.
Sanctions Ordered: CensureMonetary/Fine $12,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 10 of 120
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Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITSAMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES ANDPROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OFSUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'SAMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THATTHE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'SBUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING ANDREPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AMLDEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITSAMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRMCREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITSCLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OFTHE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATERESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OFITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVERESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THELABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THEFIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMSREASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRMFAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FORCERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TOESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THEAML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEWACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER,FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILOREDTO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUSTRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTENPROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTSMONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERSOF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENTBUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEENUNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE,PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMERACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; ANDMOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROMMULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'SSURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FORSUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRMFAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THEFIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OFACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTSOR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TOREASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINEWHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AMLANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS,THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRMFAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURESFOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGNFINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NORELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THEACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITHREPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING.THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISKREVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WASASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGHINCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURESTO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICEDSECURITIES.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Date Initiated: 05/18/2016
Docket/Case Number: 2014043592001
Principal Product Type: Annuity(ies) - Variable
Other Product Type(s): LOW PRICED SECURITIES
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITSAMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES ANDPROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OFSUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'SAMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THATTHE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'SBUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING ANDREPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AMLDEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITSAMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRMCREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITSCLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OFTHE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATERESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OFITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVERESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THELABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THEFIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMSREASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRMFAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FORCERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TOESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THEAML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEWACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER,FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILOREDTO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUSTRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTENPROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTSMONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERSOF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENTBUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEENUNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE,PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMERACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; ANDMOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROMMULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'SSURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FORSUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRMFAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THEFIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OFACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTSOR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TOREASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINEWHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AMLANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS,THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRMFAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURESFOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGNFINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NORELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THEACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITHREPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING.THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISKREVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WASASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGHINCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURESTO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICEDSECURITIES.
51©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 05/18/2016
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED $8,000,000 AND REQUIRED TOCONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AMLAND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING.AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THISAWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THECERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THELETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM,STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS,PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) ADESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONSREACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES ANDTRAINING.
FINE PAID IN FULL ON MAY 26, 2016.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $8,000,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITSAMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES ANDPROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OFSUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'SAMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THATTHE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'SBUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING ANDREPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AMLDEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITSAMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRMCREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITSCLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OFTHE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATERESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OFITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVERESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THELABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THEFIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMSREASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRMFAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FORCERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TOESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THEAML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEWACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER,FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILOREDTO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUSTRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTENPROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTSMONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERSOF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENTBUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEENUNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE,PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMERACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; ANDMOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROMMULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'SSURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FORSUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRMFAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THEFIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OFACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTSOR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TOREASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINEWHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AMLANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS,THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRMFAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURESFOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGNFINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NORELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THEACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITHREPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING.THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISKREVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WASASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGHINCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURESTO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICEDSECURITIES.
Current Status: Final
52©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITSAMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES ANDPROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OFSUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'SAMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THATTHE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'SBUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING ANDREPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AMLDEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITSAMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRMCREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITSCLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OFTHE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATERESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OFITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVERESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THELABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THEFIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMSREASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRMFAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FORCERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TOESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THEAML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEWACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER,FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILOREDTO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUSTRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTENPROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTSMONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERSOF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENTBUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEENUNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE,PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMERACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; ANDMOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROMMULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'SSURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FORSUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRMFAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THEFIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OFACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTSOR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TOREASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINEWHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AMLANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS,THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRMFAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURESFOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGNFINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NORELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THEACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITHREPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING.THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISKREVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WASASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGHINCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURESTO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICEDSECURITIES.
53©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/18/2016
Docket/Case Number: 2014043592001
Principal Product Type: Annuity(ies) - Variable
Other Product Type(s): LOW PRICED SECURITIES
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITSAMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES ANDPROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OFSUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'SAMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THATTHE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'SBUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING ANDREPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AMLDEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITSAMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRMCREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITSCLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OFTHE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATERESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OFITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVERESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THELABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THEFIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMSREASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRMFAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FORCERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TOESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THEAML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEWACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER,FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILOREDTO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUSTRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTENPROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTSMONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERSOF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENTBUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEENUNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE,PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMERACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; ANDMOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROMMULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'SSURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FORSUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRMFAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THEFIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OFACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTSOR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TOREASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINEWHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AMLANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS,THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRMFAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURESFOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGNFINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NORELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THEACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITHREPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING.THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISKREVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WASASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THATTHE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGHINCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURESTO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICEDSECURITIES.
Resolution Date: 05/18/2016
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED $8,000,000 AND REQUIRED TOCONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AMLAND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING.AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THISAWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THECERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THELETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM,STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS,PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) ADESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONSREACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES ANDTRAINING. THE $8,000,000 FINE WAS PAID ON 5/26/16.
Sanctions Ordered: CensureMonetary/Fine $8,000,000.00
Acceptance, Waiver & Consent(AWC)
54©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
THE FIRM WAS CENSURED, FINED $8,000,000 AND REQUIRED TOCONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AMLAND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING.AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THISAWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THECERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THELETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM,STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS,PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) ADESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONSREACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES ANDTRAINING. THE $8,000,000 FINE WAS PAID ON 5/26/16.
Disclosure 11 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other
Date Initiated: 03/08/2016
Docket/Case Number: 2013035599201
Principal Product Type: No Product
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSEDCERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROMOTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLICPERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDERTHE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THATTHE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TOPRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMERINFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANYDETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENTBROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HADOBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THECUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDEDCUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF,THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS,INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITHREGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THEFIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLICPERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELYTRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLICPERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES INWHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TOREGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THEFIRM TO ANOTHER BROKER-DEALER, IT WAS UNABLE TO DEMONSTRATETHAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED.
Current Status: Final
55©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
N/A
Resolution Date: 03/08/2016
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED $500,000, AND REQUIRED TO REVIEWAND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNALCONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THE NOTICEOF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICER ANDCHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY IN WRITING TOFINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, (I)THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBED ABOVE; AND (II) ASOF THE DATE OF THE CERTIFICATION, THE FIRM HAS ESTABLISHED ANDIMPLEMENTED POLICIES, PROCEDURES, AND INTERNAL CONTROLSREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934.FINE PAID IN FULL ON MARCH 24, 2016.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $500,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSEDCERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROMOTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLICPERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDERTHE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THATTHE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TOPRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMERINFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANYDETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENTBROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HADOBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THECUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDEDCUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF,THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS,INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITHREGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THEFIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLICPERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELYTRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLICPERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES INWHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TOREGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THEFIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATETHAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED.
Current Status: Final
56©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 03/08/2016
Docket/Case Number: 2013035599201
Principal Product Type: No Product
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSEDCERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROMOTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLICPERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDERTHE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THATTHE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TOPRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMERINFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANYDETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENTBROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HADOBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THECUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDEDCUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF,THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS,INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITHREGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THEFIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLICPERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELYTRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLICPERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES INWHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TOREGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THEFIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATETHAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED.
Resolution Date: 03/08/2016
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEWAND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNALCONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THENOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICERAND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY INWRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED INTHE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBEDABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HASESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNALCONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHREGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934.
Sanctions Ordered: CensureMonetary/Fine $500,000.00
Acceptance, Waiver & Consent(AWC)
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THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEWAND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNALCONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THENOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICERAND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY INWRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED INTHE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBEDABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HASESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNALCONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHREGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934.
Disclosure 12 of 120
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Reporting Source: Regulator
Initiated By: INTERNATIONAL SECURITIES EXCHANGE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 05/08/2015
Docket/Case Number: 2014-131
Principal Product Type: Options
Other Product Type(s):
Allegations: DURING THE REVIEW PERIOD (2/20/14 - 3/28/14) RAYMOND JAMESEXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITHSOLICITED SIZE OF LESS THAN 1000 CONTRACTS.
Current Status: Final
Resolution Date: 05/20/2015
Resolution:
Other Sanctions Ordered:
Sanction Details: RAYMOND JAMES FINED $5000.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $5,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Current Status: Final
58©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: INTERNATIONAL SECURITIES EXCHANGE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 05/08/2015
Docket/Case Number: 2014-131
Principal Product Type: Options
Other Product Type(s):
Allegations: DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMESEXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITHSOLICITED SIZE OF LESS THAN 1000 CONTRACTS.
Resolution Date: 05/20/2015
Resolution:
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS FINED $5000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.
Firm Statement DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMESEXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITHSOLICITED SIZE OF LESS THAN 1000 CONTRACTS. THERE WAS AMONETARY FINE OF $5,000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.
Sanctions Ordered: Monetary/Fine $5,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 13 of 120
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Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEADSOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS BOR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOINGFEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERSWHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANYCONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDESALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIRMUTUAL FUND PURCHASES.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 07/06/2015
Docket/Case Number: 2015044309001
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEADSOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS BOR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOINGFEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERSWHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANYCONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDESALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIRMUTUAL FUND PURCHASES.
Resolution Date: 07/06/2015
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM IS CENSURED, ORDERED TO PAY RESTITUTION IN THE TOTALAMOUNT OF $4,489,553.70 TO CUSTOMERS, AND WITH RESPECT TO ANYCUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDSSUCH SHARES IN AN ACCOUNT AT THE FIRM, THE FIRM UNDERTAKES TOOFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS BOR C SHARES TO CLASS A SHARES AT NO EXPENSE TO THE CUSTOMER.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureDisgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEADSOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS BOR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOINGFEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRMFAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERSWHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANYCONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDESALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIRMUTUAL FUND PURCHASES.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 07/06/2015
Docket/Case Number: 2015044309001
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEADSOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS BOR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOINGFEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRMFAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERSWHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANYCONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDESALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIRMUTUAL FUND PURCHASES.
Resolution Date: 07/06/2015
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: THE FIRM IS CENSURED, ORDERED TO PAY RESTITUTION IN THE TOTALAMOUNT OF $4,489,553.70 TO CUSTOMERS, AND WITH RESPECT TO ANYCUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDSSUCH SHARES IN AN ACCOUNT AT THE FIRM, THE FIRM UNDERTAKES TOOFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS BOR C SHARES TO CLASS A SHARES AT NO EXPENSE TO THE CUSTOMER.
Sanctions Ordered: CensureDisgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 14 of 120
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Reporting Source: Regulator
Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 06/18/2015
Docket/Case Number: 3-16631
Principal Product Type: Debt - Municipal
Other Product Type(s):
Allegations: SEC ADMIN RELEASES 33-9838; 34-75232, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST RAYMONDJAMES & ASSOCIATES, INC. ("RESPONDENT"). RESPONDENT WILLFULLYVIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTERINVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITINGOF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, AREGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUEDILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM AREASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAINMATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED INCONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENTOFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OFMATERIALLY MISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.
Current Status: Final
Resolution Date: 06/18/2015
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Order
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Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.
Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/Injunction
iReporting Source: Firm
Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION")ISSUED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS, SECURITIES ACT RELEASE NO. 9838 DATED JUNE 18, 2015("ORDER") CAPTIONED "IN THE MATTER OF RAYMOND JAMES &ASSOCIATES, INC., RESPONDENT" IN RESPONSE TO AN OFFER OFSETTLEMENT ("OFFER") SUBMITTED BY RAYMOND JAMES & ASSOCIATES,INC. ("RESPONDENT"). RESPONDENT SUBMITTED THE OFFER PURSUANTTO THE TERMS SET FORTH IN THE DIVISION OF ENFORCEMENT'SMUNICIPALITIES CONTINUING DISCLOSURE COOPERATIVE INITIATIVE("MCDC"). RESPONDENT NEITHER ADMITTED NOR DENIED THE FINDINGSCONTAINED IN THE ORDER (OTHER THAN THE FINDINGS PERTAINING TOTHE COMMISSION'S JURISDICTION, WHICH WERE ADMITTED). INCLUDEDIN THE ORDER WERE FINDINGS WITH RESPECT TO THE REQUIREMENT OFCOMMISSION RULE 15C2-12 THAT ISSUERS OR OBLIGATED PERSONSDISCLOSE IN OFFICIAL STATEMENTS THEIR MATERIAL NONCOMPLIANCEIN THE PRECEDING FIVE YEAR PERIOD WITH THEIR CONTINUINGDISCLOSURE OBLIGATIONS, THAT RESPONDENT "CONDUCTEDINADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIALSTATEMENTS IN CONNECTION WITH THOSE OFFERINGS."
Current Status: Final
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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 06/18/2015
Docket/Case Number: 3-16631
Principal Product Type: Debt - Municipal
Other Product Type(s):
Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION")ISSUED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS, SECURITIES ACT RELEASE NO. 9838 DATED JUNE 18, 2015("ORDER") CAPTIONED "IN THE MATTER OF RAYMOND JAMES &ASSOCIATES, INC., RESPONDENT" IN RESPONSE TO AN OFFER OFSETTLEMENT ("OFFER") SUBMITTED BY RAYMOND JAMES & ASSOCIATES,INC. ("RESPONDENT"). RESPONDENT SUBMITTED THE OFFER PURSUANTTO THE TERMS SET FORTH IN THE DIVISION OF ENFORCEMENT'SMUNICIPALITIES CONTINUING DISCLOSURE COOPERATIVE INITIATIVE("MCDC"). RESPONDENT NEITHER ADMITTED NOR DENIED THE FINDINGSCONTAINED IN THE ORDER (OTHER THAN THE FINDINGS PERTAINING TOTHE COMMISSION'S JURISDICTION, WHICH WERE ADMITTED). INCLUDEDIN THE ORDER WERE FINDINGS WITH RESPECT TO THE REQUIREMENT OFCOMMISSION RULE 15C2-12 THAT ISSUERS OR OBLIGATED PERSONSDISCLOSE IN OFFICIAL STATEMENTS THEIR MATERIAL NONCOMPLIANCEIN THE PRECEDING FIVE YEAR PERIOD WITH THEIR CONTINUINGDISCLOSURE OBLIGATIONS, THAT RESPONDENT "CONDUCTEDINADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIALSTATEMENTS IN CONNECTION WITH THOSE OFFERINGS."
Resolution Date: 06/18/2015
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: AS A RESULT THE COMMISSION FOUND THAT RESPONDENT VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. THE COMMISSIONALSO FOUND THAT "[I]N DETERMINING TO ACCEPT RESPONDENT'S OFFER,THE COMMISSION CONSIDERED THE COOPERATION OF RESPONDENT INSELF-REPORTING THE VIOLATIONS." RESPONDENT WAS ORDERED TOCEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIESACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000, ANDCOMPLY WITH THE CERTAIN UNDERTAKINGS, INCLUDING RETENTION OFAN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OFRESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TOMUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.
Sanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/Injunction
Order
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AS A RESULT THE COMMISSION FOUND THAT RESPONDENT VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. THE COMMISSIONALSO FOUND THAT "[I]N DETERMINING TO ACCEPT RESPONDENT'S OFFER,THE COMMISSION CONSIDERED THE COOPERATION OF RESPONDENT INSELF-REPORTING THE VIOLATIONS." RESPONDENT WAS ORDERED TOCEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIESACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000, ANDCOMPLY WITH THE CERTAIN UNDERTAKINGS, INCLUDING RETENTION OFAN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OFRESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TOMUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.
Disclosure 15 of 120
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Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 12/24/2014
Docket/Case Number: 2013036894301
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SECURITIZED PRODUCTS TO TRACE WITHIN THE TIMEREQUIRED BY FINRA RULE 6730(A).
Current Status: Final
Resolution Date: 12/24/2014
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. FINE PAID IN FULL ONDECEMBER 9, 2014.
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 12/24/2014
Docket/Case Number: 2013036894301
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, IN CONNECTION WITHREVIEW NOS. 2013036894301 AND 20140400254, THE FIRM CONSENTED TOTHE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SECURITIZED PRODUCTS TO TRACE WITHIN THE TIMEREQUIRED BY FINRA RULE 6730(A).
Current Status: Final
Resolution Date: 12/24/2014
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND FINDINGS, THEREFORE, THE FIRMWAS CENSURED AND FINED $10,000. FINE PAID IN FULL 12/09/2014.
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 16 of 120
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Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOEXECUTE CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWNMARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIEDEACH CUSTOMER'S LIMIT ORDER. THE FINDINGS STATED THAT THE FIRMFAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERSIN OTC SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITSOWN MARKET-MAKING ACCOUNT, AND IN SOME OF THOSE INSTANCES,FAILED TO EXECUTE THE ORDER AT A PRICE THAT WOULD HAVESATISFIED EACH CUSTOMER'S LIMIT ORDER. IN TRANSACTIONS FOR ORWITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FIRM FAILED TO PUBLISH IMMEDIATELY A BIDOR OFFER THAT REFLECTED THE PRICE AND THE FULL SIZE OFCUSTOMER LIMIT ORDERS FOR OTC EQUITY SECURITIES HELD BY THEFIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OROFFER OF THE FIRM IN SUCH SECURITIES.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 08/15/2014
Docket/Case Number: 2011028038301
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOEXECUTE CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWNMARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIEDEACH CUSTOMER'S LIMIT ORDER. THE FINDINGS STATED THAT THE FIRMFAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERSIN OTC SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITSOWN MARKET-MAKING ACCOUNT, AND IN SOME OF THOSE INSTANCES,FAILED TO EXECUTE THE ORDER AT A PRICE THAT WOULD HAVESATISFIED EACH CUSTOMER'S LIMIT ORDER. IN TRANSACTIONS FOR ORWITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FIRM FAILED TO PUBLISH IMMEDIATELY A BIDOR OFFER THAT REFLECTED THE PRICE AND THE FULL SIZE OFCUSTOMER LIMIT ORDERS FOR OTC EQUITY SECURITIES HELD BY THEFIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OROFFER OF THE FIRM IN SUCH SECURITIES.
Resolution Date: 08/15/2014
Resolution:
Other Sanctions Ordered:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $22,500.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: SEE ABOVE
Regulator Statement FINE PAID IN FULL ON SEPTEMBER 8, 2014.
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 08/15/2014
Docket/Case Number: 2011028038301
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOEXECUTE CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWNMARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIEDEACH CUSTOMER'S LIMIT ORDER. THE FINDINGS STATED THAT THE FIRMFAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERSIN OTC SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITSOWN MARKET-MAKING ACCOUNT, AND IN SOME OF THOSE INSTANCES,FAILED TO EXECUTE THE ORDER AT A PRICE THAT WOULD HAVESATISFIED EACH CUSTOMER'S LIMIT ORDER. IN TRANSACTIONS FOR ORWITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FIRM FAILED TO PUBLISH IMMEDIATELY A BIDOR OFFER THAT REFLECTED THE PRICE AND THE FULL SIZE OFCUSTOMER LIMIT ORDERS FOR OTC EQUITY SECURITIES HELD BY THEFIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OROFFER OF THE FIRM IN SUCH SECURITIES.
Current Status: Final
Resolution Date: 08/15/2014
Resolution: Acceptance, Waiver & Consent(AWC)
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Resolution Date: 08/15/2014
Other Sanctions Ordered:
Sanction Details: SEE ABOVE
Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $22,500.00
Sanctions Ordered: CensureMonetary/Fine $22,500.00Disgorgement/Restitution
Disclosure 17 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Date Initiated: 11/25/2013
Docket/Case Number: 2011026165201
Principal Product Type: No Product
Allegations: SEC RULES 10B-10, 17A-3, NASD RULE 3110 - RAYMOND JAMES &ASSOCIATES, INC. (1) INCORRECTLY DISCLOSED ITS CAPACITY AS AGENTON 22 OCCASIONS FOR ONE ORDER WHEN IT ACTED IN A RISKLESSPRINCIPAL CAPACITY INSTEAD, (2) INCORRECTLY DISCLOSED ITSCAPACITY AS AGENT ON SIX OCCASIONS FORTHREE ORDERS WHEN IT ACTED AS A DUAL AGENT INSTEAD, (3)INCORRECTLY DISCLOSED ITS CAPACITY AS ACTING ONLY AS PRINCIPALON TEN OCCASIONS FOR ONE ORDER WHEN IT ACTEDINSTEAD IN MULTIPLE CAPACITIES AS DUAL AGENT, RISKLESS PRINCIPALAND PRINCIPAL,(4) INCORRECTLY DISCLOSED ITS CAPACITY AS ACTINGONLY AS PRINCIPAL ON THREE OCCASIONS FORONE ORDER WHEN IT ACTED INSTEAD IN MULTIPLE CAPACITIES AS BOTHAGENT AND RISKLESS PRINCIPAL, (5) INCORRECTLY DISCLOSED ITSCAPACITY AS ACTING ONLY AS AGENT ON ONEOCCASION FOR ONE ORDER WHEN IT ACTED IN MULTIPLE CAPACITIES ASDUAL AGENT, RISKLESS PRINCIPAL AND PRINCIPAL, AND (6) INCORRECTLYDISCLOSED ITS COMPENSATION AS A "COMMISSION" WHEN IT ACTED IN ARISKLESS PRINCIPAL CAPACITY ON 22 OCCASIONS FOR ONE ORDER. THEFIRM INCORRECTLY MARKED SHORT SALES AS LONG SALES ONNUMEROUS OCCASIONS ON ITS PROPRIETARY TRADE LEDGER, ANDINCORRECTLY MARKED LONG SALES AS SHORT SALES ON NUMEROUSOCCASIONS ON ITS PROPRIETARY TRADE LEDGER.
Current Status: Final
69©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type: No Product
Other Product Type(s):
Resolution Date: 11/25/2013
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $12,500.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $12,500.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: FINRA ALLEGED SEC RULES 10B-10, 17A-3, NASD RULE 3110 - IT ALLEGEDTHAT RAYMOND JAMES & ASSOCIATES, INC. (1) INCORRECTLY DISCLOSEDITS CAPACITY AS AGENT ON 22 OCCASIONS FOR ONE ORDER WHEN ITACTED IN A RISKLESS PRINCIPAL CAPACITY INSTEAD, (2) INCORRECTLYDISCLOSED ITS CAPACITY AS AGENT ON SIX OCCASIONS FOR THREEORDERS WHEN IT ACTED AS A DUAL AGENT INSTEAD, (3) INCORRECTLYDISCLOSED ITS CAPACITY AS ACTING ONLY AS PRINCIPAL ON TENOCCASIONS FOR ONE ORDER WHEN IT ACTED INSTEAD IN MULTIPLECAPACITIES AS DUAL AGENT, RISKLESS PRINCIPAL AND PRINCIPAL,(4)INCORRECTLY DISCLOSED ITS CAPACITY AS ACTING ONLY AS PRINCIPALON THREE OCCASIONS FOR ONE ORDER WHEN IT ACTED INSTEAD INMULTIPLE CAPACITIES AS BOTH AGENT AND RISKLESS PRINCIPAL, (5)INCORRECTLY DISCLOSED ITS CAPACITY AS ACTING ONLY AS AGENT ONONE OCCASION FOR ONE ORDER WHEN IT ACTED IN MULTIPLECAPACITIES AS DUAL AGENT, RISKLESS PRINCIPAL AND PRINCIPAL, AND(6) INCORRECTLY DISCLOSED ITS COMPENSATION AS A "COMMISSION"WHEN IT ACTED IN A RISKLESS PRINCIPAL CAPACITY ON 22 OCCASIONSFOR ONE ORDER. IT ALLEGED THAT THE FIRM INCORRECTLY MARKEDSHORT SALES AS LONG SALES ON NUMEROUS OCCASIONS ON ITSPROPRIETARY TRADE LEDGER, AND INCORRECTLY MARKED LONG SALESAS SHORT SALES ON NUMEROUS OCCASIONS ON ITS PROPRIETARYTRADE LEDGER.
Current Status: Final
70©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 11/25/2013
Docket/Case Number: 2011026165201
Principal Product Type: No Product
Other Product Type(s):
FINRA ALLEGED SEC RULES 10B-10, 17A-3, NASD RULE 3110 - IT ALLEGEDTHAT RAYMOND JAMES & ASSOCIATES, INC. (1) INCORRECTLY DISCLOSEDITS CAPACITY AS AGENT ON 22 OCCASIONS FOR ONE ORDER WHEN ITACTED IN A RISKLESS PRINCIPAL CAPACITY INSTEAD, (2) INCORRECTLYDISCLOSED ITS CAPACITY AS AGENT ON SIX OCCASIONS FOR THREEORDERS WHEN IT ACTED AS A DUAL AGENT INSTEAD, (3) INCORRECTLYDISCLOSED ITS CAPACITY AS ACTING ONLY AS PRINCIPAL ON TENOCCASIONS FOR ONE ORDER WHEN IT ACTED INSTEAD IN MULTIPLECAPACITIES AS DUAL AGENT, RISKLESS PRINCIPAL AND PRINCIPAL,(4)INCORRECTLY DISCLOSED ITS CAPACITY AS ACTING ONLY AS PRINCIPALON THREE OCCASIONS FOR ONE ORDER WHEN IT ACTED INSTEAD INMULTIPLE CAPACITIES AS BOTH AGENT AND RISKLESS PRINCIPAL, (5)INCORRECTLY DISCLOSED ITS CAPACITY AS ACTING ONLY AS AGENT ONONE OCCASION FOR ONE ORDER WHEN IT ACTED IN MULTIPLECAPACITIES AS DUAL AGENT, RISKLESS PRINCIPAL AND PRINCIPAL, AND(6) INCORRECTLY DISCLOSED ITS COMPENSATION AS A "COMMISSION"WHEN IT ACTED IN A RISKLESS PRINCIPAL CAPACITY ON 22 OCCASIONSFOR ONE ORDER. IT ALLEGED THAT THE FIRM INCORRECTLY MARKEDSHORT SALES AS LONG SALES ON NUMEROUS OCCASIONS ON ITSPROPRIETARY TRADE LEDGER, AND INCORRECTLY MARKED LONG SALESAS SHORT SALES ON NUMEROUS OCCASIONS ON ITS PROPRIETARYTRADE LEDGER.
Resolution Date: 11/25/2013
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $12,500.
Sanctions Ordered: CensureMonetary/Fine $12,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 18 of 120
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Reporting Source: Regulator
Allegations: SEC RULE 10B-10, FINRA RULES 2010, 2265, NASD RULE 3010: THE FIRM:DISCLOSED INCORRECT EXECUTION CAPACITIES ON CONFIRMSCONCERNING ORDERS; INCORRECTLY DISCLOSED IT WAS A REGISTEREDMARKET MAKER IN CONNECTION WITH TRANSACTIONS ON CONFIRMSCONCERNING ORDERS; FAILED TO DISCLOSE THAT IT WAS A REGISTEREDMARKET MAKER WITH RESPECT TO TRANSACTIONS ON CONFIRMSCONCERNING ORDERS; AND FAILED TO DISCLOSE ON CONFIRMS FORORDERS THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE.ON MULTIPLE OCCASIONS, WITH RESPECT TO ORDERS, THE FIRMACCEPTED ORDERS FROM CUSTOMERS THAT WERE EXECUTED INWHOLE OR IN PART IN THE PRE-MARKET SESSION OR POST-MARKETSESSION WITHOUT DISCLOSING TO SUCH CUSTOMERS THAT EXTENDEDHOURS TRADING INVOLVES MATERIAL TRADING RISKS, INCLUDING THEPOSSIBILITY OF LOWER LIQUIDITY, HIGH VOLATILITY, CHANGING PRICES,UNLINKED MARKETS, AN EXAGGERATED EFFECT FROM NEWSANNOUNCEMENTS, WIDER SPREADS AND ANY OTHER RELEVANT RISK.THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOCERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THERULES OF FINRA. AT A MINIMUM, ADEQUATE WRITTEN SUPERVISORYPROCEDURES (WSPS) ADDRESSING QUALITY OF MARKETS TOPICSSHOULD DESCRIBE THE FOLLOWING: SPECIFIC IDENTIFICATION OF THEINDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; THE SUPERVISORYSTEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR;THE FREQUENCY OF SUCH REVIEWS; AND HOW SUCH REVIEWS SHALL BEDOCUMENTED. THE FIRM'S WSPS FAILED TO PROVIDE FOR ONE OR MOREOF THE ABOVE-CITED MINIMUM REQUIREMENTS FOR ADEQUATE WSPS, INTHE FOLLOWING SUBJECT AREAS: REGISTRATION AND QUALIFICATION;TRADE REPORTING; SALES TRANSACTIONS; FIRM QUOTE COMPLIANCE;REVIEW OF CLEARLY ERRONEOUS TRANSACTIONS UNDER FINRA RULES;AND ORDER AUDIT TRAIL SYSTEM.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/27/2013
Docket/Case Number: 2010021597701
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
SEC RULE 10B-10, FINRA RULES 2010, 2265, NASD RULE 3010: THE FIRM:DISCLOSED INCORRECT EXECUTION CAPACITIES ON CONFIRMSCONCERNING ORDERS; INCORRECTLY DISCLOSED IT WAS A REGISTEREDMARKET MAKER IN CONNECTION WITH TRANSACTIONS ON CONFIRMSCONCERNING ORDERS; FAILED TO DISCLOSE THAT IT WAS A REGISTEREDMARKET MAKER WITH RESPECT TO TRANSACTIONS ON CONFIRMSCONCERNING ORDERS; AND FAILED TO DISCLOSE ON CONFIRMS FORORDERS THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE.ON MULTIPLE OCCASIONS, WITH RESPECT TO ORDERS, THE FIRMACCEPTED ORDERS FROM CUSTOMERS THAT WERE EXECUTED INWHOLE OR IN PART IN THE PRE-MARKET SESSION OR POST-MARKETSESSION WITHOUT DISCLOSING TO SUCH CUSTOMERS THAT EXTENDEDHOURS TRADING INVOLVES MATERIAL TRADING RISKS, INCLUDING THEPOSSIBILITY OF LOWER LIQUIDITY, HIGH VOLATILITY, CHANGING PRICES,UNLINKED MARKETS, AN EXAGGERATED EFFECT FROM NEWSANNOUNCEMENTS, WIDER SPREADS AND ANY OTHER RELEVANT RISK.THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOCERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THERULES OF FINRA. AT A MINIMUM, ADEQUATE WRITTEN SUPERVISORYPROCEDURES (WSPS) ADDRESSING QUALITY OF MARKETS TOPICSSHOULD DESCRIBE THE FOLLOWING: SPECIFIC IDENTIFICATION OF THEINDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; THE SUPERVISORYSTEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR;THE FREQUENCY OF SUCH REVIEWS; AND HOW SUCH REVIEWS SHALL BEDOCUMENTED. THE FIRM'S WSPS FAILED TO PROVIDE FOR ONE OR MOREOF THE ABOVE-CITED MINIMUM REQUIREMENTS FOR ADEQUATE WSPS, INTHE FOLLOWING SUBJECT AREAS: REGISTRATION AND QUALIFICATION;TRADE REPORTING; SALES TRANSACTIONS; FIRM QUOTE COMPLIANCE;REVIEW OF CLEARLY ERRONEOUS TRANSACTIONS UNDER FINRA RULES;AND ORDER AUDIT TRAIL SYSTEM.
Resolution Date: 09/27/2013
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Acceptance, Waiver & Consent(AWC)
72©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $15,000 AND UNDERTAKES TOREVISE THE FIRM'S WSPS IN THE AREAS DESCRIBED ABOVE. WITHIN 30BUSINESS DAYS AFTER ACCEPTANCE OF THE AWC, A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN EMAIL FROM A WORK-RELATED ACCOUNT OF THEREGISTERED PRINCIPAL PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HASREVISED ITS WSPS TO ADDRESS THE DEFICIENCIES; AND THE DATE THEREVISED PROCEDURES WERE IMPLEMENTED. FINE PAID IN FULL 10/25/13.
Sanctions Ordered: CensureMonetary/Fine $15,000.00
iReporting Source: Firm
Allegations: FINRA ALLEGED SEC RULE 10B-10 CLIENT CONFIRM VIOLATIONS BECAUSEIT ALLEGED THAT THE FIRM STATED INCORRECT EXECUTION CAPACITIESCONCERNING ORDERS; INCORRECTLY DISCLOSED IT WAS A REGISTEREDMARKET MAKER IN CONNECTION WITH TRANSACTIONS; FAILED TODISCLOSE THAT IT WAS A REGISTERED MARKET MAKER WITH RESPECTTO TRANSACTIONS; AND FAILED TO DISCLOSE THAT THE TRANSACTIONSWERE EXECUTED AT AN AVERAGE PRICE.
FINRA ALLEGED FINRA RULE 2265 VIOLATIONS BECAUSE IT ALLEGED THATTHE FIRM ACCEPTED ORDERS FROM CUSTOMERS THAT WERE EXECUTEDIN THE PRE-MARKET SESSION OR POST-MARKET SESSION WITHOUTDISCLOSING TO SUCH CUSTOMERS THAT EXTENDED HOURS TRADINGINVOLVES MATERIAL TRADING RISKS, INCLUDING THE POSSIBILITY OFLOWER LIQUIDITY, HIGH VOLATILITY, CHANGING PRICES, UNLINKEDMARKETS, AN EXAGGERATED EFFECT FROM NEWS ANNOUNCEMENTS,WIDER SPREADS, AND ANY OTHER RELEVANT RISKS.
FINRA ALLEGED FINRA RULE 2010 AND NASD RULE 3010 VIOLATIONSBECAUSE IT ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR THE RULES OF FINRA. SPECIFICALLY, FINRASTATED THE FIRM VIOLTED FINRA RULE 2010 AND NASD RULE 3010BECAUSE IT ALLEGED THAT THE FIRM'S WSPS FAILED TO MEET THEMINIMUM REQUIREMENTS FOR ADEQUATE WSPS SET FORTH IN FINRARULE 2010 AND NASD RULE 3010 IN THE FOLLOWING SUBJECT AREAS:REGISTRATION AND QUALIFICATION; TRADE REPORTING; SALESTRANSACTIONS; FIRM QUOTE COMPLIANCE; REVIEW OF CLEARLYERRONEOUS TRANSACTIONS UNDER FINRA RULES; AND THE ORDERAUDIT TRAIL SYSTEM.
Current Status: Final
73©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/27/2013
Docket/Case Number: 2010021597701
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
FINRA ALLEGED SEC RULE 10B-10 CLIENT CONFIRM VIOLATIONS BECAUSEIT ALLEGED THAT THE FIRM STATED INCORRECT EXECUTION CAPACITIESCONCERNING ORDERS; INCORRECTLY DISCLOSED IT WAS A REGISTEREDMARKET MAKER IN CONNECTION WITH TRANSACTIONS; FAILED TODISCLOSE THAT IT WAS A REGISTERED MARKET MAKER WITH RESPECTTO TRANSACTIONS; AND FAILED TO DISCLOSE THAT THE TRANSACTIONSWERE EXECUTED AT AN AVERAGE PRICE.
FINRA ALLEGED FINRA RULE 2265 VIOLATIONS BECAUSE IT ALLEGED THATTHE FIRM ACCEPTED ORDERS FROM CUSTOMERS THAT WERE EXECUTEDIN THE PRE-MARKET SESSION OR POST-MARKET SESSION WITHOUTDISCLOSING TO SUCH CUSTOMERS THAT EXTENDED HOURS TRADINGINVOLVES MATERIAL TRADING RISKS, INCLUDING THE POSSIBILITY OFLOWER LIQUIDITY, HIGH VOLATILITY, CHANGING PRICES, UNLINKEDMARKETS, AN EXAGGERATED EFFECT FROM NEWS ANNOUNCEMENTS,WIDER SPREADS, AND ANY OTHER RELEVANT RISKS.
FINRA ALLEGED FINRA RULE 2010 AND NASD RULE 3010 VIOLATIONSBECAUSE IT ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR THE RULES OF FINRA. SPECIFICALLY, FINRASTATED THE FIRM VIOLTED FINRA RULE 2010 AND NASD RULE 3010BECAUSE IT ALLEGED THAT THE FIRM'S WSPS FAILED TO MEET THEMINIMUM REQUIREMENTS FOR ADEQUATE WSPS SET FORTH IN FINRARULE 2010 AND NASD RULE 3010 IN THE FOLLOWING SUBJECT AREAS:REGISTRATION AND QUALIFICATION; TRADE REPORTING; SALESTRANSACTIONS; FIRM QUOTE COMPLIANCE; REVIEW OF CLEARLYERRONEOUS TRANSACTIONS UNDER FINRA RULES; AND THE ORDERAUDIT TRAIL SYSTEM.
Resolution Date: 09/27/2013
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $15,000 AND UNDERTAKES TOREVISE THE FIRM'S WSPS IN THE AREAS DESCRIBED ABOVE. WITHIN 30BUSINESS DAYS AFTER ACCEPTANCE OF THE AWC, A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN EMAIL FROM A WORK-RELATED ACCOUNT OF THEREGISTERED PRINCIPAL PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HASREVISED ITS WSPS TO ADDRESS THE DEFICIENCIES; AND THE DATE THEREVISED PROCEDURES WERE IMPLEMENTED.
Sanctions Ordered: CensureMonetary/Fine $15,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 19 of 120
i
Reporting Source: Firm
Allegations: THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION("DIVISION"), FILES THIS PETITION FOR ORDER TO SHOW CAUSE TOCOMMENCE AN ADJUNDICATIVE PROCEEDING AGAINST RAYMOND JAMES& ASSOCIATES, INC. FOR VIOLATING THE INDIANA SECURITIES ACT, IND.CODE 23-2-1 ("ACT") (REPEALED EFFECTIVE JULY 1, 2008) AND THEINDIANA UNIFORM SECURITIES ACT, IND. CODE 23-19 ("IUSA") AND THERULES AND REGULATIONS PROMULGATED THEREUNDER, VIOLATIONSOCCURRING PRIOR TO JULY 1, 2008 ARE CHARGED UNDER THE ACT ANDVIOLATIONS OCCURRING AFTER JULY 1, 2008 ARE CHARGED UNDER THEIUSA. THIS IS AN ENFORCEMENT ACTION ARISING FROM A VIOLATION OFSTATE SECURITIES LAWS BY THE RESPONDENTS.
THE SANCTIONS SOUGHT ON THE FIRM ARE: SUSPENSION, CEASE ANDDESIST, RESTITUTION, CIVIL AND ADMINISTRATIVE PENALTY(IES) FINES,AND MONETARY PENALTY(IES) OTHER THAN FINES.
Current Status: Final
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Initiated By: THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 06/24/2013
Docket/Case Number: CAUSE NO. 13-0163 SC
Principal Product Type: No Product
Other Product Type(s):
THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION("DIVISION"), FILES THIS PETITION FOR ORDER TO SHOW CAUSE TOCOMMENCE AN ADJUNDICATIVE PROCEEDING AGAINST RAYMOND JAMES& ASSOCIATES, INC. FOR VIOLATING THE INDIANA SECURITIES ACT, IND.CODE 23-2-1 ("ACT") (REPEALED EFFECTIVE JULY 1, 2008) AND THEINDIANA UNIFORM SECURITIES ACT, IND. CODE 23-19 ("IUSA") AND THERULES AND REGULATIONS PROMULGATED THEREUNDER, VIOLATIONSOCCURRING PRIOR TO JULY 1, 2008 ARE CHARGED UNDER THE ACT ANDVIOLATIONS OCCURRING AFTER JULY 1, 2008 ARE CHARGED UNDER THEIUSA. THIS IS AN ENFORCEMENT ACTION ARISING FROM A VIOLATION OFSTATE SECURITIES LAWS BY THE RESPONDENTS.
THE SANCTIONS SOUGHT ON THE FIRM ARE: SUSPENSION, CEASE ANDDESIST, RESTITUTION, CIVIL AND ADMINISTRATIVE PENALTY(IES) FINES,AND MONETARY PENALTY(IES) OTHER THAN FINES.
Resolution Date: 07/28/2015
Resolution:
Other Sanctions Ordered: MONETARY FINE $200,000; $175,000 INVESTIGATION COST; $100,000 FORCONTINUING INVESTOR EDUCATION.
Sanction Details: PAID ON 7/31/15 A MONETARY FINE $200,000; $175,000 INVESTIGATIONCOST; $100,000 FOR CONTINUING INVESTOR EDUCATION. NO AMOUNTWAS WAIVED.
Firm Statement THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION("DIVISION"), FILED THIS PETITION FOR ORDER TO SHOW CAUSE TOCOMMENCE AN ADJUNDICATIVE PROCEEDING AGAINST RAYMOND JAMES& ASSOCIATES, INC. FOR VIOLATING THE INDIANA SECURITIES ACT, IND.CODE 23-2-1 ("ACT") (REPEALED EFFECTIVE JULY 1, 2008) AND THEINDIANA UNIFORM SECURITIES ACT, IND. CODE 23-19 ("IUSA") AND THERULES AND REGULATIONS PROMULGATED THEREUNDER, VIOLATIONSOCCURRING PRIOR TO JULY 1, 2008 ARE CHARGED UNDER THE ACT ANDVIOLATIONS OCCURRING AFTER JULY 1, 2008 ARE CHARGED UNDER THEIUSA. THIS IS AN ENFORCEMENT ACTION ARISING FROM A VIOLATION OFSTATE SECURITIES LAWS BY THE RESPONDENTS. ON 7/31/15 THE FIRMPAID A MONETARY FINE OF $200,000; $175,000 INVESTIGATION COST;$100,000 FOR CONTINUING INVESTOR EDUCATION. NO AMOUNT WASWAIVED.
Sanctions Ordered: Monetary/Fine $200,000.00
Consent
75©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION("DIVISION"), FILED THIS PETITION FOR ORDER TO SHOW CAUSE TOCOMMENCE AN ADJUNDICATIVE PROCEEDING AGAINST RAYMOND JAMES& ASSOCIATES, INC. FOR VIOLATING THE INDIANA SECURITIES ACT, IND.CODE 23-2-1 ("ACT") (REPEALED EFFECTIVE JULY 1, 2008) AND THEINDIANA UNIFORM SECURITIES ACT, IND. CODE 23-19 ("IUSA") AND THERULES AND REGULATIONS PROMULGATED THEREUNDER, VIOLATIONSOCCURRING PRIOR TO JULY 1, 2008 ARE CHARGED UNDER THE ACT ANDVIOLATIONS OCCURRING AFTER JULY 1, 2008 ARE CHARGED UNDER THEIUSA. THIS IS AN ENFORCEMENT ACTION ARISING FROM A VIOLATION OFSTATE SECURITIES LAWS BY THE RESPONDENTS. ON 7/31/15 THE FIRMPAID A MONETARY FINE OF $200,000; $175,000 INVESTIGATION COST;$100,000 FOR CONTINUING INVESTOR EDUCATION. NO AMOUNT WASWAIVED.
Disclosure 20 of 120
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Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/25/2013
Docket/Case Number: 2009017412501
Principal Product Type: Debt - Corporate
Other Product Type(s): TRACE-ELIGIBLE SECURITIES
Allegations: FINRA RULE 2010, NASD RULES 2110, 2320, 2440, 3010, INTERPRETATIVEMATERIAL 2440-1, 2440-2 - RAYMOND JAMES & ASSOCIATES, INC. SOLD(BOUGHT) CORPORATE BONDS TO (FROM) CUSTOMERS AND FAILED TOSELL (BUY) SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTOCONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKETCONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDFINRA RULES CONCERNING COMPLIANCE WITH NASD RULE 2440 ANDINTERPRETATIVE MATERIAL 2440. IN TRANSACTIONS IN TRADEREPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIESFOR OR WITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLEDILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMERS WERE AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.
Current Status: Final
Resolution Date: 04/25/2013
Resolution: Acceptance, Waiver & Consent(AWC)
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Resolution Date: 04/25/2013
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD RULE 2440 AND INTERPRETATIVE MATERIAL 2440WITHIN 60 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.FINE PAID JUNE 4, 2013.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $27,500.00
iReporting Source: Firm
Initiated By: FINRA
Date Initiated: 04/25/2013
Allegations: FINRA RULE 2010, NASD RULES 2110, 2320, 2440, 3010, INTERPRETATIVEMATERIAL 2440-1, 2440-2 - IN 7 TRANSACTIONS, RAYMOND JAMES &ASSOCIATES, INC. SOLD (BOUGHT) CORPORATE BONDS TO (FROM)CUSTOMERS AND FAILED TO SELL (BUY) SUCH BONDS AT A PRICE THATWAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TOEACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVEDAND THAT THE FIRM WAS ENTITLED TO A PROFIT. IN CONNECTIONTHEREWITH, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULESCONCERNING COMPLIANCE WITH NASD RULE 2440 AND INTERPRETATIVEMATERIAL 2440. IN 6 TRANSACTIONS IN TRADE REPORTING ANDCOMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIES FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMERS WERE AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/25/2013
Docket/Case Number: 2009017412501
Principal Product Type: Debt - Corporate
Other Product Type(s): TRACE-ELIGIBLE SECURITIES
Resolution Date: 04/25/2013
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD RULE 2440 AND INTERPRETATIVE MATERIAL 2440WITHIN 60 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
Sanctions Ordered: CensureMonetary/Fine $27,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 21 of 120
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Reporting Source: Regulator
Allegations: SEC RULES 203(B)(3), 204T(A)(1), 204T(A)(3), 204(T)(B) OF REGULATION SHO- RAYMOND JAMES & ASSOCIATES, INC. HAD FAIL-TO-DELIVER POSITIONSAT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THATRESULTED FROM A LONG SALE, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND ANDQUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE T(A)(1).THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARINGAGENCY IN AN EQUITY SECURITY THAT WAS ATTRIBUTABLE TO MARKETMAKING ACTIVITIES, AND DID NOT CLOSE OUT THE FAIL-TO-DELIVERPOSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITYWITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204T(A)(3). IN TWOINSTANCES INVOLVING ONE EQUITY SECURITY, THE FIRM ACCEPTED ASHORT SALE ORDER FROM ANOTHER PERSON, OR EFFECTED A SHORTSALE FOR ITS OWN ACCOUNT, WITHOUT FIRST BORROWING THESECURITY, OR ENTERING INTO A BONA FIDE ARRANGEMENT TO BORROWTHE SECURITY AND HAD A FAIL-TO-DELIVER POSITION AT A REGISTEREDCLEARING AGENCY IN SUCH SECURITY THAT HAD NOT BEEN CLOSED OUTIN ACCORDANCE WITH THE REQUIREMENTS OF PARAGRAPHS (A) AND (B)OF SEC RULE 204T. THE FIRM HAD A FAIL-TO-DELIVER POSITION AT AREGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13CONSECUTIVE SETTLEMENT DAYS, AND FAILED TO IMMEDIATELYTHEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BYPURCHASING SECURITIES OF LIKE AND QUANTITY. THE FIRM CONTINUEDTO HAVE A FAIL-TO-DELIVER POSITION IN THE SECURITY AT THEREGISTERED CLEARING AGENCY FOR 19 SETTLEMENT DAYS WHILE ITWAS A THRESHOLD SECURITY, WHICH IT FAILED TO CLOSE OUT WHENREQUIRED.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/12/2013
Docket/Case Number: 2009017242101
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s): THRESHOLD SECURITIES
SEC RULES 203(B)(3), 204T(A)(1), 204T(A)(3), 204(T)(B) OF REGULATION SHO- RAYMOND JAMES & ASSOCIATES, INC. HAD FAIL-TO-DELIVER POSITIONSAT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THATRESULTED FROM A LONG SALE, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND ANDQUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE T(A)(1).THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARINGAGENCY IN AN EQUITY SECURITY THAT WAS ATTRIBUTABLE TO MARKETMAKING ACTIVITIES, AND DID NOT CLOSE OUT THE FAIL-TO-DELIVERPOSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITYWITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204T(A)(3). IN TWOINSTANCES INVOLVING ONE EQUITY SECURITY, THE FIRM ACCEPTED ASHORT SALE ORDER FROM ANOTHER PERSON, OR EFFECTED A SHORTSALE FOR ITS OWN ACCOUNT, WITHOUT FIRST BORROWING THESECURITY, OR ENTERING INTO A BONA FIDE ARRANGEMENT TO BORROWTHE SECURITY AND HAD A FAIL-TO-DELIVER POSITION AT A REGISTEREDCLEARING AGENCY IN SUCH SECURITY THAT HAD NOT BEEN CLOSED OUTIN ACCORDANCE WITH THE REQUIREMENTS OF PARAGRAPHS (A) AND (B)OF SEC RULE 204T. THE FIRM HAD A FAIL-TO-DELIVER POSITION AT AREGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13CONSECUTIVE SETTLEMENT DAYS, AND FAILED TO IMMEDIATELYTHEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BYPURCHASING SECURITIES OF LIKE AND QUANTITY. THE FIRM CONTINUEDTO HAVE A FAIL-TO-DELIVER POSITION IN THE SECURITY AT THEREGISTERED CLEARING AGENCY FOR 19 SETTLEMENT DAYS WHILE ITWAS A THRESHOLD SECURITY, WHICH IT FAILED TO CLOSE OUT WHENREQUIRED.
Resolution Date: 03/12/2013
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $45,000. FINE PAID INFULL 3/26/13.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $45,000.00
Acceptance, Waiver & Consent(AWC)
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iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/12/2013
Docket/Case Number: 2009017242101
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s): THRESHOLD SECURITIES
Allegations: SEC RULES 203(B)(3), 204T(A)(1), 204T(A)(3), 204(T)(B) OF REGULATION SHO- RAYMOND JAMES & ASSOCIATES, INC. HAD FAIL-TO-DELIVER POSITIONSAT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THATRESULTED FROM A LONG SALE, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND ANDQUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE T(A)(1).THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARINGAGANCY IN AN EQUITY SECURITY THAT WAS ATTRIBUTABLE TO MARKETMAKING ACTIVITIES, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONBY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THETIME FRAME PRESCRIBED BY SEC RULE T(A)(3). IN TWO INSTANCESINVOLVING ONE EQUITY SECURITY, THE FIRM ACCEPTED A SHORT SALEORDER FROM ANOTHER PERSON OR EFFECTED A SHORT SALE FOR ITSOWN ACCOUNT, WITHOUT FIRST BORROWING THE SECURITY, ORENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITYAND HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARINGAGENCY IN SUCH SECURITY THAT HAD NOT BEEN CLOSED OUT INACCORDANCE WITH THE REQUIREMENTS OF PARAGRAPHS (A) AND (B) OFSEC RULE 204T, THE FIRM HAD A FAIL-TO-DELIVER POSITION AT AREGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13CONSECUTIVE SETTLEMENT DAYS, AND FAILED TO IMMEDIATELYTHEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BYPURCHASING SECURITIES OF LIKE AND QUANTITY. THE FIRM CONTINUEDTO HAVE A FAIL-TO-DELIVER POSITION IN THE SECURITY FOR 19SETTLEMENT DAYS WHILE IT WAS A THRESHOLD SECURITY, WHICH ITFAILED TO CLOSE OUT WHEN REQUIRED.
Current Status: Final
Resolution: Acceptance, Waiver & Consent(AWC)
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Resolution Date: 03/13/2013
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $45,000.
Sanctions Ordered: CensureMonetary/Fine $45,000.00
Disclosure 22 of 120
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Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/04/2013
Docket/Case Number: 2009018103201
Principal Product Type: Debt - Municipal
Other Product Type(s):
Allegations: MSRB RULES G-17, G-27, G-30(A) - RAYMOND JAMES & ASSOCIATES, INC.PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROMCUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANYMARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKINGINTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALERAS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THETRANSACTIONS AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTIONS, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTIONS, THE FACT THAT THE BROKER, DEALEROR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTIONS. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES FAIR PRICING REQUIREMENTS.
Current Status: Final
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Resolution Date: 03/04/2013
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $75,000 FOR MSRB RULEVIOLATIONS, REQUIRED TO PAY $25,603.28, PLUS INTEREST, INRESTITUTION TO CUSTOMERS AND TO REVISE ITS WRITTENSUPERVISORY PROCEDURES REGARDING MUNICIPAL SECURITIES FAIRPRICING REQUIREMENTS WITHIN 60 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC. A REGISTERED FIRM PRINCIPAL SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS TO EFFECT RESTITUTION, TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED. $75,000 FINE PAID IN FULL 3/21/13.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $75,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: MSRB RULES G-17, G-27, G-30(A) - IN 37 TRANSACTIONS, RAYMOND JAMES& ASSOCIATES, INC. PURCHASED MUNICIPAL SECURITIES FOR ITS OWNACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FORITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDINGANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE,TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THEBEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIESDEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIMEOF THE TRANSACTIONS AND OF ANY SECURITIES EXCHANGED ORTRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSEINVOLVED IN EFFECTING THE TRANSACTIONS, THE FACT THAT THEBROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO APROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTIONS. THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES FAIR PRICING REQUIREMENTS.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/04/2013
Docket/Case Number: 2009018103201
Principal Product Type: Debt - Municipal
Other Product Type(s):
MSRB RULES G-17, G-27, G-30(A) - IN 37 TRANSACTIONS, RAYMOND JAMES& ASSOCIATES, INC. PURCHASED MUNICIPAL SECURITIES FOR ITS OWNACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FORITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDINGANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE,TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THEBEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIESDEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIMEOF THE TRANSACTIONS AND OF ANY SECURITIES EXCHANGED ORTRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSEINVOLVED IN EFFECTING THE TRANSACTIONS, THE FACT THAT THEBROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO APROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTIONS. THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND MSRB RULES CONCERNINGMUNICIPAL SECURITIES FAIR PRICING REQUIREMENTS.
Resolution Date: 03/04/2013
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $75,000 FOR MSRB RULEVIOLATIONS, REQUIRED TO PAY $25,603.28, PLUS INTEREST, INRESTITUTION TO CUSTOMERS AND TO REVISE ITS WRITTENSUPERVISORY PROCEDURES REGARDING MUNICIPAL SECURITIES FAIRPRICING REQUIREMENTS WITHIN 60 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC. A REGISTERED FIRM PRINCIPAL SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS TO EFFECT RESTITUTION, TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.
Sanctions Ordered: CensureMonetary/Fine $75,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 23 of 120
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Disclosure 23 of 120
Reporting Source: Firm
Initiated By: STATE OF ALASKA
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 09/06/2012
Docket/Case Number: ORDER NO: 11-000736-01-S
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE STATE OF ALASKA ALLEGED THAT RAYMOND JAMES ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES INVIOLATION OF AS 45.55.025(3) AND AS 45.55.060(A)(7). FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF AS 45.55.060(B)(1).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 09/06/2012
Resolution:
Other Sanctions Ordered:
Sanctions Ordered: Monetary/Fine $6,521.93Cease and Desist/Injunction
Order
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Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 10, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $6,521.93 TO THE STATE OF ALASKA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF ALASKA ONSEPTEMBER 6, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 24 of 120
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Reporting Source: Firm
Allegations: THE OHIO DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF ORC 1707.19(A)(4) AND (A)(8). FURTHER,THE DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF ORC 1707.19(A)(9) AND OAC 1301:6-3-19(B)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: OHIO SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 09/14/2012
Docket/Case Number: ORDER NO. 12-024
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE OHIO DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF ORC 1707.19(A)(4) AND (A)(8). FURTHER,THE DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF ORC 1707.19(A)(9) AND OAC 1301:6-3-19(B)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 09/14/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 18, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $38,969.90 TO THE OHIO DIVISION OF SECURITIES INVESTOREDUCATION AND ENFORCEMENT EXPENSE FUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OHIO DIVISION OFSECURITIES ON SEPTEMBER 14, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $38,969.90Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OHIO DIVISION OFSECURITIES ON SEPTEMBER 14, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 25 of 120
i
Reporting Source: Firm
Allegations: THE STATE OF IOWA INSURANCE DIVISION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF IOWA CODE SECTION 502.412(4)(M)(2011). FURTHER, THE INSURANCE DIVISION ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF IOWA CODE SECTION 502.412(4)(I) (2011).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: STATE OF IOWA INSURANCE DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 09/17/2012
Docket/Case Number: DOCKET NO. 72282
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE STATE OF IOWA INSURANCE DIVISION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF IOWA CODE SECTION 502.412(4)(M)(2011). FURTHER, THE INSURANCE DIVISION ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF IOWA CODE SECTION 502.412(4)(I) (2011).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 09/17/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 21, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $52,039.74 AS FOLLOWS: $25,019.97 TO THE STATE OF IOWA, $2,000.00TO THE IOWA INSURANCE DIVISION FOR THE COSTS OF INVESTIGATION,AND $25,019.87 TO THE INVESTOR PROTECTION INSTITUTE ("IPI").
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF IOWAINSURANCE DIVISION ON SEPTEMBER 17, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $52,039.74Cease and Desist/Injunction
Order
88©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF IOWAINSURANCE DIVISION ON SEPTEMBER 17, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 26 of 120
i
Reporting Source: Regulator
Allegations: NASD RULES 2110, 3010, RULES 10(A) AND 30 OF REGULATION S-P: SOMEOF THE FIRM'S BRANCH OFFICES ENGAGED THE SERVICES OF ANEMPLOYEE OF THE FIRM TO BUILD AND MAINTAIN AN ONLINE DOCUMENTMANAGEMENT SYSTEM (DMS) FOR CUSTOMER RECORDS. THE EMPLOYEEDEPARTED THE FIRM AND, THIS INDIVIDUAL, A NONAFFILIATED THIRDPARTY, WAS NOT APPROVED BY THE FIRM TO RECEIVE FIRM CUSTOMERPERSONALLY IDENTIFIABLE INFORMATION (PII) AFTER HE LEFT THE FIRM.A BRANCH OFFICE OF THE FIRM PROVIDED PII OF NUMEROUSCUSTOMERS OF THE FIRM TO THE NONAFFILIATED THIRD PARTY ANDANOTHER BRANCH OFFICE PROVIDED THE NONAFFILIATED THIRD PARTYWITH PII OF SEVERAL CUSTOMERS AND SEVERAL BENEFICIARIES OF'CUSTOMERS. SUBSEQUENTLY, A FIRM CUSTOMER COMPLAINED THATHER FIRM ACCOUNT INFORMATION AND PII WAS AVAILABLE ON THEINTERNET. THE FIRM LEARNED THAT WHILE BUILDING AND MAINTAININGTHE DMS, THE NONAFFILIATED THIRD PARTY HAD INADVERTENTLYPOSTED CUSTOMER PII TO THE INTERNET. THE FIRM DID NOT HAVE ASUPERVISORY SYSTEM OR WRITTEN PROCEDURES IN PLACE TO ENSURETHAT ITS EMPLOYEES ADHERED TO ITS POLICIES ON THE MATTER. THEFIRM FAILED TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORYSYSTEMS AND PROCEDURES TO SAFEGUARD AGAINST THEUNAUTHORIZED DISCLOSURE OF PII TO NONAFFILIATED THIRD PARTIES.BECAUSE THESE BRANCH OFFICES DISCLOSED CUSTOMER PII TO ANONAFFILIATED THIRD PARTY AND BECAUSE NO EXCEPTION APPLIEDWHEN DONE, THE FIRM VIOLATED REGULATION S-P BY FAILING TOPROVIDE CUSTOMERS WITH AN OPT-OUT NOTICE PRIOR TO DISCLOSINGTHEIR PII. THE FIRM FAILED TO HAVE A SUPERVISORY SYSTEM ANDWRITTEN PROCEDURES TO MONITOR THE DISSEMINATION OF PII, OR TOTAKE REASONABLE STEPS TO PREVENT THE DISSEMINATION OF PII IN ITSMAILINGS. A FIRM-APPROVED THIRD PARTY VENDOR SENTCORRESPONDENCE TO CUSTOMERS RELATING TO A CASH MANAGEMENTACCOUNT PROGRAM. TO PREPARE FOR THE MAILING, THE FIRMPROVIDED THE VENDOR WITH A LIST OF CUSTOMERS. THE VENDORPRINTED MAILING LABELS FOR THE ENVELOPES AND PROCESSED AMAILING TO NUMEROUS CUSTOMER ACCOUNTS, HOWEVER THE LABELSON THE ENVELOPES MAILED TO CUSTOMERS DISCLOSED EACHCUSTOMER'S ACCOUNT NUMBER ALONG WITH THE CUSTOMER'S NAMEAND ADDRESS. THE FIRM, THEREAFTER, NOTIFIED AFFECTEDCUSTOMERS AND OFFERED THEM CREDIT MONITORING ANDPROTECTION SERVICES. UPON NOTIFICATION THAT THE CUSTOMER PIIWAS SEARCHABLE ON THE INTERNET, THE FIRM IMMEDIATELYCONTACTED THE UNAUTHORIZED THIRD PARTY, WHO CONTACTED THESEARCH ENGINE TO REMOVE THE CUSTOMER INFORMATION. THE FIRMSUBSEQUENTLY NOTIFIED REGULATORS OF THE INCIDENT. THE FIRMNOTIFIED AFFECTED CUSTOMERS AND THEIR BENEFICIARIES THAT THEIRPII HAD BEEN EXPOSED ON THE INTERNET AND OFFERED CUSTOMERSAND THEIR BENEFICIARIES FREE CREDIT MONITORING AND PROTECTIONSERVICES. THE FIRM ALSO AMENDED ITS WRITTEN SUPERVISORYPROCEDURES IN CONNECTION WITH THE PROTECTION OF PII ANDCONDUCTED MANDATORY TRAINING IN THE PROTECTION OF PII TO ALLASSOCIATED PERSONS, INCLUDING BRANCH PERSONNEL. TO DATE, TOTHE FIRM'S KNOWLEDGE, NO CUSTOMER HAS SUFFERED ANY INSTANCESOF IDENTITY THEFT OR OTHER ACTUAL DAMAGES AS A RESULT OF THEINFORMATION SECURITY BREACH.
Current Status: Final
89©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other
Date Initiated: 09/13/2012
Docket/Case Number: 2010023995301
Principal Product Type: No Product
Other Product Type(s):
NASD RULES 2110, 3010, RULES 10(A) AND 30 OF REGULATION S-P: SOMEOF THE FIRM'S BRANCH OFFICES ENGAGED THE SERVICES OF ANEMPLOYEE OF THE FIRM TO BUILD AND MAINTAIN AN ONLINE DOCUMENTMANAGEMENT SYSTEM (DMS) FOR CUSTOMER RECORDS. THE EMPLOYEEDEPARTED THE FIRM AND, THIS INDIVIDUAL, A NONAFFILIATED THIRDPARTY, WAS NOT APPROVED BY THE FIRM TO RECEIVE FIRM CUSTOMERPERSONALLY IDENTIFIABLE INFORMATION (PII) AFTER HE LEFT THE FIRM.A BRANCH OFFICE OF THE FIRM PROVIDED PII OF NUMEROUSCUSTOMERS OF THE FIRM TO THE NONAFFILIATED THIRD PARTY ANDANOTHER BRANCH OFFICE PROVIDED THE NONAFFILIATED THIRD PARTYWITH PII OF SEVERAL CUSTOMERS AND SEVERAL BENEFICIARIES OF'CUSTOMERS. SUBSEQUENTLY, A FIRM CUSTOMER COMPLAINED THATHER FIRM ACCOUNT INFORMATION AND PII WAS AVAILABLE ON THEINTERNET. THE FIRM LEARNED THAT WHILE BUILDING AND MAINTAININGTHE DMS, THE NONAFFILIATED THIRD PARTY HAD INADVERTENTLYPOSTED CUSTOMER PII TO THE INTERNET. THE FIRM DID NOT HAVE ASUPERVISORY SYSTEM OR WRITTEN PROCEDURES IN PLACE TO ENSURETHAT ITS EMPLOYEES ADHERED TO ITS POLICIES ON THE MATTER. THEFIRM FAILED TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORYSYSTEMS AND PROCEDURES TO SAFEGUARD AGAINST THEUNAUTHORIZED DISCLOSURE OF PII TO NONAFFILIATED THIRD PARTIES.BECAUSE THESE BRANCH OFFICES DISCLOSED CUSTOMER PII TO ANONAFFILIATED THIRD PARTY AND BECAUSE NO EXCEPTION APPLIEDWHEN DONE, THE FIRM VIOLATED REGULATION S-P BY FAILING TOPROVIDE CUSTOMERS WITH AN OPT-OUT NOTICE PRIOR TO DISCLOSINGTHEIR PII. THE FIRM FAILED TO HAVE A SUPERVISORY SYSTEM ANDWRITTEN PROCEDURES TO MONITOR THE DISSEMINATION OF PII, OR TOTAKE REASONABLE STEPS TO PREVENT THE DISSEMINATION OF PII IN ITSMAILINGS. A FIRM-APPROVED THIRD PARTY VENDOR SENTCORRESPONDENCE TO CUSTOMERS RELATING TO A CASH MANAGEMENTACCOUNT PROGRAM. TO PREPARE FOR THE MAILING, THE FIRMPROVIDED THE VENDOR WITH A LIST OF CUSTOMERS. THE VENDORPRINTED MAILING LABELS FOR THE ENVELOPES AND PROCESSED AMAILING TO NUMEROUS CUSTOMER ACCOUNTS, HOWEVER THE LABELSON THE ENVELOPES MAILED TO CUSTOMERS DISCLOSED EACHCUSTOMER'S ACCOUNT NUMBER ALONG WITH THE CUSTOMER'S NAMEAND ADDRESS. THE FIRM, THEREAFTER, NOTIFIED AFFECTEDCUSTOMERS AND OFFERED THEM CREDIT MONITORING ANDPROTECTION SERVICES. UPON NOTIFICATION THAT THE CUSTOMER PIIWAS SEARCHABLE ON THE INTERNET, THE FIRM IMMEDIATELYCONTACTED THE UNAUTHORIZED THIRD PARTY, WHO CONTACTED THESEARCH ENGINE TO REMOVE THE CUSTOMER INFORMATION. THE FIRMSUBSEQUENTLY NOTIFIED REGULATORS OF THE INCIDENT. THE FIRMNOTIFIED AFFECTED CUSTOMERS AND THEIR BENEFICIARIES THAT THEIRPII HAD BEEN EXPOSED ON THE INTERNET AND OFFERED CUSTOMERSAND THEIR BENEFICIARIES FREE CREDIT MONITORING AND PROTECTIONSERVICES. THE FIRM ALSO AMENDED ITS WRITTEN SUPERVISORYPROCEDURES IN CONNECTION WITH THE PROTECTION OF PII ANDCONDUCTED MANDATORY TRAINING IN THE PROTECTION OF PII TO ALLASSOCIATED PERSONS, INCLUDING BRANCH PERSONNEL. TO DATE, TOTHE FIRM'S KNOWLEDGE, NO CUSTOMER HAS SUFFERED ANY INSTANCESOF IDENTITY THEFT OR OTHER ACTUAL DAMAGES AS A RESULT OF THEINFORMATION SECURITY BREACH.
90©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
N/A
Resolution Date: 09/13/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $250,000. FINE PAID INFULL ON SEPTEMBER 21, 2012
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $250,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: NASD RULES 2110, 3010, RULES 10(A) AND 30 OF REGULATION S-P. SOMEOF THE FIRM'S BRANCH OFFICES IMPROPERLY DISCLOSED PERSONALLYIDENTIFIABLE INFORMATION (PII) TO A NONAFFILIATED THIRD PARTY,RESULTING IN EXPOSURE OF CUSTOMER PII ON THE INTERNET. BEFOREDISCLOSING THE PII TO THE NONAFFILIATED THIRD PARTY, THE FIRMFAILED TO PROVIDE OPT-OUT NOTICES TO THE AFFECTED CUSTOMERSAS REQUIRED BY REGULATION S-P. THE FIRM FAILED TO ESTABLISH ANDMAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES TOSAFEGUARD AGAINST THE UNAUTHORIZED DISCLOSURE OF PII TONONAFFILIATED THIRD PARTIES. IN A SEPARATE INCIDENT, CUSTOMER PIIWAS PUBLICLY EXPOSED WHEN A FIRM APPROVED VENDOR MAILEDLETTERS TO CUSTOMERS IN ENVELOPES THAT BORE THE CUSTOMERACCOUNT NUMBERS TOGETHER WITH CUSTOMER NAME AND ADDRESS.UPON NOTIFICATION THAT THE CUSTOMER PII WAS SEARCHABLE ON THEINTERNET, THE FIRM IMMEDIATELY CONTACTED THE UNAUTHORIZEDTHIRD PARTY, WHO CONTACTED THE SEARCH ENGINE TO REMOVE THECUSTOMER INFORMATION. FURTHER, THE FIRM SUBSEQUENTLYNOTIFIED REGULATORS OF THE INCIDENT. THE FIRM NOTIFIED AFFECTEDCUSTOMERS AND THEIR BENEFICIARIES THAT THEIR PII HAD BEENEXPOSED ON THE INTERNET AND OFFERED CUSTOMERS AND THEIRBENEFICIARIES FREE CREDIT MONITORING AND PROTECTION SERVICES.THE FIRM ALSO AMENDED ITS WRITTEN SUPERVISORY PROCEDURES INCONNECTION WITH THE PROTECTION OF PII AND CONDUCTEDMANDATORY TRAINING IN THE PROTECTION OF PII TO ALL ASSOCIATEDPERSONS, INCLUDING BRANCH PERSONNEL. TO DATE, TO THE FIRM'SKNOWLEDGE, NO CUSTOMER HAS SUFFERED ANY INSTANCES OFIDENTITY THEFT OR OTHER ACTUAL DAMAGES AS A RESULT OF THEINFORMATION SECURITY BREACH.
Current Status: Final
91©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/13/2012
Docket/Case Number: 2010023995301
Principal Product Type: No Product
Other Product Type(s):
NASD RULES 2110, 3010, RULES 10(A) AND 30 OF REGULATION S-P. SOMEOF THE FIRM'S BRANCH OFFICES IMPROPERLY DISCLOSED PERSONALLYIDENTIFIABLE INFORMATION (PII) TO A NONAFFILIATED THIRD PARTY,RESULTING IN EXPOSURE OF CUSTOMER PII ON THE INTERNET. BEFOREDISCLOSING THE PII TO THE NONAFFILIATED THIRD PARTY, THE FIRMFAILED TO PROVIDE OPT-OUT NOTICES TO THE AFFECTED CUSTOMERSAS REQUIRED BY REGULATION S-P. THE FIRM FAILED TO ESTABLISH ANDMAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES TOSAFEGUARD AGAINST THE UNAUTHORIZED DISCLOSURE OF PII TONONAFFILIATED THIRD PARTIES. IN A SEPARATE INCIDENT, CUSTOMER PIIWAS PUBLICLY EXPOSED WHEN A FIRM APPROVED VENDOR MAILEDLETTERS TO CUSTOMERS IN ENVELOPES THAT BORE THE CUSTOMERACCOUNT NUMBERS TOGETHER WITH CUSTOMER NAME AND ADDRESS.UPON NOTIFICATION THAT THE CUSTOMER PII WAS SEARCHABLE ON THEINTERNET, THE FIRM IMMEDIATELY CONTACTED THE UNAUTHORIZEDTHIRD PARTY, WHO CONTACTED THE SEARCH ENGINE TO REMOVE THECUSTOMER INFORMATION. FURTHER, THE FIRM SUBSEQUENTLYNOTIFIED REGULATORS OF THE INCIDENT. THE FIRM NOTIFIED AFFECTEDCUSTOMERS AND THEIR BENEFICIARIES THAT THEIR PII HAD BEENEXPOSED ON THE INTERNET AND OFFERED CUSTOMERS AND THEIRBENEFICIARIES FREE CREDIT MONITORING AND PROTECTION SERVICES.THE FIRM ALSO AMENDED ITS WRITTEN SUPERVISORY PROCEDURES INCONNECTION WITH THE PROTECTION OF PII AND CONDUCTEDMANDATORY TRAINING IN THE PROTECTION OF PII TO ALL ASSOCIATEDPERSONS, INCLUDING BRANCH PERSONNEL. TO DATE, TO THE FIRM'SKNOWLEDGE, NO CUSTOMER HAS SUFFERED ANY INSTANCES OFIDENTITY THEFT OR OTHER ACTUAL DAMAGES AS A RESULT OF THEINFORMATION SECURITY BREACH.
Resolution Date: 09/13/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS.THEREFORE THE FIRM IS CENSURED AND FINED $250,000.
Sanctions Ordered: CensureMonetary/Fine $250,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 27 of 120
i
Reporting Source: Regulator
Initiated By: PENNSYLVANIA CONTACT: CAROLYN MENDELSON (412)-565-5083
Allegations: RAYMOND JAMES & ASSOCIATES, INC., IN THE SALE OF AUCTION RATESECURITIES IN PA, USED DISHONEST AND UNETHICAL PRACTICES IN THESECURITIES BUSINESS AND FAILED TO REASONABLY SUPERVISE AGENTSIN VIOLATION OF THE PA SECURITIES ACT OF 1972.
Current Status: Final
92©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: PENNSYLVANIA CONTACT: CAROLYN MENDELSON (412)-565-5083
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
RAYMOND JAMES & ASSOCIATES, INC. HAS COMPLETED A REPURCHASEOF AUCTION RATE SECURITIES FROM ELIGIBLE PA INVESTORS.
Date Initiated: 07/24/2012
Docket/Case Number: 2009-10-21
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 07/24/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, RAYMOND JAMES &ASSOCIATES, INC., IS ORDERED TO PAY AN ADMINISTRATIVE ASSESSMENTIN THE SUM OF $63,467.59 TO THE COMMONWEALTH OF PA.
Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TORAYMOND JAMES & ASSOCIATES, INC., AND OTHER NAMEDRESPONDENTS.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: Monetary/Fine $63,467.59
Settled
iReporting Source: Firm
Allegations: THE PENNSYLVANIA SECURITIES COMMISSION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF SECTION 305(A)(IX) OF THE 1972 ACT, 70P.S. SS 1-305(A)(IX). FURTHER, THE SECURITIES COMMISSION ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF SECTION 305(A)(VII) OF THE 1972 ACT, 70 P.S. SS1-305(A)(VII).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
93©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: PENNSYLVANIA SECURITIES COMMISSION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 07/24/2012
Docket/Case Number: NO. 2009-10-21
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE PENNSYLVANIA SECURITIES COMMISSION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF SECTION 305(A)(IX) OF THE 1972 ACT, 70P.S. SS 1-305(A)(IX). FURTHER, THE SECURITIES COMMISSION ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF SECTION 305(A)(VII) OF THE 1972 ACT, 70 P.S. SS1-305(A)(VII).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 07/24/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON AUGUST 9, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$63,494.74 TO THE COMMONWEALTH OF PENNSYLVANIA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE PENNSYLVANIASECURITIES COMMISSION ON JULY 24, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $63,494.74Cease and Desist/Injunction
Order
94©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE PENNSYLVANIASECURITIES COMMISSION ON JULY 24, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 28 of 120
i
Reporting Source: Firm
Allegations: THE ILLINOIS SECURITIES DEPARTMENT ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SECTION 8.E(1)(B). FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SECTION 8.E(1)(E)(I).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
95©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: ILLINOIS SECURITIES DEPARTMENT
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 07/16/2012
Docket/Case Number: NO. 0900447
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE ILLINOIS SECURITIES DEPARTMENT ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SECTION 8.E(1)(B). FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SECTION 8.E(1)(E)(I).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 07/16/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JULY 19, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$57,186.46 TO THE ILLINOIS SECRETARY OF STATE, INVESTOR EDUCATIONFUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE ILLINOIS SECURITIESDEPARTMENT ON JULY 16, 2012, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $57,186.46Cease and Desist/Injunction
Order
96©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE ILLINOIS SECURITIESDEPARTMENT ON JULY 16, 2012, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 29 of 120
i
Reporting Source: Firm
Allegations: STATE OF WEST VIRGINIA ALLEGED THAT RAYMOND JAMES ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES INVIOLATION OF WEST VIRGINIA CODE 32-2-204(B)(33). FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF WEST VIRGINIACODE 32-2-204(A)(I).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
97©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: STATE OF WEST VIRGINIA
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 06/13/2012
Docket/Case Number: ORDER NO.: 81-705
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
STATE OF WEST VIRGINIA ALLEGED THAT RAYMOND JAMES ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES INVIOLATION OF WEST VIRGINIA CODE 32-2-204(B)(33). FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF WEST VIRGINIACODE 32-2-204(A)(I).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 06/13/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON 6/22/2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF $4,869.31TO THE TREASURER OF WEST VIRGINIA SECURITIES COMMISSION.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WEST VIRGINIASECURITIES COMMISSION ON 8/18/2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,869.31Cease and Desist/Injunction
Order
98©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WEST VIRGINIASECURITIES COMMISSION ON 8/18/2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 30 of 120
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Reporting Source: Firm
Initiated By: U.S. VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE
Date Initiated: 05/17/2012
Docket/Case Number: ORDER NO. 04/2012
Allegations: THE U.S. VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCEALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF CHAPTER 23,9VIC, SECTION 642(D)(13). FURTHER, THE DIVISION OF BANKING ANDINSURANCE ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLYSUPERVISE THEIR AGENTS IN VIOLATION OF CHAPTER 23, 9VIC, SECTION642(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
99©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Docket/Case Number: ORDER NO. 04/2012
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 05/17/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON MAY 30, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$3,500.00 TO THE OFFICE OF THE LIEUTENANT GOVERNOR, DIVISION OFBANKING AND INSURANCE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE U.S. VIRGIN ISLANDSON MAY 17, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $3,500.00Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE U.S. VIRGIN ISLANDSON MAY 17, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 31 of 120
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Reporting Source: Firm
Initiated By: THE STATE OF MICHIGAN, OFFICE OF FINANCIAL AND INSURANCEREGULATION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Date Initiated: 05/31/2012
Docket/Case Number:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCEREGULATION ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONESTOR UNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OFSECTION 204(A)(1)(G) OF THE ACT, MCL 451.604(A)(1)(G). FURTHER, THEOFFICE OF FINANCIAL AND INSURANCE REGULATION ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF SECTION 204(A)(2) OF THE ACT, MCL 451.604(A)(2).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
101©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Resolution Date: 05/31/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JUNE 6, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$75,860.45 TO THE STATE OF MICHIGAN AND A FINE IN THE AMOUNT OF$8,428.94 PAYABLE TO THE SECURITIES INVESTOR EDUCATION ANDTRAINING FUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF MICHIGANOFFICE OF FINANCIAL AND INSURANCE REGULATION ON MAY 31, 2012, INWHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $84,289.39Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF MICHIGANOFFICE OF FINANCIAL AND INSURANCE REGULATION ON MAY 31, 2012, INWHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 32 of 120
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Reporting Source: Regulator
Initiated By: DISTRICT OF COLUMBIA
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
ADMINISTRATIVE CONSENT ORDER
Date Initiated: 05/24/2012
Docket/Case Number: SB-CO-08-12
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIALSERVICES, INC. VIOLATED D.C. OFFICIAL CODE § 31-5602.07(A)(9)BYENGAGING IN DISHONEST OR UNETHICAL PRACTICES. RESPONDENTSWERE ALSO IN VIOLATION OF D.C. OFFICIAL CODE § 5602.07(A)(12) BYFAILING TO REASONABLE SUPERVISE THEIR AGENTS.
Current Status: Final
Resolution Date: 05/24/2012
Resolution:
Other Sanctions Ordered: RESPONDENTS WILL TAKE VARIOUS MEASURES TO RESOLVEOUTSTANDING ARS ISSUES.
Sanction Details: RESPONDENTS SHALL CEASE AND DESIST FROM VIOLATING D.C. OFFICIALCODE §§ 31-5602.07(A)(9) AND 31-5602.07(A)(12). ON JUNE 6, 2012RESPONDENTS PAID A FINE IN THE AMOUNT $4302.70 TO THE DISTRICT OFCOLUMBIA, DC TREASURER.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $4,302.70
Order
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RESPONDENTS SHALL CEASE AND DESIST FROM VIOLATING D.C. OFFICIALCODE §§ 31-5602.07(A)(9) AND 31-5602.07(A)(12). ON JUNE 6, 2012RESPONDENTS PAID A FINE IN THE AMOUNT $4302.70 TO THE DISTRICT OFCOLUMBIA, DC TREASURER.
iReporting Source: Firm
Initiated By: THE DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIESAND BANKING
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 05/24/2012
Docket/Case Number: ORDER NO. SB-CO-08-12
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIESAND BANKING ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONESTOR UNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OFD.C. OFFICIAL CODE SEC. 31-5602.07(A)(9). FURTHER, THE DEPARTMENTOF INSURANCE, SECURITIES AND BANKING ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF D.C. OFFICIAL CODE SEC. 31-5602.07(A)(12).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution: Order104©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Resolution Date: 05/24/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JUNE 5, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$4,302.70 TO THE D.C. TREASURER.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE DISTRICT OF COLUMBIADEPARTMENT OF INSURANCE, SECURITIES AND BANKING ON MAY 24,2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,302.70Cease and Desist/Injunction
Order
Disclosure 33 of 120
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Reporting Source: Firm
Initiated By: ARKANSAS SECURITIES COMMISSIONER
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 04/04/2012
Docket/Case Number: ORDER NO. S-09-024-11-0R15 CASE NO. S-09-024
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE ARKANSAS SECURITIES COMMISSIONER ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THEOFFER AND SALE OF SECURITIES IN VIOLATION OF ARK. CODE ANN. SEC.23-42-308(A)(2)(G). FURTHER, THE SECURITIES COMMISSIONER ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF ARK. CODE ANN. SEC. 23-42-308(A)(2)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 04/04/2012
Resolution:
Other Sanctions Ordered:
Sanctions Ordered: Monetary/Fine $5,766.45Cease and Desist/Injunction
Order
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Other Sanctions Ordered:
Sanction Details: ON APRIL 10, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$5,766.45 TO THE ARKANSAS SECURITIES DEPARTMENT.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE ARKANSAS SECURITIESCOMMISSIONER ON APRIL 4, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 34 of 120
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Reporting Source: Firm
Allegations: THE WISCONSIN SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SEC. 551.34(1)(G), WIS. STATS. FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SEC. 551.34(1)(J), WIS. STATS.
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
107©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: WISCONSIN SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 02/23/2012
Docket/Case Number: FILE S-220238 (EX)
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE WISCONSIN SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SEC. 551.34(1)(G), WIS. STATS. FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SEC. 551.34(1)(J), WIS. STATS.
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 02/23/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON FEBRUARY 29, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$10,044.37 TO THE WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WISCONSINSECURITIES DIVISION ON FEBRUARY 23, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $10,044.37Cease and Desist/Injunction
Order
108©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WISCONSINSECURITIES DIVISION ON FEBRUARY 23, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 35 of 120
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Reporting Source: Firm
Allegations: THE NEBRASKA DEPARTMENT OF BANKING & FINANCE ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF NEB. REV. STAT. SEC. 8-1103(9)(A)(VII) (REISSUE 2007). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF NEB. REV. STAT. SEC. 8-1103(9)(A)(XI)(REISSUE2007).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
109©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: NEBRASKA DEPARTMENT OF BANKING & FINANCE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 01/12/2012
Docket/Case Number: NONE
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE NEBRASKA DEPARTMENT OF BANKING & FINANCE ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF NEB. REV. STAT. SEC. 8-1103(9)(A)(VII) (REISSUE 2007). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF NEB. REV. STAT. SEC. 8-1103(9)(A)(XI)(REISSUE2007).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 01/12/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JANUARY 23, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$5,190.39 TO THE NEBRASKA DEPARTMENT OF BANKING & FINANCE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEBRASKADEPARTMENT OF BANKING & FINANCE ON JANUARY 12, 2012, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $5,190.39Cease and Desist/Injunction
Order
110©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEBRASKADEPARTMENT OF BANKING & FINANCE ON JANUARY 12, 2012, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 36 of 120
i
Reporting Source: Firm
Allegations: THE DELAWARE SECURITIES COMMISSIONER ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF 6 DEL. C. SEC. 73-304(A)(7) (FORMERLY 6DEL. C. SEC. 7316(A)(7)). FURTHER, THE SECURITIES DIVISION ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF 6 DEL. C. SEC. 73-304(A)(10) (FORMERLY 6 DEL.C. SEC. 7316(A)(10)).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
111©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: DELAWARE SECURITIES COMMISSIONER
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 01/09/2012
Docket/Case Number: CASE NO. 11-11-3
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE DELAWARE SECURITIES COMMISSIONER ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF 6 DEL. C. SEC. 73-304(A)(7) (FORMERLY 6DEL. C. SEC. 7316(A)(7)). FURTHER, THE SECURITIES DIVISION ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF 6 DEL. C. SEC. 73-304(A)(10) (FORMERLY 6 DEL.C. SEC. 7316(A)(10)).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 01/09/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JANUARY 13, 2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$5,766.45 TO THE STATE OF DELAWARE INVESTOR PROTECTION FUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE DELAWARE SECURITIESCOMMISSIONER ON JANUARY 9, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $5,766.45Cease and Desist/Injunction
Order
112©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE DELAWARE SECURITIESCOMMISSIONER ON JANUARY 9, 2012, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 37 of 120
i
Reporting Source: Firm
Allegations: COMMISSIONER OF SECURITIES STATE OF GEORGIA ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF SECTION 10-5-4(A)(8) OF THE1973 ACT AND RULE 590-4-2-14(1). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF SECTION 10-5-4(A)(11) OF THE 1973 ACTAND RULE 590-4-2-07(1) UNDER THE 1973 ACT.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
113©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: COMMISSIONER OF SECURITIES STATE OF GEORGIA
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 01/04/2012
Docket/Case Number: CASE NO. ENSC - 120081
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
COMMISSIONER OF SECURITIES STATE OF GEORGIA ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF SECTION 10-5-4(A)(8) OF THE1973 ACT AND RULE 590-4-2-14(1). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF SECTION 10-5-4(A)(11) OF THE 1973 ACTAND RULE 590-4-2-07(1) UNDER THE 1973 ACT.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 01/04/2012
Resolution:
Other Sanctions Ordered:
Sanction Details: ON 01/10/2012, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$32,869.37 TO THE COMMISSIONER OF SECURITIES STATE OF GEORGIA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COMMISSIONER OFSECURITIES STATE OF GEORGIA ON 1/04/2012 IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $32,869.37Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COMMISSIONER OFSECURITIES STATE OF GEORGIA ON 1/04/2012 IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 38 of 120
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Reporting Source: Firm
Initiated By: COLORADO DIVISION OF SECURITIES
Date Initiated: 12/15/2011
Docket/Case Number: ORDER NO. 12-6-21
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: COLORADO DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SECTION 11-51-410(1) (G), C.R.S. FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SECTION 11-51-410(1) (I), C.R.S.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
115©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 12/15/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON 12/20/2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$50,897.07 TO THE COLORADO DIVISION OF SECURITIES.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COLORADO DIVISIONOF SECURITIES ON 12/15/2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $50,897.07Cease and Desist/Injunction
Order
116©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COLORADO DIVISIONOF SECURITIES ON 12/15/2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 39 of 120
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Reporting Source: Regulator
Initiated By: MISSOURI
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
CONSENT ORDER
Date Initiated: 07/29/2011
Docket/Case Number: AP-11-23
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: ACTIVITIES REGARDING THE SALE OF AUCTION RATE SECURITIES HAVEBEEN THE SUBJECT OF COORDINATED INVESTIGATIONS CONDUCTED BYA MUTLI-STATE TASK FORCE.
Current Status: Final
Resolution Date: 11/04/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: RESPONDENTS HAVE VOLUNTARILY AGREED TO PURCHASE CERTAINAUCION RATE SECURITIES FROM CUSTOMERS AND TO MAKE CERTAINPAYMENTS,TO USE BEST EFFORTS TO PROVIDE LIQUIDITY SOLUTIONSFOR CERTAIN OTHER CUSTOMERS AND RESPONDENTS NEITHER ADMITNOR DENY THE FINDINGS OF FACT AND CONCLUSIONS OF LAW.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered:
Consent
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Reporting Source: Firm
Initiated By: MISSOURI SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 11/04/2011
Docket/Case Number: CASE NO. AP-11-23
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE MISSOURI SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SECTION 409.4-412(D)(13), RSMO. (CUM.SUPP. 2009) OF THE MISSOURI SECURITIES ACT OF 2003. FURTHER, THESECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF SECTION 409.4-412(D)(9), RSMO. (CUM. SUPP. 2009) OF THE MISSOURI SECURITIES ACT OF2003.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 11/04/2011
Resolution:
Sanctions Ordered: Monetary/Fine $10,960.39Cease and Desist/Injunction
Order
118©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 16, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$10,960.39 TO THE STATE OF MISSOURI.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MISSOURI SECURITIESDIVISION ON NOVEMBER 4, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $10,960.39Cease and Desist/Injunction
Disclosure 40 of 120
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Reporting Source: Firm
Allegations: THE MISSISSIPPI SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF MISS. CODE ANN. SECTION 75-71-412(D)(13).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFMISS. CODE ANN. SECTION 75-71-412(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
119©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: MISSISSIPPI SECRETARY OF STATE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 11/23/2011
Docket/Case Number: FILE NO. S-11-0240
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE MISSISSIPPI SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF MISS. CODE ANN. SECTION 75-71-412(D)(13).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFMISS. CODE ANN. SECTION 75-71-412(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 11/23/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON DECEMBER 8, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$10,771.52 TO THE MISSISSIPPI SECRETARY OF STATE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MISSISSIPPISECRETARY OF STATE ON NOVEMBER 23, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $10,771.52Cease and Desist/Injunction
Order
120©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MISSISSIPPISECRETARY OF STATE ON NOVEMBER 23, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 41 of 120
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Reporting Source: Regulator
Allegations: ON NOVEMBER 22, 2011, THE SECURITIES DIVISION ENTERED INTO ACONSENT ORDER WITH RAYMOND JAMES & ASSOCIATES, INC. ANDRAYMOND JAMES FINANCIAL SERVICES, INC. (COLLECTIVELY "RESPONDENTS"), IN ORDER TO SETTLE THE ALLEGATIONS THAT THERESPONDENTS ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TOREASONABLY SUPERVISE ITS SALESPERSONS IN THE MARKETING ANDSALE OF ARS. THE RESPONDENTS NEITHER ADMITTED NOR DENIED THEALLEGATIONS, BUT AGREED TO CEASE AND DESIST FROM VIOLATING THESECURITIES ACT OF WASHINGTON. THE RESPONDENTS AGREED TOOFFER TO PURCHASE AT PAR ARS THAT SINCE FEBRUARY 13, 2008 HAVENOT BEEN AUCTIONING FROM CERTAIN INVESTORS WHO PURCHASEDTHOSE ARS FROM THE RESPONDENTS ON OR BEFORE FEBRUARY 13,2008. THE RESPONDENTS AGREED TO PAY $8,363.42 AS A CIVILMONETARY PENALTY. THE RESPONDENTS WAIVED THEIR RIGHT TO AHEARING AND TO JUDICIAL REVIEW OF THIS MATTER.
Current Status: Final
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Initiated By: WASHINGTON
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
CIVIL MONETARY PENALTY
Date Initiated: 11/22/2011
Docket/Case Number: S-11-0740-11-CO01
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
ON NOVEMBER 22, 2011, THE SECURITIES DIVISION ENTERED INTO ACONSENT ORDER WITH RAYMOND JAMES & ASSOCIATES, INC. ANDRAYMOND JAMES FINANCIAL SERVICES, INC. (COLLECTIVELY "RESPONDENTS"), IN ORDER TO SETTLE THE ALLEGATIONS THAT THERESPONDENTS ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TOREASONABLY SUPERVISE ITS SALESPERSONS IN THE MARKETING ANDSALE OF ARS. THE RESPONDENTS NEITHER ADMITTED NOR DENIED THEALLEGATIONS, BUT AGREED TO CEASE AND DESIST FROM VIOLATING THESECURITIES ACT OF WASHINGTON. THE RESPONDENTS AGREED TOOFFER TO PURCHASE AT PAR ARS THAT SINCE FEBRUARY 13, 2008 HAVENOT BEEN AUCTIONING FROM CERTAIN INVESTORS WHO PURCHASEDTHOSE ARS FROM THE RESPONDENTS ON OR BEFORE FEBRUARY 13,2008. THE RESPONDENTS AGREED TO PAY $8,363.42 AS A CIVILMONETARY PENALTY. THE RESPONDENTS WAIVED THEIR RIGHT TO AHEARING AND TO JUDICIAL REVIEW OF THIS MATTER.
Resolution Date: 11/22/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: CIVIL MONETARY PENALTY OF $8363.42. FULL AMOUNT WAS PAID ON12/8/2011.
Regulator Statement BRIDGETT FISHER 3609028783
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: Monetary/Fine $8,363.42
Consent
iReporting Source: Firm
Allegations: THE STATE OF WASHINGTON, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF RCW 21.20.110(1)(G).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFRCW 21.20.110(1)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
122©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: STATE OF WASHINGTON, SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 11/22/2011
Docket/Case Number: ORDER NUMBER S-11-0740-11-CO01
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE STATE OF WASHINGTON, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF RCW 21.20.110(1)(G).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFRCW 21.20.110(1)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 11/22/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON DECEMBER 1, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$8,363.42 TO THE STATE OF WASHINGTON.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WASHINGTONSECURITIES DIVISION ON NOVEMBER 22, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $8,363.42Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WASHINGTONSECURITIES DIVISION ON NOVEMBER 22, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 42 of 120
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Reporting Source: Firm
Allegations: THE COMMONWEALTH OF VIRGINIA ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-280 G.FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFCOMMISSION RULE 21 VAC 5-20-260.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
124©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: COMMONWEALTH OF VIRGINIA
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 11/15/2011
Docket/Case Number: CASE NO. SEC-2011-00039
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE COMMONWEALTH OF VIRGINIA ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-280 G.FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFCOMMISSION RULE 21 VAC 5-20-260.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 11/15/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 22, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$25,597.86 TO THE TREASURER OF VIRGINIA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COMMONWEALTH OFVIRGINIA ON NOVEMBER 15, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $25,597.86
Order
125©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE COMMONWEALTH OFVIRGINIA ON NOVEMBER 15, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 43 of 120
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Reporting Source: Firm
Allegations: THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF MASS. GEN. LAWS CH.110A, SEC.204(A)(2)(G). FURTHER, THE SECURITIES DIVISION ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF MASS. GEN. LAWS CH. 110A, SEC. 204(A)(2)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
126©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: MASSACHUSETTS SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 11/09/2011
Docket/Case Number: DOCKET NO. E-2011-0049
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF MASS. GEN. LAWS CH.110A, SEC.204(A)(2)(G). FURTHER, THE SECURITIES DIVISION ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF MASS. GEN. LAWS CH. 110A, SEC. 204(A)(2)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 11/09/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 10, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$29,564.14 TO THE COMMONWEALTH OF MASSACHUSETTS.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MASSACHUSETTSSECURITIES DIVISION ON NOVEMBER 9, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $29,564.14Cease and Desist/Injunction
Order
127©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MASSACHUSETTSSECURITIES DIVISION ON NOVEMBER 9, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 44 of 120
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Reporting Source: Firm
Initiated By: SECURITIES COMMISSIONER OF MARYLAND
Date Initiated: 10/24/2011
Docket/Case Number: NO. 2011-0336
Principal Product Type: Other
Allegations: THE SECURITIES COMMISSIONER OF MARYLAND ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF SEC. 11-412(A)(7) OF THESECURITIES ACT. FURTHER, THE SECURITIES COMMISSIONER ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF SEC. 11-412(A)(10) OF THE SECURITIES ACT.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 10/24/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 2, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$21,017.75 TO THE SECURITIES DIVISION, OFFICE OF THE ATTORNEYGENERAL OF MARYLAND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SECURITIESCOMMISSIONER OF MARYLAND ON OCTOBER 24, 2011, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $21,017.75Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SECURITIESCOMMISSIONER OF MARYLAND ON OCTOBER 24, 2011, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 45 of 120
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Reporting Source: Regulator
Initiated By: UTAH
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
ADMINISTRATIVE FINE
Date Initiated: 10/27/2011
Docket/Case Number: SD-11-0089
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE DIVISION ALLEGED THAT: (1) RESPONDENT ENGAGED IN DISHONESTOR UNETHICAL PRACTICES WARRANTING SANCTIONS UNDER SECTION61-1-6(2)(A)(II)(G) OF THE UTAH UNIFORM SECURITIES ACT ("ACT"); AND (2)RESPONDENT FAILED TO REASONABLY SUPERVISE ITS AGENTSWARRANTING SANCTIONS UNDER SECTION 61-1-6(2)(A)(II)(J) OF THE ACT.
Current Status: Final
Resolution Date: 10/27/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: THE FINE OF $29328.05 WAS PAID WITHIN TEN (10) DAYS OF ENTRY OF THEORDER.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: Monetary/Fine $29,328.05Cease and Desist/Injunction
Stipulation and Consent
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Sanction Details: THE FINE OF $29328.05 WAS PAID WITHIN TEN (10) DAYS OF ENTRY OF THEORDER.
Regulator Statement THE STIPULATION AND CONSENT ORDER CAN BE VIEWED ONLINE AT:HTTP://SECURITIES.UTAH.GOV/DOCKETS/11008901.PDF(NOTE: THE WEB ADDRESS MUST BE ENTERED IN ALL LOWER CASELETTERS).
iReporting Source: Firm
Initiated By: UTAH DIVISION OF SECURITIES
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/27/2011
Docket/Case Number: SD-11-0089
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE UTAH DIVISION OF SECURITIES ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SEC. 61-1-6((2)(A)(II)(G) OF THE UTAHUNIFORM SECURITIES ACT. FURTHER, THE SECURITIES DIVISION ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF SEC. 61-1-6(2)(A)(II)(J) OF THE ACT.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERS,AUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Resolution Date: 10/27/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 7, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$29,328.05 TO THE UTAH DIVISION OF SECURITIES.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE UTAH DIVISION OFSECURITIES ON OCTOBER 13, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $29,328.05Cease and Desist/Injunction
Stipulation and Consent
Disclosure 46 of 120
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Reporting Source: Regulator
Initiated By: MAINE OFFICE OF SECURITIES
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
CIVIL MONETARY PENALTY
Date Initiated: 10/28/2011
Docket/Case Number: 11-7620
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: ON OCTOBER 28, 2011, THE MAINE OFFICE OF SECURITIES ENTERED INTOAN ADMINISTRATIVE CONSENT ORDER WITH RAYMOND JAMES &ASSOCIATES, INC., AND RAYMOND JAMES FINANCIAL SERVICES, INC.(COLLECTIVELY "RESPONDENTS"), IN ORDER TO SETTLE THEALLEGATIONS THAT THE RESPONDENTS ENGAGED IN DISHONEST ORUNETHICAL PRACTICES IN THE SALE OF AUCTION RATE SECURITIES("ARS"), AND FAILED TO REASONABLY SUPERVISE ITS SALESPERSONS INTHE MARKETING AND SALE OF ARS. THE RESPONDENTS NEITHERADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TO CEASE ANDDESIST FROM VIOLATING THE MAINE UNIFORM SECURITIES ACT. THERESPONDENTS AGREED TO OFFER TO PURCHASE AT PAR ARS THATSINCE FEBRUARY 13, 2008 HAVE NOT BEEN AUCTIONING FROM CERTAININVESTORS WHO PURCHASED THOSE ARS FROM THE RESPONDENTS ONOR BEFORE FEBRUARY 13, 2008. THE RESPONDENTS AGREED TO PAY$4,586 AS A CIVIL MONETARY PENALTY. THE RESPONDENTS WAIVED THEIRRIGHT TO A HEARING AND TO JUDICIAL REVIEW OF THIS MATTER.
Current Status: Final
Resolution Date: 10/28/2011
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $4,586.00Cease and Desist/Injunction
Order
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Other Sanctions Ordered:
Sanction Details: CIVIL MONETARY PENALTY OF $4,586 PAID IN FULL ON 10/28/2011.
iReporting Source: Firm
Initiated By: MAINE OFFICE OF SECURITIES
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/28/2011
Docket/Case Number: CASE NO. 11-7620
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE MAINE OFFICE OF SECURITIES ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF 32 M.R.S. SEC. 16412(4)(M). FURTHER, THEOFFICE OF SECURITIES ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF 32 M.R.S. SEC.16412(4)(I).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 10/28/2011
Resolution: Order
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Resolution Date: 10/28/2011
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 7, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$4,586.00 TO THE TREASURER, STATE OF MAINE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MAINE OFFICE OFSECURITIES ON OCTOBER 28, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,586.00Cease and Desist/Injunction
Disclosure 47 of 120
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Reporting Source: Firm
Allegations: THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF MINN. STAT. 80A.07, SUBD. 1(7) AND80A.67(D)(13). FURTHER, THE DEPARTMENT OF COMMERCE ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF MINN. STAT. 80A.07, SUBD. 1(10) AND 80A.67(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: STATE OF MINNESOTA, DEPARTMENT OF COMMERCE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/19/2011
Docket/Case Number: FILE 21296
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF MINN. STAT. 80A.07, SUBD. 1(7) AND80A.67(D)(13). FURTHER, THE DEPARTMENT OF COMMERCE ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF MINN. STAT. 80A.07, SUBD. 1(10) AND 80A.67(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/19/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 27, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$13,982.32 TO THE MINNESOTA DEPARTMENT OF COMMERCE.
Sanctions Ordered: Monetary/Fine $13,982.32Cease and Desist/Injunction
Order
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Sanction Details: ON OCTOBER 27, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$13,982.32 TO THE MINNESOTA DEPARTMENT OF COMMERCE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MINNESOTADEPARTMENT OF COMMERCE ON OCTOBER 19, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 48 of 120
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Reporting Source: Firm
Allegations: THE OFFICE OF THE KANSAS SECURITIES COMMISSIONER ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF K.S.A. 17-12A412(D)(13).FURTHER, THE SECURITIES COMMISSIONER ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF K.S.A. 17-12A412(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: KANSAS SECURITIES COMMISSIONER
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/14/2011
Docket/Case Number: DOCKET NO. 12 E 006 -- KSC NO. 2012-5915
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE OFFICE OF THE KANSAS SECURITIES COMMISSIONER ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF K.S.A. 17-12A412(D)(13).FURTHER, THE SECURITIES COMMISSIONER ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF K.S.A. 17-12A412(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/14/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 27, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$6,238.62 TO THE OFFICE OF THE KANSAS SECURITIES COMMISSIONER.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OFFICE OF THE KANSASSECURITIES COMMISSIONER ON OCTOBER 14, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $6,238.62Cease and Desist/Injunction
Order
138©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OFFICE OF THE KANSASSECURITIES COMMISSIONER ON OCTOBER 14, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 49 of 120
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Reporting Source: Firm
Allegations: THE WYOMING SECRETARY OF STATE, SECURITIES DIVISION ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF W.S. SEC. 17-4-106(A)(2)(G). FURTHER, THE SECURITIES DIVISION ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF W.S. SEC. 17-4-106(B)(2)(A).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
139©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: STATE OF WYOMING, SECRETARY OF STATE, SECURITIES DIISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/05/2011
Docket/Case Number: ORDER NO. 11-06
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE WYOMING SECRETARY OF STATE, SECURITIES DIVISION ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF W.S. SEC. 17-4-106(A)(2)(G). FURTHER, THE SECURITIES DIVISION ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF W.S. SEC. 17-4-106(B)(2)(A).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/05/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$21,489.92 TO THE WYOMING SECRETARY OF STATE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WYOMING SECRETARYOF STATE, SECURITIES DIVISION ON OCTOBER 5, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $21,489.92Cease and Desist/Injunction
Order
140©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE WYOMING SECRETARYOF STATE, SECURITIES DIVISION ON OCTOBER 5, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 50 of 120
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Reporting Source: Firm
Allegations: THE STATE OF NEW MEXICO, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF THE NEW MEXICO UNIFORMSECURITIES ACT SEC. 58-13B-16A(2)(H). FURTHER, THE SECURITIESDIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLYSUPERVISE THEIR AGENTS IN VIOLATION OF THE NEW MEXICO UNIFORMSECURITIES ACT SEC. 58-13B-16A(2)(K).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
141©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: STATE OF NEW MEXICO REGULATION AND LICENSING DEPT., SECURITIESDIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/03/2011
Docket/Case Number: MATTER NO. 11-11-996-015
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE STATE OF NEW MEXICO, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF THE NEW MEXICO UNIFORMSECURITIES ACT SEC. 58-13B-16A(2)(H). FURTHER, THE SECURITIESDIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLYSUPERVISE THEIR AGENTS IN VIOLATION OF THE NEW MEXICO UNIFORMSECURITIES ACT SEC. 58-13B-16A(2)(K).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/03/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$5,719.23 TO THE NEW MEXICO SECURITIES DIVISION.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF NEW MEXICOSECURITIES DIVISION ON OCTOBER 3, 2011, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $5,719.23Cease and Desist/Injunction
Order
142©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF NEW MEXICOSECURITIES DIVISION ON OCTOBER 3, 2011, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 51 of 120
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Reporting Source: Firm
Allegations: THE IDAHO DEPARTMENT OF FINANCE ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF IDAHO CODE SEC. 30-14-412(D)(13).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFIDAHO CODE SEC. 30-14-412(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
143©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: IDAHO DEPARTMENT OF FINANCE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/03/2011
Docket/Case Number: DOCKET NO. 2011-7-15
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE IDAHO DEPARTMENT OF FINANCE ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF IDAHO CODE SEC. 30-14-412(D)(13).FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMESFAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OFIDAHO CODE SEC. 30-14-412(D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/03/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 6, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$4,491.57 TO THE IDAHO DEPARTMENT OF FINANCE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE IDAHO DEPARTMENT OFFINANCE ON OCTOBER 3, 2011, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,491.57Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE IDAHO DEPARTMENT OFFINANCE ON OCTOBER 3, 2011, IN WHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 52 of 120
i
Reporting Source: Regulator
Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SECURITIES.
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
CIVIL PENALTY; BUYBACK OF ELIGIBLE AUCTION RATE SECURITIES FROMELIGIBLE INVESTORS
Date Initiated: 10/13/2011
Docket/Case Number: S-11-0060
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s):
Allegations: ENGAGING IN DISHONEST OR UNETHICAL PRACTICES IN CONNECTIONWITH THE PURCHASE OR SALE OF SECURITIES; FAILURE TO SUPERVISE
Current Status: Final
Resolution Date: 10/13/2011
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Consent
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Other Sanctions Ordered: BUYBACK OF ELIGIBLE AUCTION RATE SECURITIES FROM ELIGIBLEINVESTORS; CIVIL PENALTY OF $5,577.58
Sanction Details: CIVIL PENALTY PAYMENT TO OREGON OF $5,577.58 WAS RECEIVED ON10/21/11.
Regulator Statement THIS CASE RELATES TO MULI-STATE TASK FORCE INVESTIGATIONS,COORDINATED BY NASAA, OF INVESTOR COMPLIANTS REGARDING THEMARKETING OF AUCTION RATE SECURITIES. OREGON CONSENT ORDERWAS EXECUTED ON 10/13/11.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $5,577.58Cease and Desist/Injunction
iReporting Source: Firm
Allegations: THE OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SERVICES, ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF ORS 59.205(2). FURTHER, THEOREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICESALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF ORS 59.205(13).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
146©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SECURITIES
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 10/13/2011
Docket/Case Number: DFCS FILE NO. S-11-0060
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SERVICES, ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF ORS 59.205(2). FURTHER, THEOREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICESALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF ORS 59.205(13).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 10/13/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 18, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$5,577.58 TO THE OREGON DEPARTMENT OF CONSUMER AND BUSINESSSERVICES.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OREGON DEPARTMENTOF CONSUMER AND BUSINESS SERVICES ON OCTOBER 13, 2011, INWHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $5,577.58Cease and Desist/Injunction
Order
147©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OREGON DEPARTMENTOF CONSUMER AND BUSINESS SERVICES ON OCTOBER 13, 2011, INWHICH IT CONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 53 of 120
i
Reporting Source: Firm
Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT
Allegations: THE NORTH DAKOTA SECURITIES DEPARTMENT ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF N.D.C.C. SEC. 10-04-11(1)(C). FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF N.D.C.C. SEC.10-04-11(1)(M).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
148©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 09/26/2011
Docket/Case Number: N/A
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 09/26/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 29, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $3,972.18 TO THE NORTH DAKOTA SECURITIES DEPARTMENT.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NORTH DAKOTASECURITIES DEPARTMENT ON SEPTEMBER 26, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $3,972.18Cease and Desist/Injunction
Order
149©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NORTH DAKOTASECURITIES DEPARTMENT ON SEPTEMBER 26, 2011, IN WHICH ITCONSENTED:
(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 54 of 120
i
Reporting Source: Firm
Initiated By: TENNESSEE DEPT. OF COMMERCE AND INSURANCE, SECURITIESDIVISION
Date Initiated: 09/19/2011
Docket/Case Number: ORDER NO. 11-010 (SI#2011-002)
Allegations: THE TENNESSEE DEPT. OF COMMERCE AND INSURANCE, SECURITIESDIVISION ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONEST ORUNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OFTENN. CODE ANN. SEC. 48-2-112(A)(2)(G). FURTHER, THE SECURITIESDIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLYSUPERVISE THEIR AGENTS IN VIOLATION OF TENN. CODE ANN. SEC. 48-2-112(A)(2)(J).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
150©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Docket/Case Number: ORDER NO. 11-010 (SI#2011-002)
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 09/19/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 21, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $30,414.06 TO THE STATE OF TENNESSEE, SECURITIES DIVISION.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE TENNESSEESECURITIES DIVISION ON SEPTEMBER 19, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $30,414.06Cease and Desist/Injunction
Order
151©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE TENNESSEESECURITIES DIVISION ON SEPTEMBER 19, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 55 of 120
i
Reporting Source: Firm
Initiated By: MONTANA COMMISSIONER OF SECURITIES AND INSURANCE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 09/12/2011
Docket/Case Number: SEC-2001-228
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE MONTANA COMMISSIONER OF SECURITIES AND INSURANCE ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF MONT. CODEANN. SEC. 30-10-201 (13)(G). FURTHER, THE COMMISSIONER ALLEGEDTHAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIRAGENTS IN VIOLATION OF MONT. CODE ANN. SEC. 30-10-201 (13)(K).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
152©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Resolution Date: 09/12/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 21, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $4,538.79 TO THE STATE OF MONTANA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE MONTANACOMMISSIONER OF SECURITIES ON SEPTEMBER 12, 2011, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,538.79Cease and Desist/Injunction
Order
153©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Disclosure 56 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/29/2011
Docket/Case Number: 2010024958501
Principal Product Type: Other
Other Product Type(s): LOW PRICED SECURITIES
Allegations: FINRA RULE 2010, NASD RULES 2110, 2440, 3010, INTERPRETATIVEMATERIAL 2440-1 - RAYMOND JAMES & ASSOCIATES, INC. UTILIZED ANAUTOMATED COMMISSION SCHEDULE PURSUANT TO WHICH THE FIRMCHARGED COMMISSIONS ON CERTAIN PURCHASES AND SALES OFPRIMARILY LOW-PRICED SECURITIES THAT WERE NOT FAIR ANDREASONABLE, TAKING INTO CONSIDERATION THE FACTORS SET FORTH ININTERPRETATIVE MATERIAL 2440-1(B). AS A RESULT, THE FIRM CHARGED$893,888.69 IN EXCESSIVE COMMISSIONS. THE FIRM'S SUPERVISORYSYSTEM WAS INADEQUATE BECAUSE IN ESTABLISHING ITS COMMISSIONSCHEDULE AND IN SETTING COMMISSIONS ON TRANSACTIONS, THE FIRMFAILED TO CONSIDER, FOR EACH SPECIFIC TRANSACTION, THE FACTORSDELINEATED IN INTERPRETATIVE MATERIAL 2440-1(B).
Current Status: Final
Resolution Date: 09/29/2011
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $225,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
154©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $225,000, AND ORDERED TOPAY $893.888.69, PLUS INTEREST, IN RESTITUTION. THE FIRM SHALL ALSOPAY RESTITUTION TO CUSTOMERS WHO WERE CHARGED, AND WILL BECHARGED, UNFAIR AND UNREASONABLE COMMISSIONS FROMNOVEMBER 1, 2010 THROUGH THE DATE THAT THE FIRM REVISES ITSAUTOMATED COMMISSION SCHEDULE TO CONFORM TO THEREQUIREMENTS IN NASD RULE 2440. THE FIRM SHALL PROVIDE FINRAWITH A CERTIFICATION BY A REGISTERED PRINCIPAL ON BEHALF OF THEFIRM WITHIN 120 DAYS OF ACCEPTANCE OF THIS AWC THAT IT HASREVISED ITS AUTOMATED COMMISSION SCHEDULE. A REGISTEREDPRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION NOLATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCHACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTEDRESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY.
iReporting Source: Firm
Initiated By: FINRA
Date Initiated: 09/29/2011
Docket/Case Number: 2010024958501
Allegations: FINRA RULE 2010, NASD RULES 2110, 2440, 3010, INTERPRETATIVEMATERIAL 2440-1 - RAYMOND JAMES & ASSOCIATES, INC. UTILIZED ANAUTOMATED COMMISSION SCHEDULE PURSUANT TO WHICH THE FIRMCHARGED COMMISSIONS ON CERTAIN PURCHASES AND SALES OFPRIMARILY LOW-PRICED SECURITIES THAT WERE NOT FAIR ANDREASONABLE, TAKING INTO CONSIDERATION THE FACTORS SET FORTH ININTERPRETATIVE MATERIAL 2440-1(B). AS A RESULT, THE FIRM CHARGED$893,888.69 IN EXCESSIVE COMMISSIONS. THE FIRM'S SUPERVISORYSYSTEM WAS INADEQUATE BECAUSE IN ESTABLISHING ITS COMMISSIONSCHEDULE AND IN SETTING COMMISSIONS ON TRANSACTIONS, THE FIRMFAILED TO CONSIDER, FOR EACH SPECIFIC TRANSACTION, THE FACTORSDELINEATED IN INTERPRETATIVE MATERIAL 2440-1(B).
Current Status: Final
155©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Docket/Case Number: 2010024958501
Principal Product Type: Other
Other Product Type(s): LOW PRICED SECURITIES
Resolution Date: 09/29/2011
Resolution:
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $225,000 AND ORDERED TOPAY $893,888.69, PLUS INTEREST, IN RESTITUTION. THE FIRM SHALL ALSOPAY RESTITUTION TO CUSTOMERS WHO WERE CHARGED, AND WILL BECHARGED, UNFAIR AND UNREASONABLE COMMISSIONS FROMNOVEMBER 1, 2010 THROUGH THE DATE THAT THE FIRM REVISES ITSAUTOMATED COMMISSION SCHEDULE TO CONFORM TO THEREQUIREMENTS IN NASD RULE 2440. THE FIRM SHALL PROVIDE FINRAWITH A CERTIFICATION BY A REGISTERED PRINCIPAL ON BEHALF OF THEFIRM WITHIN 120 DAYS OF ACCEPTANCE OF THIS AWC THAT IT HASREVISED ITS AUTOMATED COMMISSION SCHEDULE. A REGISTEREDPRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION NOLATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCHACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTEDRESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY.
Sanctions Ordered: CensureMonetary/Fine $225,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 57 of 120
i
Reporting Source: Regulator
Allegations: FINRA RULE 2010, NASD RULES 2110, 2320 - RAYMOND JAMES &ASSOCIATES, INC. FAILED TO EXECUTE ORDERS FULLY AND PROMPTLYAND IN MANY OF THESE TRANSACTIONS FOR OR WITH A CUSTOMER, THEFIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BESTINTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKETSO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLEAS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Current Status: Final
156©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/23/2011
Docket/Case Number: 2009017657001
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: FINRA RULE 2010, NASD RULES 2110, 2320 - RAYMOND JAMES &ASSOCIATES, INC. FAILED TO EXECUTE ORDERS FULLY AND PROMPTLYAND IN MANY OF THESE TRANSACTIONS FOR OR WITH A CUSTOMER, THEFIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BESTINTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKETSO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLEAS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Resolution Date: 09/23/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND ORDERED TOPAY $1,849.33, PLUS INTEREST, IN RESTITUTION TO INVESTORS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $12,500.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
157©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND ORDERED TOPAY $1,849.33, PLUS INTEREST, IN RESTITUTION TO INVESTORS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/23/2011
Docket/Case Number: 2009017657001
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: FINRA RULE 2010, NASD RULES 2110, 2320 - RAYMOND JAMES &ASSOCIATES, INC. FAILED TO EXECUTE ORDERS FULLY AND PROMPTLYAND IN MANY OF THESE TRANSACTIONS FOR OR WITH A CUSTOMER, THEFIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BESTINTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKETSO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLEAS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Current Status: Final
Resolution Date: 09/23/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND ORDERED TOPAY $1,849.33, PLUS INTEREST, IN RESTITUTION TO INVESTORS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.
Sanctions Ordered: CensureMonetary/Fine $12,500.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
158©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND ORDERED TOPAY $1,849.33, PLUS INTEREST, IN RESTITUTION TO INVESTORS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.
Disclosure 58 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/20/2011
Docket/Case Number: 2009016867701
Principal Product Type: No Product
Other Product Type(s):
Allegations: FINRA RULE 7450, NASD RULE 6955 - RAYMOND JAMES & ASSOCIATES,INC. FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES)CONCERNING NUMEROUS ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) FOR MORE THAN TWO YEARS.
Current Status: Final
Resolution Date: 09/20/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $15,000.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $15,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: 159©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Reporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/20/2011
Docket/Case Number: 2009016867701
Principal Product Type: No Product
Other Product Type(s):
Allegations: FINRA RULE 7450, NASD RULE 6955 - RAYMOND JAMES & ASSOCIATES,INC. FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES)CONCERNING NUMEROUS ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) FOR MORE THAN TWO YEARS.
Current Status: Final
Resolution Date: 09/20/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $15,000.00.
Sanctions Ordered: CensureMonetary/Fine $15,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 59 of 120
i
Reporting Source: Firm
Allegations: THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF SEC. 7-11-212(8)OF THE RIUSA. FURTHER, THE DEPARTMENT ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF SEC. 7-11-212(11) OF THE RIUSA.
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
160©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/26/2011
Docket/Case Number: NONE
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF SEC. 7-11-212(8)OF THE RIUSA. FURTHER, THE DEPARTMENT ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF SEC. 7-11-212(11) OF THE RIUSA.
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 08/26/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 16, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $3,594.44 TO THE GENERAL TREASURER, STATE OF RHODE ISLAND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE RHODE ISLANDDEPARTMENT OF BUSINESS REGULATION ON AUGUST 26, 2011, IN WHICHIT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $3,594.44Cease and Desist/Injunction
Order
161©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE RHODE ISLANDDEPARTMENT OF BUSINESS REGULATION ON AUGUST 26, 2011, IN WHICHIT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 60 of 120
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Reporting Source: Firm
Allegations: THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES ANDHEALTH CARE ADMINISTRATION (THE "DEPARTMENT") ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF 9 V.S.A. SEC. 5412 (D)(13).FURTHER, THE DEPARTMENT ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF 9 V.S.A. SEC.5412 (D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
162©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES ANDHEALTHCARE
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 09/09/2011
Docket/Case Number: DOCKET NO. 11-034-S
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES ANDHEALTH CARE ADMINISTRATION (THE "DEPARTMENT") ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF 9 V.S.A. SEC. 5412 (D)(13).FURTHER, THE DEPARTMENT ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF 9 V.S.A. SEC.5412 (D)(9).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 09/09/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 16, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $4,255.48 TO THE VERMONT GENERAL FUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE DEPARTMENT ONSEPTEMBER 9, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $4,255.48Cease and Desist/Injunction
Order
163©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE DEPARTMENT ONSEPTEMBER 9, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 61 of 120
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Reporting Source: Firm
Allegations: THE NEW JERSEY BUREAU OF SECURITIES ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF N.J.S.A. 49:3-58(A)(2)(VII). FURTHER, THEBUREAU OF SECURITIES ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF N.J.S.A. 49:3-58(A)(2)(XI).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
164©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NEW JERSEY BUREAU OF SECURITIES
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 09/08/2011
Docket/Case Number: NONE
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE NEW JERSEY BUREAU OF SECURITIES ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF N.J.S.A. 49:3-58(A)(2)(VII). FURTHER, THEBUREAU OF SECURITIES ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF N.J.S.A. 49:3-58(A)(2)(XI).
RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 09/08/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $35,183.04 TO THE NEW JERSEY BUREAU OF SECURITIES.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEW JERSEY BUREAUOF SECURITIES ON SEPTEMBER 8, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $35,183.04Cease and Desist/Injunction
Order
165©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEW JERSEY BUREAUOF SECURITIES ON SEPTEMBER 8, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 62 of 120
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Reporting Source: Firm
Initiated By: SOUTH DAKOTA DIVISION OF SECURITIES
Date Initiated: 08/25/2011
Docket/Case Number: NONE
Allegations: THE SOUTH DAKOTA DIVISION OF SECURITIES ALLEGED THAT RAYMONDJAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALEOF SECURITIES IN VIOLATION OF SDCL 47-31B-412(D)(13) AND ARSD20:08:03:06. FURTHER, THE DIVISION OF SECURITIES ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF SDCL 47-31B-412(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
166©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Docket/Case Number: NONE
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 08/25/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $5,388.71 TO THE STATE OF SOUTH DAKOTA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SOUTH DAKOTADIVISION OF SECURITIES ON AUGUST 25, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $5,388.71Cease and Desist/Injunction
Order
167©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SOUTH DAKOTADIVISION OF SECURITIES ON AUGUST 25, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 63 of 120
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Reporting Source: Firm
Initiated By: SECURITIES COMMISSIONER OF SOUTH CAROLINA
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/25/2011
Docket/Case Number: FILE NO. 10056
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE SECURITIES COMMISSIONER OF SOUTH CAROLINA ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF S.C. CODE ANN. SEC. 35-1-412(13). FURTHER, THE SECURITIES COMMISSIONER ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS INVIOLATION OF S.C. CODE ANN. SEC. 35-1-412(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
168©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Resolution Date: 08/25/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 2, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$15,304.31 TO THE SOUTH CAROLINA ATTORNEY GENERAL.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SECURITIESCOMMISSIONER OF SOUTH CAROLINA ON AUGUST 25, 2011, IN WHICH ITCONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $15,304.41Cease and Desist/Injunction
Order
169©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Disclosure 64 of 120
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Reporting Source: Firm
Initiated By: PUERTO RICO OFFICE OF THE COMMISSIONER OF FINANCIALINSTITUTIONS
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/25/2011
Docket/Case Number: C11 - ND - 008
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE PUERTO RICO COMMISSION OF FINANCIAL INSTITUTIONS ALLEGEDTHAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICALPRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF ARTICLE204(A)(2)(G) OF ACT NO. 60. FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF ARTICLE 204(A)(2)(I) OF ACT NO. 60.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 08/25/2011
Resolution: Order
170©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 2, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$3,500 TO THE SECRETARIO DE HACIENDA DE PUERTO RICO, SECURITIESTRADING, INVESTOR EDUCATION AND INVESTIGATION FUND.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE PUERTO RICOCOMMISSION OF FINANCIAL INSTITUTIONS ON AUGUST 25, 2011, IN WHICHIT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $3,500.00Cease and Desist/Injunction
Disclosure 65 of 120
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Reporting Source: Firm
Current Status: Final
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Initiated By: ALABAMA SECURITIES COMMISSION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/23/2011
Docket/Case Number: NO. C0-2011
Principal Product Type: Other
Other Product Type(s): AUTION RATE SECURITIES
Allegations: THE ALABAMA SECURITIES COMMISSION ALLEGED THAT RAYMOND JAMESENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OFSECURITIES IN VIOLATION OF SECTION 8-6-3 (J) (7), CODE OF ALABAMA1975, THE ALABAMA SECURITIES ACT. FURTHER, THE SECURITIESDIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLYSUPERVISE THEIR AGENTS IN VIOLATION OF SECTION 8-6-3 (J) (10), CODEOF ALABAMA 1975, THE ALABAMA SECURITIES ACT.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 08/23/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON SEPTEMBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $23,189.76 TO THE ALABAMA SECURITIES COMMISSION PAYABLE AS$22,189.76 TO THE ALABAMA SECURITIES COMMISSION AND $1,000.00 TONASAA.
Sanctions Ordered: Monetary/Fine $23,189.76Cease and Desist/Injunction
Order
172©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Sanction Details: ON SEPTEMBER 12, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNTOF $23,189.76 TO THE ALABAMA SECURITIES COMMISSION PAYABLE AS$22,189.76 TO THE ALABAMA SECURITIES COMMISSION AND $1,000.00 TONASAA.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE ALABAMA SECURITIESCOMMISSION ON AUGUST 23, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 66 of 120
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Reporting Source: Firm
Allegations: THE NEVADA SECRETARY OF STATE, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF NRS 90.420(1)(H). FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF NRS 90.420(1)(L).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE
Current Status: Final
173©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: STATE OF NEVADA, SECRETARY OF STATE, SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/18/2011
Docket/Case Number: MATTER NO. I11-142
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE NEVADA SECRETARY OF STATE, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF NRS 90.420(1)(H). FURTHER,THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF NRS 90.420(1)(L).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE
Resolution Date: 08/18/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON AUGUST 22, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$7,230.19 TO THE NEVADA SECRETARY OF STATE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEVADA SECRETARY OFSTATE ON AUGUST 18, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $7,230.19Cease and Desist/Injunction
Order
174©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NEVADA SECRETARY OFSTATE ON AUGUST 18, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 67 of 120
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Reporting Source: Firm
Allegations: THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF IND. CODE SEC.23-19-4-12(D)(13). FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF IND. CODE SEC. 23-19-4-12(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
175©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: STATE OF INDIANA, SECRETARY OF STATE, SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE AND DESIST
Date Initiated: 08/05/2011
Docket/Case Number: 11-0210 CO
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SALE OF SECURITIES IN VIOLATION OF IND. CODE SEC.23-19-4-12(D)(13). FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMONDJAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATIONOF IND. CODE SEC. 23-19-4-12(D)(9).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 08/05/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON AUGUST 15, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$62,503.17 TO THE INDIANA SECRETARY OF STATE.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE INDIANA SECRETARY OFSTATE ON AUGUST 5, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $62,503.17Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE INDIANA SECRETARY OFSTATE ON AUGUST 5, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 68 of 120
i
Reporting Source: Regulator
Initiated By: TEXAS
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 06/29/2011
Docket/Case Number: ORDER NO. IC11-FIN-08
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: INEQUITABLE PRACTICES AND FAILURE TO SUPERVISE AGENTS INCONNECTION WITH THE SALE OF AUCTION RATE SECURITIES PRIOR TOFEBRUARY 13, 2008.
Current Status: Final
Resolution Date: 06/29/2011
Resolution: Consent
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Resolution Date: 06/29/2011
Other Sanctions Ordered: RESPONDENTS HAVE AGREED TO PURCHASE CERTAIN AUCTION RATESECURITIES FROM CUSTOMERS, TO USE BEST EFFORTS TO PROVIDELIQUIDITY SOLUTIONS FOR SOME CUSTOMERS.
Sanction Details: RESPONDENTS PAID A FINE OF $293,595.77.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $293,595.77
iReporting Source: Firm
Initiated By: TEXAS STATE SECURITIES BOARD
Date Initiated: 06/29/2011
Docket/Case Number: 1C11-FIN-08
Allegations: THE TEXAS STATE SECURITIES BOARD ALLEGED THAT RAYMOND JAMESENGAGED IN INEQUITABLE PRACTICES IN THE SALE OF SECURITIES.FURTHER, THE TEXAS STATE SECURITIES BOARD ALLEGED THATRAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR FINANCIALADVISORS IN VIOLATION OF SECTION 115.10(B) OF THE RULES ANDREGULATION OF THE TEXAS STATE SECURITIES BOARD.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
178©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
FINE
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Resolution Date: 06/29/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: ON JULY 7, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$293,595.77 TO THE STATE OF TEXAS.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE TEXAS STATESECURITIES BOARD ON JUNE 29, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: Monetary/Fine $293,595.77Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE TEXAS STATESECURITIES BOARD ON JUNE 29, 2011, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 69 of 120
i
Reporting Source: Regulator
Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFFICE")
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 06/29/2011
Docket/Case Number: 0404-S-10/08
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES ("ARS")
Allegations: ON 6/29/2011, THE OFFICE, SUBSEQUENT TO COORDINATEDINVESTIGATIONS CONDUCTED BY A MULTI-STATE TASK FORCECONSISTING OF MEMBER STATES OF THE NORTH AMERICAN SECURITIESADMINISTRATORS ASSOCIATION ("NASAA"), ENTERED INTO ANADMINISTRATIVE CONSENT AGREEMENT REGARDING RAYMOND JAMES'ACTIVITIES IN THE MARKETING AND SALE OF ARS PRIOR TO WIDESPREADFAILED AUCTIONS BEGINNING IN FEBRUARY 2008.
Current Status: Final
Resolution Date: 06/29/2011
Resolution:
Other Sanctions Ordered: ON 6/29/2011, THE OFFICE ENTERED A FINAL ORDER ADOPTING THEADMINISTRATIVE CONSENT AGREEMENT WHEREBY RAYMOND JAMESAGREED TO DO THE FOLLOWING: 1.) OFFER TO PURCHASE ARS AT PARPLUS ACCRUED AND UNPAID DIVIDENDS OR INTEREST FOR CERTAIN "ELIGIBLE" INVESTORS, 2.) TO USE BEST EFFORTS TO PROVIDE LIQUIDITYSOLUTIONS FOR CERTAIN OTHER CUSTOMERS, AND; 3.) PARTICIPATE INSPECIAL ARBITRATION PROCESS.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $634,933.58Cease and Desist/Injunction
Order
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Other Sanctions Ordered: ON 6/29/2011, THE OFFICE ENTERED A FINAL ORDER ADOPTING THEADMINISTRATIVE CONSENT AGREEMENT WHEREBY RAYMOND JAMESAGREED TO DO THE FOLLOWING: 1.) OFFER TO PURCHASE ARS AT PARPLUS ACCRUED AND UNPAID DIVIDENDS OR INTEREST FOR CERTAIN "ELIGIBLE" INVESTORS, 2.) TO USE BEST EFFORTS TO PROVIDE LIQUIDITYSOLUTIONS FOR CERTAIN OTHER CUSTOMERS, AND; 3.) PARTICIPATE INSPECIAL ARBITRATION PROCESS.
Sanction Details: THE ADMINISTRATIVE FINE AMOUNT OF $384,933.58 REPRESENTS THESTATE OF FLORIDA'S PRO RATA SHARE OF THE ONE MILLION SEVENHUNDRED-FIFTY THOUSAND DOLLAR ($1,750,000.00) TOTAL PENALTY THATRAYMOND JAMES AGREED TO PAY PURSUANT TO THE MULTI-STATESETTLEMENT.
Regulator Statement PER THE OFFICE'S FINAL ORDER DATED 6/29/2011 ADOPTING THECONSENT AGREEMENT, RAYMOND JAMES, WITHOUT ADMITTING ORDENYING THE STATEMENT OF FACTS AND CONCLUSIONS OF LAWCONTAINED IN THE AGREEMENT, AND WITHOUT AN ADJUDICATION OF ANYISSUE OF LAW OR FACT, CONSENTED TO THE ENTRY OF THE OFFICE'SFINDINGS OF FACTS AND CONCLUSIONS OF LAW THAT THEY ENGAGED INDISHONEST OR UNETHICAL PRACTICES AND FAILED TO REASONABLYSUPERVISE THEIR AGENTS.
iReporting Source: Firm
Allegations: THE FLORIDA OFFICE OF FINANCIAL REGULATION (OFR) ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INVIOLATION OF SECTION 517.161(1)(H) OF THE FLORIDA STATUTES.FURTHER, THE OFR ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE ITS FINANCIAL ADVISORS IN VIOLATION OFRULE 69W-600.013(1)(H)1., FLORIDA ADMINISTRATIVE CODE, AND NASDCONDUCT RULE 3010.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: STATE OF FLORIDA - OFFICE OF FINANCIAL REGULATION
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
FINE; CENSURE; INVESTIGATIVE COSTS; REIMBURSEMENT OF NASAAASSISTANCE.
Date Initiated: 06/29/2011
Docket/Case Number: 0404-S-10/08 AND 0404A-S-10/08
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
THE FLORIDA OFFICE OF FINANCIAL REGULATION (OFR) ALLEGED THATRAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INVIOLATION OF SECTION 517.161(1)(H) OF THE FLORIDA STATUTES.FURTHER, THE OFR ALLEGED THAT RAYMOND JAMES FAILED TOREASONABLY SUPERVISE ITS FINANCIAL ADVISORS IN VIOLATION OFRULE 69W-600.013(1)(H)1., FLORIDA ADMINISTRATIVE CODE, AND NASDCONDUCT RULE 3010.RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 06/29/2011
Resolution:
Other Sanctions Ordered: COSTS OF INVESTIGATION AND CONSIDERATION FOR FINANCIALASSISTANCE PROVIDED.
Sanction Details: ON JULY 7, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$384,933.58 TO THE OFR AND $250,000 TO THE OFR BASED ON FEES ANDEXPENSES INCURRED IN CONNECTION WITH ITS INVESTIGATION. ONJULY 7, 2011, RAYMOND JAMES PAID $25,000 TO THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION AS CONSIDERATION FORFINANCIAL ASSISTANCE PROVIDED.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OFR ON JUNE 29, 2011,IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: CensureMonetary/Fine $384,933.58Cease and Desist/Injunction
Order
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE OFR ON JUNE 29, 2011,IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 70 of 120
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Reporting Source: Regulator
Allegations: SEC ADMIN RELEASES 33-9228, 34-64767; IA RELEASE 3227, JUNE 29, 2011:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACTOF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENTADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST RAYMOND JAMES &ASSOCIATES, INC. ("RJ&A" "RESPONDENT").
THE COMMISSION FOUND THAT:
RJ&A OFFERED AND SOLD TO SOME CUSTOMERS FINANCIALINSTRUMENTS KNOWN AS AUCTION RATE SECURITIES ("ARS") WHILE NOTACCURATELY CHARACTERIZING OR WHILE FAILING TO ADEQUATELYDISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESEINVESTMENTS. ARS ARE BONDS OR PREFERRED STOCK WHOSELIQUIDITY DEPENDS UPON SUFFICIENT DEMAND AT PERIODICSECURITIES AUCTIONS. ALTHOUGH RJ&A'S ARS TRADE CONFIRMATIONS,SENT AFTER CUSTOMERS PURCHASED ARS, DISCLOSED THE RISK THATTHESE AUCTIONS COULD FAIL AND THAT IT WAS NOT OBLIGED TOENSURE THEIR SUCCESS, AT THE POINT-OF-SALE, SOME OF RJ&A'SREGISTERED REPRESENTATIVES AND FINANCIAL ADVISERS IMPROPERLYDESCRIBED ARS AS SAFE, LIQUID ALTERNATIVES TO MONEY MARKETFUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELYDISCLOSING THE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IFTHESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, A SIGNIFICANTNUMBER OF ARS AUCTIONS FAILED, RESULTING IN AN OVERALL MARKETCOLLAPSE THAT LEFT THOUSANDS OF INVESTORS, INCLUDING RJ&A'SCUSTOMERS, HOLDING ARS THAT THEY HAVE NOT BEEN ABLE TOLIQUIDATE.
RJ&A WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT,WHICH MAKES IT UNLAWFUL FOR ANY PERSON IN THE OFFER OR SALE OFANY SECURITIES BY THE USE OF ANY MEANS OR INSTRUMENTS OFTRANSPORTATION OR COMMUNICATION IN INTERSTATE COMMERCE ORBY USE OF THE MAILS, DIRECTLY OR INDIRECTLY, TO OBTAIN MONEY ORPROPERTY BY MEANS OF ANY UNTRUE STATEMENT OF A MATERIAL FACTOR ANY OMISSION TO STATE A MATERIAL FACT NECESSARY IN ORDER TOMAKE THE STATEMENTS MADE, IN LIGHT OF THE CIRCUMSTANCES UNDERWHICH THEY WERE MADE, NOT MISLEADING.
Current Status: Final
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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 06/29/2011
Docket/Case Number: 3-14445
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
SEC ADMIN RELEASES 33-9228, 34-64767; IA RELEASE 3227, JUNE 29, 2011:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACTOF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENTADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST RAYMOND JAMES &ASSOCIATES, INC. ("RJ&A" "RESPONDENT").
THE COMMISSION FOUND THAT:
RJ&A OFFERED AND SOLD TO SOME CUSTOMERS FINANCIALINSTRUMENTS KNOWN AS AUCTION RATE SECURITIES ("ARS") WHILE NOTACCURATELY CHARACTERIZING OR WHILE FAILING TO ADEQUATELYDISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESEINVESTMENTS. ARS ARE BONDS OR PREFERRED STOCK WHOSELIQUIDITY DEPENDS UPON SUFFICIENT DEMAND AT PERIODICSECURITIES AUCTIONS. ALTHOUGH RJ&A'S ARS TRADE CONFIRMATIONS,SENT AFTER CUSTOMERS PURCHASED ARS, DISCLOSED THE RISK THATTHESE AUCTIONS COULD FAIL AND THAT IT WAS NOT OBLIGED TOENSURE THEIR SUCCESS, AT THE POINT-OF-SALE, SOME OF RJ&A'SREGISTERED REPRESENTATIVES AND FINANCIAL ADVISERS IMPROPERLYDESCRIBED ARS AS SAFE, LIQUID ALTERNATIVES TO MONEY MARKETFUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELYDISCLOSING THE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IFTHESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, A SIGNIFICANTNUMBER OF ARS AUCTIONS FAILED, RESULTING IN AN OVERALL MARKETCOLLAPSE THAT LEFT THOUSANDS OF INVESTORS, INCLUDING RJ&A'SCUSTOMERS, HOLDING ARS THAT THEY HAVE NOT BEEN ABLE TOLIQUIDATE.
RJ&A WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT,WHICH MAKES IT UNLAWFUL FOR ANY PERSON IN THE OFFER OR SALE OFANY SECURITIES BY THE USE OF ANY MEANS OR INSTRUMENTS OFTRANSPORTATION OR COMMUNICATION IN INTERSTATE COMMERCE ORBY USE OF THE MAILS, DIRECTLY OR INDIRECTLY, TO OBTAIN MONEY ORPROPERTY BY MEANS OF ANY UNTRUE STATEMENT OF A MATERIAL FACTOR ANY OMISSION TO STATE A MATERIAL FACT NECESSARY IN ORDER TOMAKE THE STATEMENTS MADE, IN LIGHT OF THE CIRCUMSTANCES UNDERWHICH THEY WERE MADE, NOT MISLEADING.
Resolution Date: 06/29/2011
Resolution:
Other Sanctions Ordered: UNDERTAKING:
RJ&A HAS UNDERTAKEN TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLECUSTOMERS, AND OTHER MEASURES, AS SPECIFIED UNDER THE TERMSSET FORTH.
A. KEY DEFINITIONS
1. "ELIGIBLE ARS" SHALL MEAN AUCTION RATE SECURITIES THAT WEREPURCHASED AT RJ&A ON OR BEFORE FEBRUARY 13, 2008 AND THAT HAVEFAILED AT AUCTION AT LEAST ONCE SINCE THEN.
2. "ELIGIBLE CUSTOMERS" ARE THE CURRENT AND FORMER ACCOUNTOWNERS WHO PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008, DID NOT TRANSFER SUCH ELIGIBLE ARS AWAY FROMRJ&A PRIOR TO JANUARY 1, 2006, AND HELD THOSE SECURITIES ONFEBRUARY 13, 2008. "ELIGIBLE CUSTOMERS" SHALL NOT INCLUDE ARSCUSTOMERS WHO ACTED AS INSTITUTIONAL MONEY MANAGERS AND DIDNOT HOLD ARS IN RJ&A ACCOUNTS.
A. RJ&A WILL USE BEST EFFORTS TO PROVIDE THE INSTITUTIONALMONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARSINCLUDING, BUT NOT LIMITED TO, FACILITATING ISSUER REDEMPTIONS,RESTRUCTURINGS, AND THROUGH OTHER REASONABLE MEANS.
B. RJ&A WILL USE BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RESPONDENTS BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RESPONDENTS PRIORTO JANUARY 1, 2006.
B. RJ&A SHALL ESTABLISH: 1) A DEDICATED TOLL-FREE TELEPHONEASSISTANCE LINE TO PROVIDE INFORMATION AND TO RESPOND TOQUESTIONS CONCERNING THE TERMS OF THE ORDER; AND 2) A PUBLICINTERNET PAGE ON ITS CORPORATE WEB SITE(S), WITH A PROMINENTLINK TO THAT PAGE APPEARING ON RJ&A'S RELEVANT HOMEPAGE(S), TOPROVIDE INFORMATION CONCERNING THE TERMS OF THE ORDER AND,TO RESPOND TO QUESTIONS CONCERNING THE TERMS OF THE ORDER.
C. RJ&A'S OFFER TO PURCHASE ELIGIBLE ARS
1. OFFER NOTICES.
A. NO LATER THAN 30 DAYS AFTER THE DATE OF THE ORDER, RJ&A SHALLOFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ELIGIBLE CUSTOMERS("PURCHASE OFFER"), AND EXPLAIN WHAT THE ELIGIBLE CUSTOMERSMUST DO TO ACCEPT THE PURCHASE OFFER. [UNDERTAKINGCONTINUED IN COMMENTS]
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: CensureCease and Desist/Injunction
Order
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Other Sanctions Ordered: UNDERTAKING:
RJ&A HAS UNDERTAKEN TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLECUSTOMERS, AND OTHER MEASURES, AS SPECIFIED UNDER THE TERMSSET FORTH.
A. KEY DEFINITIONS
1. "ELIGIBLE ARS" SHALL MEAN AUCTION RATE SECURITIES THAT WEREPURCHASED AT RJ&A ON OR BEFORE FEBRUARY 13, 2008 AND THAT HAVEFAILED AT AUCTION AT LEAST ONCE SINCE THEN.
2. "ELIGIBLE CUSTOMERS" ARE THE CURRENT AND FORMER ACCOUNTOWNERS WHO PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008, DID NOT TRANSFER SUCH ELIGIBLE ARS AWAY FROMRJ&A PRIOR TO JANUARY 1, 2006, AND HELD THOSE SECURITIES ONFEBRUARY 13, 2008. "ELIGIBLE CUSTOMERS" SHALL NOT INCLUDE ARSCUSTOMERS WHO ACTED AS INSTITUTIONAL MONEY MANAGERS AND DIDNOT HOLD ARS IN RJ&A ACCOUNTS.
A. RJ&A WILL USE BEST EFFORTS TO PROVIDE THE INSTITUTIONALMONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARSINCLUDING, BUT NOT LIMITED TO, FACILITATING ISSUER REDEMPTIONS,RESTRUCTURINGS, AND THROUGH OTHER REASONABLE MEANS.
B. RJ&A WILL USE BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RESPONDENTS BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RESPONDENTS PRIORTO JANUARY 1, 2006.
B. RJ&A SHALL ESTABLISH: 1) A DEDICATED TOLL-FREE TELEPHONEASSISTANCE LINE TO PROVIDE INFORMATION AND TO RESPOND TOQUESTIONS CONCERNING THE TERMS OF THE ORDER; AND 2) A PUBLICINTERNET PAGE ON ITS CORPORATE WEB SITE(S), WITH A PROMINENTLINK TO THAT PAGE APPEARING ON RJ&A'S RELEVANT HOMEPAGE(S), TOPROVIDE INFORMATION CONCERNING THE TERMS OF THE ORDER AND,TO RESPOND TO QUESTIONS CONCERNING THE TERMS OF THE ORDER.
C. RJ&A'S OFFER TO PURCHASE ELIGIBLE ARS
1. OFFER NOTICES.
A. NO LATER THAN 30 DAYS AFTER THE DATE OF THE ORDER, RJ&A SHALLOFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ELIGIBLE CUSTOMERS("PURCHASE OFFER"), AND EXPLAIN WHAT THE ELIGIBLE CUSTOMERSMUST DO TO ACCEPT THE PURCHASE OFFER. [UNDERTAKINGCONTINUED IN COMMENTS]
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UNDERTAKING:
RJ&A HAS UNDERTAKEN TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLECUSTOMERS, AND OTHER MEASURES, AS SPECIFIED UNDER THE TERMSSET FORTH.
A. KEY DEFINITIONS
1. "ELIGIBLE ARS" SHALL MEAN AUCTION RATE SECURITIES THAT WEREPURCHASED AT RJ&A ON OR BEFORE FEBRUARY 13, 2008 AND THAT HAVEFAILED AT AUCTION AT LEAST ONCE SINCE THEN.
2. "ELIGIBLE CUSTOMERS" ARE THE CURRENT AND FORMER ACCOUNTOWNERS WHO PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008, DID NOT TRANSFER SUCH ELIGIBLE ARS AWAY FROMRJ&A PRIOR TO JANUARY 1, 2006, AND HELD THOSE SECURITIES ONFEBRUARY 13, 2008. "ELIGIBLE CUSTOMERS" SHALL NOT INCLUDE ARSCUSTOMERS WHO ACTED AS INSTITUTIONAL MONEY MANAGERS AND DIDNOT HOLD ARS IN RJ&A ACCOUNTS.
A. RJ&A WILL USE BEST EFFORTS TO PROVIDE THE INSTITUTIONALMONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARSINCLUDING, BUT NOT LIMITED TO, FACILITATING ISSUER REDEMPTIONS,RESTRUCTURINGS, AND THROUGH OTHER REASONABLE MEANS.
B. RJ&A WILL USE BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RESPONDENTS BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RESPONDENTS PRIORTO JANUARY 1, 2006.
B. RJ&A SHALL ESTABLISH: 1) A DEDICATED TOLL-FREE TELEPHONEASSISTANCE LINE TO PROVIDE INFORMATION AND TO RESPOND TOQUESTIONS CONCERNING THE TERMS OF THE ORDER; AND 2) A PUBLICINTERNET PAGE ON ITS CORPORATE WEB SITE(S), WITH A PROMINENTLINK TO THAT PAGE APPEARING ON RJ&A'S RELEVANT HOMEPAGE(S), TOPROVIDE INFORMATION CONCERNING THE TERMS OF THE ORDER AND,TO RESPOND TO QUESTIONS CONCERNING THE TERMS OF THE ORDER.
C. RJ&A'S OFFER TO PURCHASE ELIGIBLE ARS
1. OFFER NOTICES.
A. NO LATER THAN 30 DAYS AFTER THE DATE OF THE ORDER, RJ&A SHALLOFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ELIGIBLE CUSTOMERS("PURCHASE OFFER"), AND EXPLAIN WHAT THE ELIGIBLE CUSTOMERSMUST DO TO ACCEPT THE PURCHASE OFFER. [UNDERTAKINGCONTINUED IN COMMENTS]
Sanction Details: IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS,RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICHTHE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THEEXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT, MAKINGFINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").
THE COMMISSION FOUND THAT RJ&A WILLFULLY VIOLATED SECTION17(A)(2) OF THE SECURITIES ACT.
THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTERESTTO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT RJ&A'S OFFER.
PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OFTHE EXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT, THECOMMISSION ORDERED THAT:
A. RESPONDENT RAYMOND JAMES & ASSOCIATES, INC. CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT;
B. RESPONDENT RAYMOND JAMES & ASSOCIATES, INC. IS CENSURED;AND
C. THE COMMISSION IS NOT IMPOSING A PENALTY AGAINST RESPONDENTAT THIS TIME. HOWEVER, IN THE EVENT THE DIVISION OF ENFORCEMENT("DIVISION") BELIEVES THAT RJ&A HAS NOT COMPLIED WITH THEUNDERTAKINGS, THE DIVISION MAY, AT ANY TIME FOLLOWING THE ENTRYOF THE ORDER, PETITION THE COMMISSION TO: (1) REOPEN THIS MATTERTO CONSIDER THE APPROPRIATENESS OF A PENALTY; AND (2) SEEK ANORDER DIRECTING PAYMENT OF UP TO THE MAXIMUM CIVIL PENALTYALLOWABLE UNDER THE LAW.
Regulator Statement [UNDERTAKING CONTINUED]B. RJ&A SHALL PROVIDE ELIGIBLE CUSTOMERS THAT HAVE NOTRESPONDED TO THE PURCHASE OFFER ON OR BEFORE 45 DAYS BEFORETHE END OF THE APPLICABLE OFFER PERIOD A SECOND WRITTENNOTICE INFORMING THEM AGAIN OF THE RESPONDENTS' PURCHASEOFFER, THE RELEVANT TERMS OF THE ORDER AND ANY OTHER MATERIALISSUES REGARDING THE ELIGIBLE CUSTOMERS' RIGHTS.
2. FOR ELIGIBLE CUSTOMERS, THE PURCHASE OFFER SHALL REMAINOPEN FOR A PERIOD OF 75 DAYS FROM THE DATE ON WHICH RJ&A SENTTHE FIRST OFFER NOTICE ("OFFER PERIOD").
ACCEPTANCE AND PURCHASE PROCEDURES
1. ELIGIBLE CUSTOMERS MAY ACCEPT RJ&A'S PURCHASE OFFER BYNOTIFYING RJ&A IN WRITING.
2. RJ&A SHALL SEND THOSE ELIGIBLE CUSTOMERS A NOTICE ("PURCHASENOTICE"), INDICATING WHEN ("PURCHASE DATE") AND HOW RJ&A WILLPURCHASE THEIR ELIGIBLE ARS.
3. ELIGIBLE CUSTOMERS MAY REVOKE THEIR ACCEPTANCE OF RJ&A'SPURCHASE OFFER UP UNTIL RJ&A PURCHASES AN ELIGIBLE CUSTOMER'SELIGIBLE ARS.
4. RJ&A SHALL PURCHASE THE ELIGIBLE ARS NO LATER THAN 5 BUSINESSDAYS FOLLOWING EXPIRATION OF THE OFFER PERIOD.
5. RJ&A'S PURCHASE OBLIGATIONS APPLY EQUALLY TO THOSE ELIGIBLECUSTOMERS WHO ACCEPT THE PURCHASE OFFER WITHIN THE OFFERPERIOD, BUT WHO HAVE SINCE TRANSFERRED THEIR ELIGIBLE ARS AWAYFROM RJ&A.
A. RJ&A'S PURCHASE OBLIGATIONS TO THESE ELIGIBLE CUSTOMERSSHALL BE CONTINGENT ON: (1) RJ&A RECEIVING REASONABLYSATISFACTORY ASSURANCE FROM THE FINANCIAL SERVICES FIRMCURRENTLY HOLDING THE ELIGIBLE CUSTOMER'S ELIGIBLE ARS THATTHE BIDDING RIGHTS ASSOCIATED WITH THE ELIGIBLE ARS WILL BETRANSFERRED TO RJ&A; (2) THE ELIGIBLE CUSTOMER REACTIVATINGTHEIR FORMER ACCOUNT WITH RJ&A; AND (3) THE TRANSFER OF THEELIGIBLE ARS TO THE ELIGIBLE CUSTOMER'S FORMER ACCOUNT WITHRJ&A.
B. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY, CONTACT AND ASSISTSUCH ELIGIBLE CUSTOMERS TO REACTIVATE THEIR FORMER ACCOUNT ATRJ&A AND TO TRANSFER THE ELIGIBLE ARS TO SUCH ACCOUNT, ANDSHALL NOT CHARGE SUCH ELIGIBLE CUSTOMERS ANY FEES RELATING TOOR IN CONNECTION WITH THE TRANSFER TO RJ&A OR CUSTODIANSHIPBY RJ&A OF SUCH ELIGIBLE ARS.
E. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ELIGIBLE CUSTOMERSWHO TOOK OUT LOANS FROM RJ&A AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN. RJ&A SHALL REIMBURSE SUCH CUSTOMERSFOR THE EXCESS EXPENSE, PLUS REASONABLE INTEREST THEREON.
F. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ANY ELIGIBLECUSTOMERS WHO: (1) PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARSBELOW PAR BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THIS ORDER("BELOW PAR SELLERS"). RJ&A SHALL PAY THE BELOW PAR SELLERS THEDIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE BELOW PARSELLER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLEINTEREST THEREON.
G. CONSEQUENTIAL DAMAGES CLAIMS.
1. RJ&A SHALL CONSENT TO PARTICIPATE IN THE SPECIAL ARBITRATIONPROCEDURES ANNOUNCED BY FINRA ON DECEMBER 16, 2008, FOR THEEXCLUSIVE PURPOSE OF ARBITRATING AN ELIGIBLE CUSTOMER'S CLAIMFOR CONSEQUENTIAL DAMAGES AGAINST RJ&A RELATED TO THECUSTOMER'S INVESTMENT IN ELIGIBLE ARS.
I. REPORTS AND MEETINGS
1. BEGINNING WITH THE MONTH ENDED AFTER THE DATE OF THE ORDERAND CONTINUING THROUGH THE MONTH ENDED 9 MONTHS FROM THEDATE OF THE ORDER, RJ&A SHALL SUBMIT BI-MONTHLY WRITTENREPORTS AND A FINAL WRITTEN REPORT DETAILING ITS PROGRESS WITHRESPECT TO THE UNDERTAKINGS.
2. RJ&A SHALL CONFER AT LEAST QUARTERLY WITH THE COMMISSIONSTAFF TO DISCUSS THEIR PROGRESS WITH RESPECT TO THEUNDERTAKINGS FOR 9 MONTHS FROM THE DATE OF THE ORDER.
3. THE REPORTING AND CONFERENCE DEADLINES SET FORTH MAY BEAMENDED OR MODIFIED WITH AGREEMENT FROM THE COMMISSIONSTAFF.
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Regulator Statement [UNDERTAKING CONTINUED]B. RJ&A SHALL PROVIDE ELIGIBLE CUSTOMERS THAT HAVE NOTRESPONDED TO THE PURCHASE OFFER ON OR BEFORE 45 DAYS BEFORETHE END OF THE APPLICABLE OFFER PERIOD A SECOND WRITTENNOTICE INFORMING THEM AGAIN OF THE RESPONDENTS' PURCHASEOFFER, THE RELEVANT TERMS OF THE ORDER AND ANY OTHER MATERIALISSUES REGARDING THE ELIGIBLE CUSTOMERS' RIGHTS.
2. FOR ELIGIBLE CUSTOMERS, THE PURCHASE OFFER SHALL REMAINOPEN FOR A PERIOD OF 75 DAYS FROM THE DATE ON WHICH RJ&A SENTTHE FIRST OFFER NOTICE ("OFFER PERIOD").
ACCEPTANCE AND PURCHASE PROCEDURES
1. ELIGIBLE CUSTOMERS MAY ACCEPT RJ&A'S PURCHASE OFFER BYNOTIFYING RJ&A IN WRITING.
2. RJ&A SHALL SEND THOSE ELIGIBLE CUSTOMERS A NOTICE ("PURCHASENOTICE"), INDICATING WHEN ("PURCHASE DATE") AND HOW RJ&A WILLPURCHASE THEIR ELIGIBLE ARS.
3. ELIGIBLE CUSTOMERS MAY REVOKE THEIR ACCEPTANCE OF RJ&A'SPURCHASE OFFER UP UNTIL RJ&A PURCHASES AN ELIGIBLE CUSTOMER'SELIGIBLE ARS.
4. RJ&A SHALL PURCHASE THE ELIGIBLE ARS NO LATER THAN 5 BUSINESSDAYS FOLLOWING EXPIRATION OF THE OFFER PERIOD.
5. RJ&A'S PURCHASE OBLIGATIONS APPLY EQUALLY TO THOSE ELIGIBLECUSTOMERS WHO ACCEPT THE PURCHASE OFFER WITHIN THE OFFERPERIOD, BUT WHO HAVE SINCE TRANSFERRED THEIR ELIGIBLE ARS AWAYFROM RJ&A.
A. RJ&A'S PURCHASE OBLIGATIONS TO THESE ELIGIBLE CUSTOMERSSHALL BE CONTINGENT ON: (1) RJ&A RECEIVING REASONABLYSATISFACTORY ASSURANCE FROM THE FINANCIAL SERVICES FIRMCURRENTLY HOLDING THE ELIGIBLE CUSTOMER'S ELIGIBLE ARS THATTHE BIDDING RIGHTS ASSOCIATED WITH THE ELIGIBLE ARS WILL BETRANSFERRED TO RJ&A; (2) THE ELIGIBLE CUSTOMER REACTIVATINGTHEIR FORMER ACCOUNT WITH RJ&A; AND (3) THE TRANSFER OF THEELIGIBLE ARS TO THE ELIGIBLE CUSTOMER'S FORMER ACCOUNT WITHRJ&A.
B. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY, CONTACT AND ASSISTSUCH ELIGIBLE CUSTOMERS TO REACTIVATE THEIR FORMER ACCOUNT ATRJ&A AND TO TRANSFER THE ELIGIBLE ARS TO SUCH ACCOUNT, ANDSHALL NOT CHARGE SUCH ELIGIBLE CUSTOMERS ANY FEES RELATING TOOR IN CONNECTION WITH THE TRANSFER TO RJ&A OR CUSTODIANSHIPBY RJ&A OF SUCH ELIGIBLE ARS.
E. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ELIGIBLE CUSTOMERSWHO TOOK OUT LOANS FROM RJ&A AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN. RJ&A SHALL REIMBURSE SUCH CUSTOMERSFOR THE EXCESS EXPENSE, PLUS REASONABLE INTEREST THEREON.
F. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ANY ELIGIBLECUSTOMERS WHO: (1) PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARSBELOW PAR BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THIS ORDER("BELOW PAR SELLERS"). RJ&A SHALL PAY THE BELOW PAR SELLERS THEDIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE BELOW PARSELLER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLEINTEREST THEREON.
G. CONSEQUENTIAL DAMAGES CLAIMS.
1. RJ&A SHALL CONSENT TO PARTICIPATE IN THE SPECIAL ARBITRATIONPROCEDURES ANNOUNCED BY FINRA ON DECEMBER 16, 2008, FOR THEEXCLUSIVE PURPOSE OF ARBITRATING AN ELIGIBLE CUSTOMER'S CLAIMFOR CONSEQUENTIAL DAMAGES AGAINST RJ&A RELATED TO THECUSTOMER'S INVESTMENT IN ELIGIBLE ARS.
I. REPORTS AND MEETINGS
1. BEGINNING WITH THE MONTH ENDED AFTER THE DATE OF THE ORDERAND CONTINUING THROUGH THE MONTH ENDED 9 MONTHS FROM THEDATE OF THE ORDER, RJ&A SHALL SUBMIT BI-MONTHLY WRITTENREPORTS AND A FINAL WRITTEN REPORT DETAILING ITS PROGRESS WITHRESPECT TO THE UNDERTAKINGS.
2. RJ&A SHALL CONFER AT LEAST QUARTERLY WITH THE COMMISSIONSTAFF TO DISCUSS THEIR PROGRESS WITH RESPECT TO THEUNDERTAKINGS FOR 9 MONTHS FROM THE DATE OF THE ORDER.
3. THE REPORTING AND CONFERENCE DEADLINES SET FORTH MAY BEAMENDED OR MODIFIED WITH AGREEMENT FROM THE COMMISSIONSTAFF.
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[UNDERTAKING CONTINUED]B. RJ&A SHALL PROVIDE ELIGIBLE CUSTOMERS THAT HAVE NOTRESPONDED TO THE PURCHASE OFFER ON OR BEFORE 45 DAYS BEFORETHE END OF THE APPLICABLE OFFER PERIOD A SECOND WRITTENNOTICE INFORMING THEM AGAIN OF THE RESPONDENTS' PURCHASEOFFER, THE RELEVANT TERMS OF THE ORDER AND ANY OTHER MATERIALISSUES REGARDING THE ELIGIBLE CUSTOMERS' RIGHTS.
2. FOR ELIGIBLE CUSTOMERS, THE PURCHASE OFFER SHALL REMAINOPEN FOR A PERIOD OF 75 DAYS FROM THE DATE ON WHICH RJ&A SENTTHE FIRST OFFER NOTICE ("OFFER PERIOD").
ACCEPTANCE AND PURCHASE PROCEDURES
1. ELIGIBLE CUSTOMERS MAY ACCEPT RJ&A'S PURCHASE OFFER BYNOTIFYING RJ&A IN WRITING.
2. RJ&A SHALL SEND THOSE ELIGIBLE CUSTOMERS A NOTICE ("PURCHASENOTICE"), INDICATING WHEN ("PURCHASE DATE") AND HOW RJ&A WILLPURCHASE THEIR ELIGIBLE ARS.
3. ELIGIBLE CUSTOMERS MAY REVOKE THEIR ACCEPTANCE OF RJ&A'SPURCHASE OFFER UP UNTIL RJ&A PURCHASES AN ELIGIBLE CUSTOMER'SELIGIBLE ARS.
4. RJ&A SHALL PURCHASE THE ELIGIBLE ARS NO LATER THAN 5 BUSINESSDAYS FOLLOWING EXPIRATION OF THE OFFER PERIOD.
5. RJ&A'S PURCHASE OBLIGATIONS APPLY EQUALLY TO THOSE ELIGIBLECUSTOMERS WHO ACCEPT THE PURCHASE OFFER WITHIN THE OFFERPERIOD, BUT WHO HAVE SINCE TRANSFERRED THEIR ELIGIBLE ARS AWAYFROM RJ&A.
A. RJ&A'S PURCHASE OBLIGATIONS TO THESE ELIGIBLE CUSTOMERSSHALL BE CONTINGENT ON: (1) RJ&A RECEIVING REASONABLYSATISFACTORY ASSURANCE FROM THE FINANCIAL SERVICES FIRMCURRENTLY HOLDING THE ELIGIBLE CUSTOMER'S ELIGIBLE ARS THATTHE BIDDING RIGHTS ASSOCIATED WITH THE ELIGIBLE ARS WILL BETRANSFERRED TO RJ&A; (2) THE ELIGIBLE CUSTOMER REACTIVATINGTHEIR FORMER ACCOUNT WITH RJ&A; AND (3) THE TRANSFER OF THEELIGIBLE ARS TO THE ELIGIBLE CUSTOMER'S FORMER ACCOUNT WITHRJ&A.
B. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY, CONTACT AND ASSISTSUCH ELIGIBLE CUSTOMERS TO REACTIVATE THEIR FORMER ACCOUNT ATRJ&A AND TO TRANSFER THE ELIGIBLE ARS TO SUCH ACCOUNT, ANDSHALL NOT CHARGE SUCH ELIGIBLE CUSTOMERS ANY FEES RELATING TOOR IN CONNECTION WITH THE TRANSFER TO RJ&A OR CUSTODIANSHIPBY RJ&A OF SUCH ELIGIBLE ARS.
E. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ELIGIBLE CUSTOMERSWHO TOOK OUT LOANS FROM RJ&A AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN. RJ&A SHALL REIMBURSE SUCH CUSTOMERSFOR THE EXCESS EXPENSE, PLUS REASONABLE INTEREST THEREON.
F. RJ&A SHALL USE BEST EFFORTS TO IDENTIFY ANY ELIGIBLECUSTOMERS WHO: (1) PURCHASED ELIGIBLE ARS AT RJ&A ON OR BEFOREFEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARSBELOW PAR BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THIS ORDER("BELOW PAR SELLERS"). RJ&A SHALL PAY THE BELOW PAR SELLERS THEDIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE BELOW PARSELLER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLEINTEREST THEREON.
G. CONSEQUENTIAL DAMAGES CLAIMS.
1. RJ&A SHALL CONSENT TO PARTICIPATE IN THE SPECIAL ARBITRATIONPROCEDURES ANNOUNCED BY FINRA ON DECEMBER 16, 2008, FOR THEEXCLUSIVE PURPOSE OF ARBITRATING AN ELIGIBLE CUSTOMER'S CLAIMFOR CONSEQUENTIAL DAMAGES AGAINST RJ&A RELATED TO THECUSTOMER'S INVESTMENT IN ELIGIBLE ARS.
I. REPORTS AND MEETINGS
1. BEGINNING WITH THE MONTH ENDED AFTER THE DATE OF THE ORDERAND CONTINUING THROUGH THE MONTH ENDED 9 MONTHS FROM THEDATE OF THE ORDER, RJ&A SHALL SUBMIT BI-MONTHLY WRITTENREPORTS AND A FINAL WRITTEN REPORT DETAILING ITS PROGRESS WITHRESPECT TO THE UNDERTAKINGS.
2. RJ&A SHALL CONFER AT LEAST QUARTERLY WITH THE COMMISSIONSTAFF TO DISCUSS THEIR PROGRESS WITH RESPECT TO THEUNDERTAKINGS FOR 9 MONTHS FROM THE DATE OF THE ORDER.
3. THE REPORTING AND CONFERENCE DEADLINES SET FORTH MAY BEAMENDED OR MODIFIED WITH AGREEMENT FROM THE COMMISSIONSTAFF.
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iReporting Source: Firm
Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 06/29/2011
Docket/Case Number: 3-14445
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: THE SEC ALLEGED THAT RAYMOND JAMES VIOLATED SECTION 17(A) (2) OFTHE SECURITIES ACT WHEN RAYMOND JAMES OFFERED AND SOLD TOSOME OF ITS CUSTOMER'S AUCTION RATE SECURITIES ("ARS") WHILE NOTACCURATELY CHARACTERIZING OR WHILE FAILING TO ADEQUATELYDISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESEINVESTMENTS. ALTHOUGH RAYMOND JAMES' ARS TRADECONFIRMATIONS DISCLOSED THE RISK THAT ARS AUCTIONS COULD FAILAND THAT RAYMOND JAMES WAS NOT OBLIGED TO ENSURE THEIRSUCCESS, AT THE POINT-OF-SALE, SOME OF RAYMOND JAMES' FINANCIALADVISERS INACCURATELY DESCRIBED ARS AS ALTERNATIVES TO MONEYMARKET FUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUTADEQUATELY DISCLOSING THE AUCTION PROCESS OR THE RISK OFILLIQUIDITY IF THESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, ASIGNIFICANT NUMBER OF ARS AUCTIONS FAILED, RESULTING IN ANOVERALL MARKET COLLAPSE THAT LEFT THOUSANDS OF INVESTORS,INCLUDING SOME OF RAYMOND JAMES' CUSTOMERS, HOLDING ARS THATTHEY HAVE, IN SOME INSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
Resolution Date: 06/29/2011
Resolution:
Other Sanctions Ordered:
Sanction Details: CENSURE AND CEASE AND DESIST.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SEC ON JUNE 29, 2011,IN WHICH IT CONSENTED TO AN ORDER TO CEASE AND DESIST, ACENSURE, AND THE FOLLOWING UNDERTAKINGS:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Sanctions Ordered: CensureCease and Desist/Injunction
Order
189©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE SEC ON JUNE 29, 2011,IN WHICH IT CONSENTED TO AN ORDER TO CEASE AND DESIST, ACENSURE, AND THE FOLLOWING UNDERTAKINGS:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.(VI) TO PARTICIPATE, AT THE ELECTION OF AN ELIGIBLE CUSTOMER, INTHE SPECIAL ARBITRATION PROCEDURES ANNOUNCED BY FINRA ONDECEMBER 16, 2008, FOR THE EXCLUSIVE PURPOSE OF ARBITRATING ANELIGIBLE CUSTOMER'S CLAIM FOR CONSEQUENTIAL DAMAGES AGAINSTRAYMOND JAMES RELATED TO THE CUSTOMER'S INVESTMENT INELIGIBLE ARS.
Disclosure 71 of 120
i
Reporting Source: Regulator
Allegations: SEC RULE 10B-10, NASD RULES 2110, 2320, 6130, 6955(A) - RAYMONDJAMES AND ASSOCIATES, INC. TRANSMITTED REPORTABLE ORDEREVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WEREREJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND THE FIRMFAILED TO REPAIR SOME OF THE REJECTED ROES. THE FIRMINCORRECTLY REPORTED THE SECOND LEG OF "RISKLESS" PRINCIPALTRANSACTIONS AS "AGENT" TO THE NASD/NASDAQ TRADE REPORTINGFACILITY AND FAILED TO REPORT THE CONTRA MARKET PARTICIPANTIDENTIFIER (MPID) TO THE OTC REPORTING FACILITY FOR ONE LAST SALEREPORT OF A TRANSACTION IN AN OTC EQUITY SECURITY. THE FIRM,WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATIT WAS A MARKET MAKER IN EACH SUCH SECURITY AND FAILED ON ONEOCCASION TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION AND THE FACTTHAT THE FIRM'S REMUNERATION WAS A COMMISSION EQUIVALENT. THEFIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMERS ITS CORRECT CAPACITY FOR EACH EXECUTION AND THEFIRM'S CORRESPONDING REMUNERATION AS EITHER A COMMISSION ORCOMMISSION EQUIVALENT. THE FIRM FAILED TO EXECUTE ORDERS FULLYAND PROMPTLY AND FOR SOME OF THE TRANSACTIONS FOR OR WITH ACUSTOMER, IT FAILED TO USE REASONABLE DILIGENCE TO ASCERTAINTHE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCHMARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS ASFAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Current Status: Final
190©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/20/2010
Docket/Case Number: 2007008429301
Principal Product Type: Equity - OTC
Other Product Type(s):
SEC RULE 10B-10, NASD RULES 2110, 2320, 6130, 6955(A) - RAYMONDJAMES AND ASSOCIATES, INC. TRANSMITTED REPORTABLE ORDEREVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WEREREJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND THE FIRMFAILED TO REPAIR SOME OF THE REJECTED ROES. THE FIRMINCORRECTLY REPORTED THE SECOND LEG OF "RISKLESS" PRINCIPALTRANSACTIONS AS "AGENT" TO THE NASD/NASDAQ TRADE REPORTINGFACILITY AND FAILED TO REPORT THE CONTRA MARKET PARTICIPANTIDENTIFIER (MPID) TO THE OTC REPORTING FACILITY FOR ONE LAST SALEREPORT OF A TRANSACTION IN AN OTC EQUITY SECURITY. THE FIRM,WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATIT WAS A MARKET MAKER IN EACH SUCH SECURITY AND FAILED ON ONEOCCASION TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION AND THE FACTTHAT THE FIRM'S REMUNERATION WAS A COMMISSION EQUIVALENT. THEFIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMERS ITS CORRECT CAPACITY FOR EACH EXECUTION AND THEFIRM'S CORRESPONDING REMUNERATION AS EITHER A COMMISSION ORCOMMISSION EQUIVALENT. THE FIRM FAILED TO EXECUTE ORDERS FULLYAND PROMPTLY AND FOR SOME OF THE TRANSACTIONS FOR OR WITH ACUSTOMER, IT FAILED TO USE REASONABLE DILIGENCE TO ASCERTAINTHE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCHMARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS ASFAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Resolution Date: 01/20/2010
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $32,500 AND REQUIRED TOPAY $317.73, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRMSHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION,OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TOEFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTERACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION ANDINTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $32,500.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
191©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $32,500 AND REQUIRED TOPAY $317.73, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRMSHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION,OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TOEFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTERACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION ANDINTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED.
iReporting Source: Firm
Initiated By: FINRA
Date Initiated: 01/20/2010
Docket/Case Number: 2007008429301
Allegations: SEC RULE 10B-10, NASD RULES 2110, 2320, 6130, 6955(A) - RAYMONDJAMES AND ASSOCIATES, INC. TRANSMITTED REPORTABLE ORDEREVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WEREREJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND THE FIRMFAILED TO REPAIR SOME OF THE REJECTED ROES. THE FIRMINCORRECTLY REPORTED THE SECOND LEG OF "RISKLESS" PRINCIPALTRANSACTIONS AS "AGENT" TO THE NASD/NASDAQ TRADE REPORTINGFACILITY AND FAILED TO REPORT THE CONTRA MARKET PARTICIPANTIDENTIFIER (MPID) TO THE OTC REPORTING FACILITY FOR ONE LAST SALEREPORT OF A TRANSACTION IN AN OTC EQUITY SECURITY. THE FIRM,WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATIT WAS A MARKET MAKER IN EACH SUCH SECURITY AND FAILED ON ONEOCCASION TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION AND THE FACTTHAT THE FIRM'S REMUNERATION WAS A COMMISSION EQUIVALENT. THEFIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMERS ITS CORRECT CAPACITY FOR EACH EXECUTION AND THEFIRM'S CORRESPONDING REMUNERATION AS EITHER A COMMISSION ORCOMMISSION EQUIVALENT. THE FIRM FAILED TO EXECUTE ORDERS FULLYAND PROMPTLY AND FOR SOME OF THE TRANSACTIONS FOR OR WITH ACUSTOMER, IT FAILED TO USE REASONABLE DILIGENCE TO ASCERTAINTHE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCHMARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS ASFAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Current Status: Final
192©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Docket/Case Number: 2007008429301
Principal Product Type: Equity - OTC
Other Product Type(s):
Resolution Date: 01/20/2010
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $32,500 AND REQUIRED TOPAY $317.73, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRMSHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION,OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TOEFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTERACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION ANDINTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED.
Sanctions Ordered: CensureMonetary/Fine $32,500.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 72 of 120
i
Reporting Source: Regulator
Allegations: FINRA RULE 2010, NASD RULES 2110, 2510(D)(1), 3010 AND 3110:RESPONDENT RAYMOND JAMES & ASSOCIATES, INC. DID NOT CAUSE THEEXERCISE OF TIME AND PRICE DISCRETION TO BE REFLECTED ON ANORDER TICKET AS REQUIRED BY NASD RULE 2510(D)(1)'S ORDER TICKETDESIGNATION REQUIREMENT, CAUSING THE FIRM TO MAINTAININACCURATE BOOKS AND RECORDS. THE FIRM IMPLEMENTED A CHANGETO ITS ELECTRONIC ORDER MANAGEMENT SYSTEM (OMS), SATISFYINGTHE SPECIFICITY REQUIREMENTS OF NASD RULE 2510(D)(1), BUT DID NOTIMPLEMENT A SIMILAR CHANGE TO ANOTHER OF THE FIRM'S OMS USEDBY THE FIRM'S FINANCIAL ADVISORS FOR LARGER ORDERS. THE FIRMALSO FAILED TO EXERCISE REASONABLE SUPERVISION BY NOT HAVINGADEQUATE SYSTEMS OR PROCEDURES IN PLACE TO CAUSE THE FIRM TOBE IN COMPLIANCE WITH THE ORDER TICKET DESIGNATIONREQUIREMENT OF NASD RULE 2510(D)(1); BY NOT CONDUCTINGADEQUATE SUPERVISORY REVIEWS OF DATA RELATING TO THE EXERCISEOF TIME AND PRICE DISCRETION; AND BY NOT HAVING A SYSTEM ORPROCEDURE IN PLACE TO PRODUCE CERTAIN ORDER TICKET DATA INCONNECTION WITH REGULATORY REQUESTS FOR ORDER TICKETS.
Current Status: Final
193©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/11/2010
Docket/Case Number: 2008015756901
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s):
FINRA RULE 2010, NASD RULES 2110, 2510(D)(1), 3010 AND 3110:RESPONDENT RAYMOND JAMES & ASSOCIATES, INC. DID NOT CAUSE THEEXERCISE OF TIME AND PRICE DISCRETION TO BE REFLECTED ON ANORDER TICKET AS REQUIRED BY NASD RULE 2510(D)(1)'S ORDER TICKETDESIGNATION REQUIREMENT, CAUSING THE FIRM TO MAINTAININACCURATE BOOKS AND RECORDS. THE FIRM IMPLEMENTED A CHANGETO ITS ELECTRONIC ORDER MANAGEMENT SYSTEM (OMS), SATISFYINGTHE SPECIFICITY REQUIREMENTS OF NASD RULE 2510(D)(1), BUT DID NOTIMPLEMENT A SIMILAR CHANGE TO ANOTHER OF THE FIRM'S OMS USEDBY THE FIRM'S FINANCIAL ADVISORS FOR LARGER ORDERS. THE FIRMALSO FAILED TO EXERCISE REASONABLE SUPERVISION BY NOT HAVINGADEQUATE SYSTEMS OR PROCEDURES IN PLACE TO CAUSE THE FIRM TOBE IN COMPLIANCE WITH THE ORDER TICKET DESIGNATIONREQUIREMENT OF NASD RULE 2510(D)(1); BY NOT CONDUCTINGADEQUATE SUPERVISORY REVIEWS OF DATA RELATING TO THE EXERCISEOF TIME AND PRICE DISCRETION; AND BY NOT HAVING A SYSTEM ORPROCEDURE IN PLACE TO PRODUCE CERTAIN ORDER TICKET DATA INCONNECTION WITH REGULATORY REQUESTS FOR ORDER TICKETS.
Resolution Date: 01/11/2010
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $100,000 AND REQUIRED TOCOMMENCE A THOROUGH REVIEW THE FIRM'S PRACTICES ANDPROCEDURES CONCERNING ITS COMPLIANCE WITH NASD RULE2510(D)(1). THE REVIEW SHALL INCLUDE A DETERMINATION WHETHERANY ORDER ENTRY SYSTEM IN USE BY THE FIRM PERMITS A REGISTEREDREPRESENTATIVE OR OTHER ASSOCIATED PERSON TO EXERCISEDISCRETION AS TO THE PRICE AT WHICH OR THE TIME WHEN AN ORDERGIVEN BY A CUSTOMER FOR THE PURCHASE OR SALE OF A DEFINITEAMOUNT OF A SPECIFIED SECURITY SHALL BE EXECUTED. WITHRESPECT TO ANY SECURITY FOR WHICH ANY SUCH EXERCISE OFDISCRETION IS PERMITTED BY ANY ORDER ENTRY SYSTEM, ADETERMINATION WILL BE MADE BY THE FIRM WHETHER IT HAS SYSTEMSAND PROCEDURES IN PLACE THAT ARE REASONABLY DESIGNED TOCAUSE AN EXERCISE OF TIME AND PRICE DISCRETION IN THAT SECURITYTO BE REFLECTED ON THE ORDER TICKET. AS PART OF THE REVIEW, THEFIRM (AS NECESSARY) WILL DEVELOP WRITTEN POLICIES ANDPROCEDURES, AND CAUSE CHANGES TO BE MADE TO ITS (OR ITSAGENTS) OPERATIONAL SYSTEMS, THAT ARE REASONABLY DESIGNED TOCAUSE THE FIRM TO BE IN COMPLIANCE WITH THE PROVISIONS OF NASDRULE 2510(D)(1). THE FIRM SHALL ALSO PREPARE A REPORT OF THEREVIEW THAT SHALL DESCRIBE THE REVIEW, AND ANY APPLICABLECHANGES TO POLICIES, PROCEDURES OR SYSTEMS THAT ARECOMPLETED OR ANTICIPATED. THE REVIEW SHALL BE COMPLETED ANDTHE REPORT DELIVERED TO FINRA WITHIN 120 DAYS OF THE APPROVALDATE OF THIS AWC.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $100,000.00
Acceptance, Waiver & Consent(AWC)
194©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $100,000 AND REQUIRED TOCOMMENCE A THOROUGH REVIEW THE FIRM'S PRACTICES ANDPROCEDURES CONCERNING ITS COMPLIANCE WITH NASD RULE2510(D)(1). THE REVIEW SHALL INCLUDE A DETERMINATION WHETHERANY ORDER ENTRY SYSTEM IN USE BY THE FIRM PERMITS A REGISTEREDREPRESENTATIVE OR OTHER ASSOCIATED PERSON TO EXERCISEDISCRETION AS TO THE PRICE AT WHICH OR THE TIME WHEN AN ORDERGIVEN BY A CUSTOMER FOR THE PURCHASE OR SALE OF A DEFINITEAMOUNT OF A SPECIFIED SECURITY SHALL BE EXECUTED. WITHRESPECT TO ANY SECURITY FOR WHICH ANY SUCH EXERCISE OFDISCRETION IS PERMITTED BY ANY ORDER ENTRY SYSTEM, ADETERMINATION WILL BE MADE BY THE FIRM WHETHER IT HAS SYSTEMSAND PROCEDURES IN PLACE THAT ARE REASONABLY DESIGNED TOCAUSE AN EXERCISE OF TIME AND PRICE DISCRETION IN THAT SECURITYTO BE REFLECTED ON THE ORDER TICKET. AS PART OF THE REVIEW, THEFIRM (AS NECESSARY) WILL DEVELOP WRITTEN POLICIES ANDPROCEDURES, AND CAUSE CHANGES TO BE MADE TO ITS (OR ITSAGENTS) OPERATIONAL SYSTEMS, THAT ARE REASONABLY DESIGNED TOCAUSE THE FIRM TO BE IN COMPLIANCE WITH THE PROVISIONS OF NASDRULE 2510(D)(1). THE FIRM SHALL ALSO PREPARE A REPORT OF THEREVIEW THAT SHALL DESCRIBE THE REVIEW, AND ANY APPLICABLECHANGES TO POLICIES, PROCEDURES OR SYSTEMS THAT ARECOMPLETED OR ANTICIPATED. THE REVIEW SHALL BE COMPLETED ANDTHE REPORT DELIVERED TO FINRA WITHIN 120 DAYS OF THE APPROVALDATE OF THIS AWC.
iReporting Source: Firm
Initiated By: FINRA
Date Initiated: 01/11/2010
Docket/Case Number: 2008015756901
Allegations: FINRA RULE 2010, NASD RULES 2110, 2510(D)(1), 3010 AND 3110:RESPONDENT RAYMOND JAMES & ASSOCIATES, INC. DID NOT CAUSE THEEXERCISE OF TIME AND PRICE DISCRETION TO BE REFLECTED ON ANORDER TICKET AS REQUIRED BY NASD RULE 2510(D)(1)'S ORDER TICKETDESIGNATION REQUIREMENT, CAUSING THE FIRM TO MAINTAININACCURATE BOOKS AND RECORDS. THE FIRM IMPLEMENTED A CHANGETO ITS ELECTRONIC ORDER MANAGEMENT SYSTEM (OMS), SATISFYINGTHE SPECIFICITY REQUIREMENTS OF NASD RULE 2510(D)(1), BUT DID NOTIMPLEMENT A SIMILAR CHANGE TO ANOTHER OF THE FIRM'S OMS USEDBY THE FIRM'S FINANCIAL ADVISORS FOR LARGER ORDERS. THE FIRMALSO FAILED TO EXERCISE REASONABLE SUPERVISION BY NOT HAVINGADEQUATE SYSTEMS OR PROCEDURES IN PLACE TO CAUSE THE FIRM TOBE IN COMPLIANCE WITH THE ORDER TICKET DESIGNATIONREQUIREMENT OF NASD RULE 2510(D)(1); BY NOT CONDUCTINGADEQUATE SUPERVISORY REVIEWS OF DATA RELATING TO THE EXERCISEOF TIME AND PRICE DISCRETION; AND BY NOT HAVING A SYSTEM ORPROCEDURE IN PLACE TO PRODUCE CERTAIN ORDER TICKET DATA INCONNECTION WITH REGULATORY REQUESTS FOR ORDER TICKETS.
Current Status: Final
195©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s):
Resolution Date: 01/11/2010
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $100,000 AND REQUIRED TOCOMMENCE A THOROUGH REVIEW THE FIRM'S PRACTICES ANDPROCEDURES CONCERNING ITS COMPLIANCE WITH NASD RULE2510(D)(1). THE REVIEW SHALL INCLUDE A DETERMINATION WHETHER ANYORDER ENTRY SYSTEM IN USE BY THE FIRM PERMITS A REGISTEREDREPRESENTATIVE OR OTHER ASSOCIATED PERSON TO EXERCISEDISCRETION AS TO THE PRICE AT WHICH OR THE TIME WHEN AN ORDERGIVEN BY A CUSTOMER FOR THE PURCHASE OR SALE OF A DEFINITEAMOUNT OF A SPECIFIED SECURITY SHALL BE EXECUTED. WITH RESPECTTO ANY SECURITY FOR WHICH ANY SUCH EXERCISE OF DISCRETION ISPERMITTED BY ANY ORDER ENTRY SYSTEM, A DETERMINATION WILL BEMADE BY THE FIRM WHETHER IT HAS SYSTEMS AND PROCEDURES INPLACE THAT ARE REASONABLY DESIGNED TO CAUSE AN EXERCISE OFTIME AND PRICE DISCRETION IN THAT SECURITY TO BE REFLECTED ONTHE ORDER TICKET. AS PART OF THE REVIEW, THE FIRM (AS NECESSARY)WILL DEVELOP WRITTEN POLICIES AND PROCEDURES, AND CAUSECHANGES TO BE MADE TO ITS (OR ITS AGENTS) OPERATIONAL SYSTEMS,THAT ARE REASONABLY DESIGNED TO CAUSE THE FIRM TO BE INCOMPLIANCE WITH THE PROVISIONS OF NASD RULE 2510(D)(1). THE FIRMSHALL ALSO PREPARE A REPORT OF THE REVIEW THAT SHALL DESCRIBETHE REVIEW, AND ANY APPLICABLE CHANGES TO POLICIES,PROCEDURES OR SYSTEMS THAT ARE COMPLETED OR ANTICIPATED. THEREVIEW SHALL BE COMPLETED AND THE REPORT DELIVERED TO FINRAWITHIN 120 DAYS OF THE APPROVAL DATE OF THIS AWC.
Sanctions Ordered: CensureMonetary/Fine $100,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 73 of 120
i
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Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 02/13/2009
Docket/Case Number: 2006003705501
Principal Product Type: Debt - Corporate
Other Product Type(s): DEBT - MUNICIPAL
Allegations: NASD RULE 6230, MSRB RULE G-14: RAYMOND JAMES PROCESSEDCORPORATE AND MUNICIPAL BONDS TRANSACTIONS THAT IT RECEIVEDFROM THE REGISTERED INVESTMENT ADVISORS HANDLING CUSTOMERS'ACCOUNTS AT RAYMOND JAMES'S INTRODUCING/CORRESPONDENTFIRMS AND USED THE INTRODUCING/CORRESPONDENT FIRMS' MARKETPARTICIPATION IDENTIFIER (MPID), AS WELL AS ITS OWN MPID, WHENREPORTING CORPORATE BOND TRADES TO THE TRADE REPORTING ANDCOMPLIANCE ENGINE (TRACE) SYSTEM AND WHEN REPORTINGMUNICIPAL BOND TRANSACTIONS TO THE MUNICIPAL SECURITIESRULEMAKING BOARD (MSRB), WHEN ITS OWN MPID ALONE SHOULD HAVEBEEN USED..
Current Status: Final
Resolution Date: 02/13/2009
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS:THEREFORE, THE FIRM WAS CENSURED AND FINED $15,000.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $15,000.00
Acceptance, Waiver & Consent(AWC)
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iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 02/13/2009
Docket/Case Number: 2006003705501
Principal Product Type: Debt - Corporate
Other Product Type(s): DEBT - MUNICIPAL
Allegations: NASD RULE 6230, MSRB RULE G-14: RAYMOND JAMES PROCESSEDCORPORATE AND MUNICIPAL BONDS TRANSACTIONS THAT IT RECEIVEDFROM THE REGISTERED INVESTMENT ADVISORS HANDLING CUSTOMERS'ACCOUNTS AT RAYMOND JAMES'S INTRODUCING/CORRESPONDENTFIRMS AND USED THE INTRODUCING/CORRESPONDENT FIRMS' MARKETPARTICIPATION IDENTIFIER (MPID), AS WELL AS ITS OWN MPID, WHENREPORTING CORPORATE BOND TRADES TO THE TRADE REPORTING ANDCOMPLIANCE ENGINE (TRACE) SYSTEM AND WHEN REPORTINGMUNICIPAL BOND TRANSACTIONS TO THE MUNICIPAL SECURITIESRULEMAKING BOARD (MSRB), WHEN ITS OWN MPID ALONE SHOULD HAVEBEEN USED.
Current Status: Final
Resolution Date: 02/13/2009
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS:THEREFORE, THE FIRM WAS CENSURED AND FINED $15,000.
Sanctions Ordered: CensureMonetary/Fine $15,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 74 of 120
i
Reporting Source: Regulator
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/22/2008
Docket/Case Number: 2007009525901
Principal Product Type: Other
Other Product Type(s): STOCK LOAN
Allegations: AIDED AND ABETTED A VIOLATION OF SECTION 15(A)(1) OF THESECURITIES EXCHANGE ACT OF 1934; VIOLATED SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4THEREUNDER; NASD RULES 2110, 2420, 3010, 3110; NYSE RULE 345(A):RESPONDENT MEMBER FIRM PERMITTED A PERSON OR ENTITY NOTREGISTERED AS A BROKER-DEALER AND WHO HAD BEEN BARRED FROMTHE SECURITIES INDUSTRY TO PERFORM DUTIES THAT REQUIREREGISTRATION; IT PERMITTED A PERSON WHO WAS NOT REGISTEREDWITH, QUALIFIED BY OR ACCEPTABLE TO THE EXCHANGE TO PERFORMREGULARLY THE DUTIES CUSTOMARILY PERFORMED BY A SECURITIESLENDING REPRESENTATIVE; THE FIRM COMPENSATED ALLEGED FINDERSIN CONNECTION WITH STOCK LOAN TRANSACTIONS WHEN THOSEFINDERS HAD NOT PERFORMED ANY SERVICES IN CONNECTION WITHTRANSACTIONS; TRANSMITTED TRANSACTION-BASED COMPENSATION TOAN UNREGISTERED PERSON OR ENTITY OPERATING AS ANUNREGISTERED BROKER-DEALER; FAILED TO REASONABLY SUPERVISEOR CONTROL CERTAIN OF ITS BUSINESS ACTIVITIES; PROVIDE FORAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL; ANDESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TODETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WASBEING PROPERLY EXERCISED; AND FAILED TO MAKE AND KEEPACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES.
Resolution Date: 09/22/2008
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $1,000,000.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $1,000,000.
Sanctions Ordered: CensureMonetary/Fine $1,000,000.00
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/22/2008
Docket/Case Number: 2007009525901
Principal Product Type: Other
Other Product Type(s): STOCK LOAN
Allegations: AIDED AND ABETTED A VIOLATION OF SECTION 15(A)(1) OF THESECURITIES EXCHANGE ACT OF 1934; VIOLATED SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4THEREUNDER; NASD RULES 2110, 2420, 3010, 3110; NYSE RULE 345(A):RESPONDENT MEMBER FIRM PERMITTED A PERSON OR ENTITY NOTREGISTERED AS A BROKER/DEALER AND WHO HAD BEEN BARRED FROMTHE SECURITIES INDUSTRY TO PERFORM DUTIES THAT REQUIREREGISTRATION; IT PERMITTED A PERSON WHO WAS NOT REGISTEREDWITH, QUALIFIED BY OR ACCEPTABLE TO THE EXCHANGE TO PERFORMREGULARLY THE DUTIES CUSTOMARILY PERFORMED BY A SECURITIESLENDING REPRESENTATIVE; THE FIRM COMPENSATED ALLEGED FINDERSIN CONNECTION WITH STOCK LOAN TRANSACTIONS WHEN THOSEFINDERS HAD NOT PERFORMED ANY SERVICES IN CONNECTION WITHTRANSACTIONS; TRANSMITTED TRANSACTION-BASED COMPENSATION TOAN UNREGISTERED PERSON OR ENTITY OPERATING AS ANUNREGISTERED BROKER-DEALER; FAILED TO REASONABLY SUPERVISEOR CONTROL CERTAIN OF ITS BUSINESS ACTIVITIES; PROVIDE FORAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL; ANDESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TODETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WASBEING PROPERLY EXERCISED; AND FAILED TO MAKE AND KEEPACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES.
Current Status: Final
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Other Sanction(s)/ReliefSought:
Resolution Date: 09/22/2008
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS: THEREFORE, FIRM IS CENSURED AND FINED $1,000,000.
Sanctions Ordered: CensureMonetary/Fine $1,000,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 75 of 120
i
Reporting Source: Regulator
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/17/2008
Docket/Case Number: 20050024302-01
Principal Product Type: No Product
Other Product Type(s):
Allegations: SEC RULE 200(G) OF REGULATION SHO - RAYMOND JAMES & ASSOCIATES,INC. EXECUTED SHORT SALE ORDERS FOR WHICH THE FIRM FAILED TOPROPERLY MARK THE ORDER MEMORANDUM AS SHORT.
Current Status: Final
Resolution Date: 04/17/2008
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $5,000.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.
Sanctions Ordered: Monetary/Fine $5,000.00
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/17/2008
Docket/Case Number: 20050024302-01
Principal Product Type: No Product
Other Product Type(s):
Allegations: SEC RULE 200(G) OF REGULATION SHO - RAYMOND JAMES & ASSOCIATES,INC. EXECUTED SHORT SALE ORDERS FOR WHICH THE FIRM FAILED TOPROPERLY MARK THE ORDER MEMORANDUM AS SHORT.
Current Status: Final
Resolution Date: 04/17/2008
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.
Sanctions Ordered: Monetary/Fine $5,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 76 of 120
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Reporting Source: Firm
Allegations: ALLEGED FAILURE TO SUPERVISE CERTAIN OF ITS BRANCH MANAGERSAND EMPLOYEES LOCATED IN THE STATE OF INDIANA FOR THE YEARS OF2000 THROUGH JUNE 30, 2005.
Current Status: Final
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Initiated By: INDIANA SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
$60000 FINE & $27500 COSTS OF INVESTIGATION
Date Initiated: 01/02/2000
Docket/Case Number: CAUSE NO. 05-0082 CA
Principal Product Type: No Product
Other Product Type(s):
Allegations: ALLEGED FAILURE TO SUPERVISE CERTAIN OF ITS BRANCH MANAGERSAND EMPLOYEES LOCATED IN THE STATE OF INDIANA FOR THE YEARS OF2000 THROUGH JUNE 30, 2005.
Resolution Date: 08/23/2005
Resolution:
Other Sanctions Ordered: $27500.00 COSTS OF INVESTIGATION
Sanction Details: RAYMOND JAMES PAID A FINE OF $60,000, PLUS $27,500 COSTS OFINVESTIGATION. THE ENTIRE AMOUNT WAS LEVIED AGAINST RJA.
Firm Statement RJA AGREED TO A CONSENT AGREEMENT AND PAID ADMINISTRATIVE FINE.
Sanctions Ordered: Monetary/Fine $60,000.00
Consent
Disclosure 77 of 120
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Reporting Source: Regulator
Initiated By: NASD
Principal Sanction(s)/ReliefSought:
Date Initiated: 06/28/2005
Docket/Case Number: C07050037
Principal Product Type: No Product
Other Product Type(s):
Allegations: MSRB RULE G-14 AND G-27- RESPONDENT FIRM FAILED TO TIMELYREPORT ITS MUNICIPAL SECURITIES CUSTOMER TRANSACTIONS TO THEMSRB. THE FIRM FAILED TO MONITOR ITS TRADE REPORTING TO ENSURECOMPLIANCE WITH MSRB RULE G-14.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 06/28/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $90,000.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $90,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/04/2005
Docket/Case Number: C07050037
Principal Product Type: Debt - Municipal
Other Product Type(s):
Allegations: ALLEGES VIOLATIONS OF MSRB RULE G-14 AND MSRB RULE G-27 FORFAILURE TO TIMELY REPORT MUNICIPAL TRANSACTIONS WITHCUSTOMERS AT A RATE OF 6.83% TO THE MUNICIPAL SECURITIESRULEMAKING BOARD, AND FAILURE TO ADEQUATELY SELF-MONITOR ITSPERFORMANCE.
Current Status: Final
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Resolution Date: 06/28/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: SANCTIONS: CENSURE AND FINE OF $90,000.00.
Sanctions Ordered: CensureMonetary/Fine $90,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 78 of 120
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Reporting Source: Regulator
Initiated By: NASD
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/10/2005
Docket/Case Number: C05050023
Principal Product Type: Other
Other Product Type(s): MUNICIPAL SECURITIES
Allegations: MSRB RULES G-17 AND G-30(A); RESPONDENT MEMBER PURCHASED THESECURITIES FROM THE PUBLIC CUSTOMERS AND THEN SOLD THESECURITIES TO THE DEALER AT A NOMINAL GAIN. THE PRICES PAID TOTHE PUBLIC CUSTOMERS AND RECEIVED BY THE FIRM WERE BELOW THEFAIR MARKET VALUE OF EACH SECURITIES. RESPONDENT FAILED TOENSURE THAT THE TRANSACTIONS WERE EXECUTED AT AGGREGATEPRICES THAT WERE FAIR AND REASONABLE.
Current Status: Final
Resolution Date: 05/10/2005
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $5,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered: REQUIRED TO UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES WITH RESPECT TO APPLICABLE SECURITIES LAWS ANDREGULATIONS RELATING TO THE DETERMINATION OF THE FAIR MARKETVALUE OF MUNICIPAL SECURITIES BEING BOUGHT OR SOLD FROM APUBLIC CUSTOMER WITHIN 90 DAYS.
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $5,000, ANDORDERED TO PAY THE CUSTOMERS RESTITUTION OF $4,487 PLUSINTEREST.
Sanctions Ordered: CensureMonetary/Fine $5,000.00Disgorgement/Restitution
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/05/2004
Docket/Case Number: C05050023
Principal Product Type: Debt - Municipal
Other Product Type(s):
Allegations: THE NASD ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. FAILEDTO ENSURE THAT TWO MUNICIPAL SECURITY TRANSACTIONS FOR PUBLICCUSTOMERS WERE EXECUTED AT AGGREGRATE PRICES THAT WERE FAIRAND REASONABLE, IN VIOLATIONS OF MSRB RULES G-17 AND G-30(A).
Current Status: Final
Resolution Date: 05/10/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: SANCTIONS: FINE OF $5,000.00 - RESTITUTION: $4,487.00 PLUS INTEREST.
ADDITIONALLY, WITHIN 90 DAYS OF THE ACCEPTANCE OF THIS AWC, RJASHALL PROVIDE NASD WITH A COPY OF ITS UPDATED WRITTENSUPERVISORY PROCEDURES AS THEY RELATE TO THE DETERMINATIONOF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIES BEING BOUGHTOR SOLD FROM A PUBLIC CUSTOMER.
Sanctions Ordered: CensureMonetary/Fine $5,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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Sanction Details: SANCTIONS: FINE OF $5,000.00 - RESTITUTION: $4,487.00 PLUS INTEREST.
ADDITIONALLY, WITHIN 90 DAYS OF THE ACCEPTANCE OF THIS AWC, RJASHALL PROVIDE NASD WITH A COPY OF ITS UPDATED WRITTENSUPERVISORY PROCEDURES AS THEY RELATE TO THE DETERMINATIONOF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIES BEING BOUGHTOR SOLD FROM A PUBLIC CUSTOMER.
Disclosure 79 of 120
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Reporting Source: Regulator
Initiated By: NASD
Date Initiated: 11/23/2005
Docket/Case Number: 2004200013801
Principal Product Type: Other
Allegations: SEC RULE 10B-10, SEC RULE 11AC1-4, SEC RULE 11AC1-5(B), NASDMARKETPLACE RULES 4632, 6130(D), 5430, 4632(D)(3)(B), 6955(A) ANDNASD CONDUCT RULE 2110- RESPONDENT FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE. THE FINDINGSSTATED THAT THE FIRM MADE AVAILABLE A REPORT ON COVEREDORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVEDFOR EXECUTION FROM ANY CUSTOMER THAT INCLUDED INCORRECTINFORMATION AS TO SHARES BEING REPORTED AS HAVING BEENEXECUTED AWAY WHEN THE SHARES WERE IN FACT EXECUTED ATMARKET CENTER AND AS TO THE ACTUAL AVERAGE REALIZED SPREAD. INADDITION, NASD FOUND THAT THE FIRM FAILED TO REPORT TO NASDAQMARKET CENTER THE CORRECT SYMBOL INDICATING WHETHER THETRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT ORCROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES AND INCORRECTLYDESIGNATED A ".W" AND ".PRP" THROUGH AUTOMATED CONFIRMATIONTRANSACTION SERVICE (ACT) LAST SALE REPORTS OF TRANSACTIONS INNASDAQ NATIONAL MARKET SECURITIES (NNM). THE FINDINGS ALSOSTATED THAT THE FIRM INCORRECTLY REPORTED TO ACT THE SECONDLEG OF "RISKLESS" PRINCIPAL TRANSACTIONS IN NNM SECURITIES,INCORRECTLY DESIGNATED THE CAPACITY OF SUCH TRANSACTIONS ASPRINCIPAL, AND INCORRECTLY MEDIA-REPORTED SUCH TRANSACTIONS.NASD ALSO FOUND THAT THE FIRM TRANSMITTED TO ORDER AUDIT TRAILSYSTEM (OATS) REPORTS THAT CONTAINED A ROUTED ORDER IDNUMBER THAT FAILED TO MATCH TO A NASDAQ MARKET CENTER TRADEREPORT.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Resolution Date: 11/23/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $37,500.
Regulator Statement ALLEGATIONS CONTINUED: IN ADDITION, THE FINDINGS STATED THAT THEFIRM FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS INNASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCHORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OROFFER IN EACH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TOTHE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER OFEACH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORETHAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITHTHE FIRM'S BID OR OFFER IN EACH SUCH SECURITY. IN ADDITION, THEFINDINGS STATED THAT THE FIRM FAILED TO REPORT TO OATS THECORRECT ROUTE TIME ON OATS-REPORTABLE ORDERS AND THECORRECT TIMES OF CANCELLATION ON OATS-REPORTABLE ORDERS ASWELL AS FAILED TO TRANSMIT TO OATS EXECUTION REPORTS FOR OATS-REPORTABLE ORDERS AND A ROUTE FOR A ROUTED ORDER.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $37,500.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: AS A RESULT OF THE NASD'S 2003 AND 2004 TRADING AND MARKETMAKING EXAMINATIONS (TMMS EXAMS) AND AN ORDER HANDLING EXAMOF ORDERS EXECUTED DURING THE 1ST QUARTER 2004, THE NASDALLEGED VIOLATIONS OF VARIOUS RULES AND REGULATIONS RELATEDTO CUSTOMER ORDER DISPLAY, ORDER EXECUTION, CUSTOMERCONFIRMATIONS, TRADE REPORTING, AND ORDER AUDIT TRAIL SYSTEM(OATS) REQUIREMENTS. IN A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT APPROVED BY THE NASD ON NOVEMBER 23, 2005, RAYMONDJAMES & ASSOCIATES AGREED TO A CENSURE AND A FINE OF $37,500.
Current Status: Final
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/02/2005
Docket/Case Number: 20042000138-01
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED SECURITIES
Allegations: AS A RESULT OF THE NASD'S 2003 AND 2004 TRADING AND MARKETMAKING EXAMINATIONS (TMMS EXAMS) AND AN ORDER HANDLING EXAMOF ORDERS EXECUTED DURING THE 1ST QUARTER 2004, THE NASDALLEGED VIOLATIONS OF VARIOUS RULES AND REGULATIONS RELATEDTO CUSTOMER ORDER DISPLAY, ORDER EXECUTION, CUSTOMERCONFIRMATIONS, TRADE REPORTING, AND ORDER AUDIT TRAIL SYSTEM(OATS) REQUIREMENTS. IN A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT APPROVED BY THE NASD ON NOVEMBER 23, 2005, RAYMONDJAMES & ASSOCIATES AGREED TO A CENSURE AND A FINE OF $37,500.
Resolution Date: 11/23/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: SANCTIONS: CENSURE AND FINE OF $37,500.00
Sanctions Ordered: CensureMonetary/Fine $37,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 80 of 120
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Reporting Source: Regulator
Initiated By: NASD
Allegations: NASD CONDUCT RULE 2310 - RESPONDENT FIRM FAILED TO MAINTAIN ANDENFORCE ITS WRITTEN SUPERVISORY PROCEDURES TO SUPERVISE THEACTIVITES OF A REGISTERED REPRESENTATIVE. FURTHER, RESPONDENTFIRM DID NOT REQUIRE ITS BRANCH MANAGER TO SIGN THE 1035EXCHANGE FORMS FOR EITHER EXCHANGE INVOLVED. ALSO,RESPONDENT FIRM ALLOWED THE REGISTERED REPRESENTATIVE TORECEIVE HIS COMMISSION WITHOUT THE BRANCH MANAGER'SSIGNATURE FOR THE EXCHANGE.
Current Status: Final
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Initiated By: NASD
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/10/2005
Docket/Case Number: C05050020
Principal Product Type: Annuity(ies) - Variable
Other Product Type(s): UNSPECIFIED SECURITIES
Resolution Date: 05/10/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $10,000. INADDITION, RESPONDENT FIRM IS JOINTLY AND SEVERALLY LIABLE FORRESTITUTION IN THE AMOUNT OF $3,924 TO CERTAIN PUBLICCUSTOMERS. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTIONOR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TOEFFECT RESTITUTION SHALL BE PROVIDED TO NASD NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASONRESPONDENT CANNOT LOCATE ANY IDENTIFIED CUSTOMERS AFTERREASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, ORSUCH ADDITIONAL PERIOD AGREED TO BY NASD , RESPONDENT SHALLFORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERS ARE LASTKNOWN TO HAVE RESIDED.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
iReporting Source:
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Reporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SRECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/24/2005
Docket/Case Number: C05050020
Principal Product Type: No Product
Other Product Type(s):
Allegations: THE NASD ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC., FAILEDTO MAINTAIN AND ENFORCE ITS WRITTEN SUPERVISORY PROCEDURESTO SUPERVISE THE ACTIVITIES OF ANGELO MASUT, JR. IN VIOLATIONS OFNASD CONDUCT RULES 3010(B) AND 2110.
Current Status: Final
Resolution Date: 05/10/2005
Resolution:
Other Sanctions Ordered:
Sanction Details: SANCTIONS: FINE OF $10,000.00 - RESTITUTION: $3,924.00 PLUSINTEREST. RESTITUTION TO BE ALLOCATED BETWEEN RJA & ANGELOMASUT, JR.
Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 81 of 120
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Reporting Source: Regulator
Allegations: NASD CONDUCT RULE 3010, 2110, 2210(D) RAYMOND JAMES &ASSOCIATES, INC. CONTINUED TO UTILIZE EXISTING PROCEDURES FORREVIEW OF ACCOUNT OPENING DOCUMENTS AND ACCOUNTTRANSACTIONS, AND DID NOT ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, SPECIFICALLY DESIGNEDTO REVIEW AND MONITOR THEIR FEE-BASED BUSINESS. THE FIRM NEVERCONDUCTED AN INITIAL OR PERIODIC SUPERVISORY REVIEW OF THEIRCUSTOMERS' FEE-BASED BROKERAGE ACCOUNTS TO DETERMINEWHETHER SUCH ACCOUNTS WERE APPROPRIATE FOR PARTICULARCUSTOMERS. THE FIRM HAS NEVER MONITORED THEIR FEE-BASEDBROKERAGE ACCOUNTS FOR INACTIVITY. IN ADDITION THE FORM FAILEDTO PROVIDE THEIR BROKERS WITH ANY CRITERIA OR GUIDANCE TODETERMINE WHETHER A FEE-BASED BROKERAGE ACCOUNT WASAPPROPRIATE FOR A CUSTOMER AND DID NOT REQUIRE THEIR BROKERSTO DETERMINE WHETHER CERTAIN ACCOUNTS WERE APPROPRIATE FORA CUSTOMER BEFORE OPENING IT. RAYMOND JAMES DID NOT DIRECTTHEIR BROKERS TO CONSIDER WHETHER THE FEE-BASED BROKERAGEACCOUNT WAS APPROPRIATE FOR A PARTICULAR CUSTOMER IN LIGHT OFTHE SERVICES PROVIDED, THE PROJECTED COST TO THE CUSTOMER,ALTERNATIVE FEE STRUCTURES THAT WERE AVAILABLE, AND THECUSTOMER'S FEE STRUCTURE PREFERENCES. IN ADDITION, THE FIRMMARKETED ACCOUNTS THROUGH THE USE OF SALES LITERATURE THATFAILED TO COMPLY WITH NASD'S ADVERTISING RULES.
Current Status: Final
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Initiated By: NASD
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/26/2005
Docket/Case Number: CE3050007
Principal Product Type: Mutual Fund(s)
Other Product Type(s): STOCKS
NASD CONDUCT RULE 3010, 2110, 2210(D) RAYMOND JAMES &ASSOCIATES, INC. CONTINUED TO UTILIZE EXISTING PROCEDURES FORREVIEW OF ACCOUNT OPENING DOCUMENTS AND ACCOUNTTRANSACTIONS, AND DID NOT ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, SPECIFICALLY DESIGNEDTO REVIEW AND MONITOR THEIR FEE-BASED BUSINESS. THE FIRM NEVERCONDUCTED AN INITIAL OR PERIODIC SUPERVISORY REVIEW OF THEIRCUSTOMERS' FEE-BASED BROKERAGE ACCOUNTS TO DETERMINEWHETHER SUCH ACCOUNTS WERE APPROPRIATE FOR PARTICULARCUSTOMERS. THE FIRM HAS NEVER MONITORED THEIR FEE-BASEDBROKERAGE ACCOUNTS FOR INACTIVITY. IN ADDITION THE FORM FAILEDTO PROVIDE THEIR BROKERS WITH ANY CRITERIA OR GUIDANCE TODETERMINE WHETHER A FEE-BASED BROKERAGE ACCOUNT WASAPPROPRIATE FOR A CUSTOMER AND DID NOT REQUIRE THEIR BROKERSTO DETERMINE WHETHER CERTAIN ACCOUNTS WERE APPROPRIATE FORA CUSTOMER BEFORE OPENING IT. RAYMOND JAMES DID NOT DIRECTTHEIR BROKERS TO CONSIDER WHETHER THE FEE-BASED BROKERAGEACCOUNT WAS APPROPRIATE FOR A PARTICULAR CUSTOMER IN LIGHT OFTHE SERVICES PROVIDED, THE PROJECTED COST TO THE CUSTOMER,ALTERNATIVE FEE STRUCTURES THAT WERE AVAILABLE, AND THECUSTOMER'S FEE STRUCTURE PREFERENCES. IN ADDITION, THE FIRMMARKETED ACCOUNTS THROUGH THE USE OF SALES LITERATURE THATFAILED TO COMPLY WITH NASD'S ADVERTISING RULES.
Resolution Date: 04/26/2005
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE THE FIRM IS CENSURED, FINED $750,000 ANDORDERED TO PAY $138,000, PLUS INTEREST, IN RESTITUTION TO PUBLICCUSTOMERS. THE FIRM SHALL RETAIN AN INDEPENDENT CONSULTANT IFTHE FIRM WISHES TO CONTINUE WITH FEE-BASED BUSINESS AFTER JULY1, 2005.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $750,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE THE FIRM IS CENSURED, FINED $750,000 ANDORDERED TO PAY $138,000, PLUS INTEREST, IN RESTITUTION TO PUBLICCUSTOMERS. THE FIRM SHALL RETAIN AN INDEPENDENT CONSULTANT IFTHE FIRM WISHES TO CONTINUE WITH FEE-BASED BUSINESS AFTER JULY1, 2005.
Regulator Statement RESPONDENT FIRM HAS STATED THEIR INTENTION TO DISCONTINUE ALLOF THEIR FEE-BASED BROKERAGE BUSINESS BY JULY 1, 2005.
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 06/09/2003
Docket/Case Number: CE3050007
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: THE NASD ALLEGED THAT RJA VIOLATED NASD CONDUCT RULES 3010 AND2110 BY FAILING TO IMPLEMENT SUPERVISORY PROCEDURESSPECIFICALLY DESIGNED TO MONITOR FEE-BASED BROKERAGEACCOUNTS TO DETERMINE WHETHER THEY WERE "APPROPRIATE" FORCUSTOMERS. AS A RESULT, THE NASD ALLEGED THAT RJARECOMMENDED AND OPENED FEE-BASED BROKERAGE ACCOUNTSWITHOUT DETERMINING WHETHER THE ACCOUNTS WERE APPROPRIATE.THE NASD ALSO ALLEGED THAT RJA MARKETED FEE-BASED BROKERAGEACCOUNTS THROUGH THE USE OF SALES LITERATURE THAT FAILED TOCOMPLY WITH NASD'S ADVERTISING RULES WHICH VIOLATED NASDCONDUCT RULES 2210(D) AND 2110.
Current Status: Final
Resolution Date: 04/26/2005
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanctions Ordered: CensureMonetary/Fine $750,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered: UNDERTAKING
Sanction Details: SANCTIONS: $750,000 - RJA RESPONSIBLE FOR $224,100. RESTITUTION:$138,000 - RJA RESPONSIBLE FOR $27,025.42 + INTEREST OF $1,492.26
Disclosure 82 of 120
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Reporting Source: Regulator
Initiated By: HAWAII
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 09/16/2014
Docket/Case Number: SEU-2011-13
URL for Regulatory Action:
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: FAILURE TO SUPERVISE MARKETING OF ARS AS LIQUID.
Current Status: Final
Resolution Date: 09/16/2014
Resolution:
Other Sanctions Ordered:
Sanction Details: PART OF MULTISTATE SETTLEMENT, PAID IN FULL UPON EXECUTION OFCONSENT ORDER ON SEPT 16, 2014
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $3,972.17
Stipulation and Consent
iReporting Source: Firm
Allegations: STATE OF HAWAII ALLEGED THAT RAYMOND JAMES ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES INVIOLATION OF HRS 485-15(7). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF HRS 485-15(10).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Current Status: Final
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Initiated By: STATE OF HAWAII
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CEASE & DESIST
Date Initiated: 09/16/2014
Docket/Case Number: SEU-2011-13
Principal Product Type: Other
Other Product Type(s): AUCTION RATE SECURITIES
Allegations: STATE OF HAWAII ALLEGED THAT RAYMOND JAMES ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES INVIOLATION OF HRS 485-15(7). FURTHER, THE SECURITIES DIVISIONALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISETHEIR AGENTS IN VIOLATION OF HRS 485-15(10).RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERSAUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELYCHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THETRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS.ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSEDTHE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMESWAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE,SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELYDESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS ANDOTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSINGTHE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONSFAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARSAUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THATLEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMONDJAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOMEINSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Resolution Date: 09/16/2014
Resolution:
Other Sanctions Ordered:
Sanction Details: ON 9/16/2014, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF $3,972.17TO THE TREASURER OF STATE OF HAWAII.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF HAWAII ON9/16/2014, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.
Sanctions Ordered: Monetary/Fine $3,972.17
Stipulation and Consent
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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF HAWAII ON9/16/2014, IN WHICH IT CONSENTED:(I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS.(II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEYMANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS.(III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERSWHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHOTRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIORTO JANUARY 1, 2006.(IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLEINTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOKOUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECUREDBY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THETIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITHTHE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTALINTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THEDURATION OF THE LOAN.(V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHOPURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2)SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEENFEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANYSUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE ATWHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUSREASONABLE INTEREST.
Disclosure 83 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Date Initiated: 02/04/2002
Docket/Case Number: CMS020021
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: NASD RULE 4613(E) - WITHOUT ADMITTING OR DENYING THEALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THATTHE FIRM, A MARKET MAKER IN SECURITIES, WITHOUT MAKINGREASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BYEXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSEQUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED BID OR ASKQUOTATIONS IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKEDOR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 02/04/2002
Resolution:
Other Sanctions Ordered:
Sanction Details: N/A
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 02/04/2002
Docket/Case Number: CMS020021
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: NASD RULE 4613(E) - WITHOUT ADMITTING OR DENYING THEALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THATTHE FIRM, A MARKET MAKER IN SECURITIES, WITHOUT MAKINGREASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BYEXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSEQUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED BID OR ASKQUOTATIONS IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKEDOR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE.
Current Status: Final
Resolution Date: 02/04/2002
Resolution:
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, THE FIRMHERRBY ACCEPTS AND CONSENTS TO THE IMPOSITION OF A CENSUREAND A $10,000 FINE.
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Disclosure 84 of 120
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Reporting Source: Regulator
Initiated By: NYSE DIVISION OF ENFORCEMENT
Date Initiated: 10/29/2001
Docket/Case Number: HPD#01-207
Principal Product Type: Other
Other Product Type(s):
Allegations: **10/29/2001**STIPULATION OF FACTS AND CONSENT TO PENALTY FILEDBY NYSE DIVISION OF ENFORCEMENT AND PENDING CONSENTEDTO:FINDINGS THAT IT:VIOLATED EXCHANGE RULE 342 IN THAT RONEY, ITSPREDECESSOR FIRM, FAILED TO ESTABLISH AND MAINTAIN APPROPRIATEPROCEDURES FOR SUPERVISION AND CONTROL, INCLUDING A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW, TO ENSURE COMPLIANCE WITHEXCHANGE RULES AND FEDERAL SECURITIES LAWS, WITH RESPECTTO:OPERATING A BRANCH OFFICE ONLY AFTER OBTAINING EXCHANGEAPPROVAL;INSPECTING A BRANCH OFFICE AT LEAST ONCE EACHYEAR;MAKING AND PRESERVING ORDER TICKETS AND OTHER BOOKSAND RECORDS AS REQUIRED BY EXCHANGE RULE 440 AND SEASECTIONS 17 A-3 AND 17 A-4; ANDREVIEWING AND APPROVING COMMUNICATIONS WITH THE PUBLIC ASREQUIRED BY EXCHANGE RULE 472.VIOLATED EXCHANGE RULE 342(C) INTHAT RONEY, ITS PREDECESSOR FIRM, ESTABLISHED ONE OR MOREBRANCH OFFICES WITHOUT PRIOR EXCHANGE APPROVAL.VIOLATED EXCHANGE RULE 440 AND SEA SECTIONS 17A-3 AND 17A-4 INTHAT RONEY, ITS PREDECESSOR FIRM, FAILED TO MAINTAIN ANDPRESERVE CERTAIN REQUIRED BOOKS AND RECORDS.VIOLATEDEXCHANGE RULE 472 IN THAT RONEY, ITS PREDECESSOR FIRM, FAILED TOENSURE COMPLIANCE WITH REQUIREMENTS THAT:CORRESPONDENCE AND NEWSLETTERS BE APPROVED BY ASUPERVISORY ANALYST; AND COMMUNICATIONS WITH THE PUBLIC BERETAINED.THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE ANDA FINE OF $150,000.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Other Product Type(s):
Resolution Date: 12/20/2001
Resolution:
Other Sanctions Ordered:
Sanction Details: **11/20/01**DECISION 01- 207 ISSUED BY THE NYSE HEARING BOARDDECISION:VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH ANDMAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL.VIOLATED RULE 342(C) BY ESTABLISHING BRANCH OFFICES WITHOUTPRIOR EXCHANGE APPROVAL. VIOLATED RULE 440 AND SEA SECTIONS17A-3 AND A-4 BY FAILING TO MAINTAIN AND PRESERVE REQUIRED BOOKSAND RECORDS. VIOLATED RULE 472 BY FAILING TO HAVECORRESPONDENCE APPROVED BY A SUPERVISORY ANALYST AND BYFAILING TO RETAIN COMMUNICATIONS WITH THE PUBLIC. THE NYSEHEARING BOARD IMPOSED THE PENALTY CONSENTED TO BY RAYMONDJAMES OF A CENSURE AND A $150,000 FINE.
Regulator Statement **12/20/2001** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450
Sanctions Ordered: CensureMonetary/Fine $150,000.00
Decision
iReporting Source: Firm
Allegations: STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO: FINDINGSTHAT IT: VIOLATED EXCHANGE RULE 342 IN THAT RONEY, ITSPREDECESSOR FIRM, FAILED TO ESTABLISH AND MAINTAIN APPROPRIATEPROCEDURES FOR SUPERVISION AND CONTROL, INCLUDING A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW, TO ENSURE COMPLIANCE WITHEXCHANGE RULES AND FEDERAL SECURITIES LAWS, WITH RESPECT TO:OPERATING A BRANCH OFFICE ONLY AFTER OBTAINING EXCHANGEAPPROVAL; INSPECTING A BRANCH OFFICE AT LEAST ONCE EACH YEAR;MAKING AND PRESERVING ORDER TICKETS AND OTHER BOOKS ANDRECORDS AS REQUIRED BY EXCHANGE RULE 440 AND SEA SECTIONS 17A-3 AND 17 A-4; AND REVIEWING AND APPROVING COMMUNICATIONS WITHTHE PUBLIC AS REQUIRED BY EXCHANGE RULE 472. VIOLATED EXCHANGERULE 342(C) IN THAT RONEY, ITS PREDECESSOR FIRM, ESTABLISHED ONEOR MORE BRANCH OFFICES WITHOUT PRIOR EXCHANGE APPROVAL.VIOLATED EXCHANGE RULE 440 AND SEA SECTIONS 17A-3 AND 17A-4 INTHAT RONEY, ITS PREDECESSOR FIRM, FAILED TO MAINTAIN ANDPRESERVE CERTAIN BOOKS AND RECORDS. VIOLATED EXCHANGE RULE472 IN THAT RONEY, ITS PREDECESSOR FIRM FAILED TO ENSURECOMPLIANCE WITH REQUIREMENTS THAT: CORRESPONDENCE ANDNEWSLETTERS BE APPROVED BY A SUPERVISORY ANALYST; ANDCOMMUNICATIONS WITH THE PUBLIC BE RETAINED. THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $150,000.
Current Status: Final
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Initiated By: NYSE DIVISION OF ENFORCEMENT
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/29/2001
Docket/Case Number: HPD#01-207
Principal Product Type: Other
Other Product Type(s):
STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO: FINDINGSTHAT IT: VIOLATED EXCHANGE RULE 342 IN THAT RONEY, ITSPREDECESSOR FIRM, FAILED TO ESTABLISH AND MAINTAIN APPROPRIATEPROCEDURES FOR SUPERVISION AND CONTROL, INCLUDING A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW, TO ENSURE COMPLIANCE WITHEXCHANGE RULES AND FEDERAL SECURITIES LAWS, WITH RESPECT TO:OPERATING A BRANCH OFFICE ONLY AFTER OBTAINING EXCHANGEAPPROVAL; INSPECTING A BRANCH OFFICE AT LEAST ONCE EACH YEAR;MAKING AND PRESERVING ORDER TICKETS AND OTHER BOOKS ANDRECORDS AS REQUIRED BY EXCHANGE RULE 440 AND SEA SECTIONS 17A-3 AND 17 A-4; AND REVIEWING AND APPROVING COMMUNICATIONS WITHTHE PUBLIC AS REQUIRED BY EXCHANGE RULE 472. VIOLATED EXCHANGERULE 342(C) IN THAT RONEY, ITS PREDECESSOR FIRM, ESTABLISHED ONEOR MORE BRANCH OFFICES WITHOUT PRIOR EXCHANGE APPROVAL.VIOLATED EXCHANGE RULE 440 AND SEA SECTIONS 17A-3 AND 17A-4 INTHAT RONEY, ITS PREDECESSOR FIRM, FAILED TO MAINTAIN ANDPRESERVE CERTAIN BOOKS AND RECORDS. VIOLATED EXCHANGE RULE472 IN THAT RONEY, ITS PREDECESSOR FIRM FAILED TO ENSURECOMPLIANCE WITH REQUIREMENTS THAT: CORRESPONDENCE ANDNEWSLETTERS BE APPROVED BY A SUPERVISORY ANALYST; ANDCOMMUNICATIONS WITH THE PUBLIC BE RETAINED. THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $150,000.
Resolution Date: 12/20/2001
Resolution:
Other Sanctions Ordered:
Sanction Details: **11/20/01**DECISION 01-207 ISSUED BY THE NYSE HEARING BOARDDEVISION:VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH ANDMAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL.VIOLATED RULE 342(C) BY ESTABLISHING BRANCH OFFICES WITHOUTPRIOR EXCHANGE APPROVAL. VIOLATED RULE 440 AND SEA SECTIONS17A-3 AND A-4 BY FAILING TO MAINTAIN AND PRESERVE REQUIRED BOOKSAND RECORDS. VIOLATED RULE 472 BY FAILING TO HAVECORRESPONDENCE APPROVED BY A SUPERVISORY ANALYST AND BYFAILING TO RETAIN COMMUNICATIONS WITH THE PUBLIC. THE NYSEHEARING BOARD IMPOSED THE PENALTY CONSENTED TO BY RAYMONDJAMES OF A CENSURE AND A $150,000.00 FINE.
Firm Statement **12/20/2001** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450
Sanctions Ordered: CensureMonetary/Fine $150,000.00
Decision
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Disclosure 85 of 120
i
Reporting Source: Regulator
Initiated By: NYSE DIVISION OF ENFORCEMENT
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/21/2001
Docket/Case Number: HPD# 01-118
Principal Product Type: Other
Other Product Type(s):
Allegations: **5/21/2001**EVENT: STIPULATION OF FACTS AND CONSENT TO PENALTYFILED WITH THE HEARING BOARD.CHARGES: AS SET FORTH IN THE STIPULATION OF FACTS AND CONSENTTO PENALTY, DURING THE PERIOD FROM 1987 THROUGH 2000, RAYMONDJAMES & ASSOCIATES, INC. (THE "FIRM") MAINTAINED TWELVE OFFICES INFIVE COUNTRIES IN EUROPE WHERE APPROXIMATELY EIGHTY PERSONSWERE PERFORMING SERVICES AS BRANCH OFFICE MANAGERS ("BOMS")AND REGISTERED REPRESENTATIVES ("RRS") UNDER THE FIRM'S NAME.THE FIRM VIOLATED EXCHANGE RULES 342(A), 342(C) AND 342.12 BYFAILING TO OWN OR CONTROL AND APPROPRIATELY REGISTER SUCHOFFICES WITH THE EXCHANGE; AND VIOLATED EXCHANGE RULES 342(D),345 AND 345(A)/02 BY FAILING TO APPROPRIATELY REGISTER SUCHPERSONNEL WITH THE EXCHANGE AND BY FAILING TO EMPLOY THE BOMSAND RRS IN EUROPE OR MEET THE REQUIREMENTS FOR SUCH RRS TOHAVE THE STATUS OF INDEPENDENT CONTRACTORS. THE FIRM HASCONSENTED TO A CENSURE, A FINE OF $250,000, AND AN UNDERTAKING.
Current Status: Final
Resolution Date: 08/10/2001
Resolution:
Other Sanctions Ordered: CONSENT TO CENSURE, FINE OF $250,000 AND AN UNDERTAKING TOCOMPLY TO COMPLY WITH SPECIFIC EXCHANGE REQUIREMENTS ANDSUBMIT A WRITTEN RESPONSE.
Sanction Details: **6/28/2001**EVENT: DECISION (HPD 01-118) ISSUED BY NYSE HEARINGPANEL.DECISION: AS SET FORTH IN THE HEARING PANEL DECISION,WHICH WAS BASED ON A STIPULATION OF FACTS AND CONSENT TOPENALTY, RAYMOND JAMES & ASSOCIATES, INC. (THE "FIRM"), VIOLATEDEXCHANGE RULES 342(A), 342(C) AND 342.12 BY FAILING TO PROVIDE FORAND ESTABLISH OWNERSHIP OR CONTROL OVER OFFICES IN EUROPEAND APPROPRIATELY REGISTER THEM; VIOLATED EXCHANGE RULES342(D) AND 345 BY FAILING TO EMPLOY QUALIFIED PERSONS ACCEPTABLETO THE EXCHANGE WHO WERE IN CHARGE OF THE FIRM'S OFFICES INEUROPE; AND VIOLATED EXCHANGE RULE 345 AND 345(A)/02 (PUBLISHEDRULE INTERPRETATION) BY PERMITTING PERSONS TO PERFORM ASREGISTERED REPRESENTATIVES WITHOUT EITHER EMPLOYING THEM ORCONTRACTING SUCH PERSONS AS INDEPENDENT CONTRACTORS. THEFIRM WAS CENSURED, FINED $250,000 AND UNDERTOOK TO COMPLY WITHSPECIFIC EXCHANGE REQUIREMENTS AND TO SUBMIT A WRITTENRESPONSE.
Sanctions Ordered: CensureMonetary/Fine $250,000.00
Decision
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Sanction Details: **6/28/2001**EVENT: DECISION (HPD 01-118) ISSUED BY NYSE HEARINGPANEL.DECISION: AS SET FORTH IN THE HEARING PANEL DECISION,WHICH WAS BASED ON A STIPULATION OF FACTS AND CONSENT TOPENALTY, RAYMOND JAMES & ASSOCIATES, INC. (THE "FIRM"), VIOLATEDEXCHANGE RULES 342(A), 342(C) AND 342.12 BY FAILING TO PROVIDE FORAND ESTABLISH OWNERSHIP OR CONTROL OVER OFFICES IN EUROPEAND APPROPRIATELY REGISTER THEM; VIOLATED EXCHANGE RULES342(D) AND 345 BY FAILING TO EMPLOY QUALIFIED PERSONS ACCEPTABLETO THE EXCHANGE WHO WERE IN CHARGE OF THE FIRM'S OFFICES INEUROPE; AND VIOLATED EXCHANGE RULE 345 AND 345(A)/02 (PUBLISHEDRULE INTERPRETATION) BY PERMITTING PERSONS TO PERFORM ASREGISTERED REPRESENTATIVES WITHOUT EITHER EMPLOYING THEM ORCONTRACTING SUCH PERSONS AS INDEPENDENT CONTRACTORS. THEFIRM WAS CENSURED, FINED $250,000 AND UNDERTOOK TO COMPLY WITHSPECIFIC EXCHANGE REQUIREMENTS AND TO SUBMIT A WRITTENRESPONSE.
Regulator Statement **8/10/2001**THE DECISION IS NOW FINAL AND EFFECTIVEIMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450
iReporting Source: Firm
Initiated By: NYSE DIVISION OF ENFORCEMENT
Date Initiated: 05/21/2001
Docket/Case Number: HPD# 01-118
Principal Product Type: Other
Allegations: **05/21/2001**EVENT: STIPULATION OF FACTS AND CONSENT TO PENALTYFILED WITH THE HEARING BOARD. CHARGES: AS SET FORTH IN THESTIPULATION OF FACTS AND CONSENT TO PENALTY, DURING THE PERIODFROM 1987 THROUGH 2000, RAYMOND JAMES & ASSOCIATES, INC. (THE "FIRM") MAINTAINED TWELVE OFFICES IN FIVE COUNTRIES IN EUROPEWHERE APPROXIMATELY EIGHTY PERSONS WERE PERFORMINGSERVICES AS BRANCH OFFICE MANAGERS ("BOMS") AND REGISTEREDREPRESENTATIVES ("RRS") UNDER THE FIRM'S NAME. THE FIRMVIOLATED EXCHANGE RULES 342(A), 342(C) AND 342.12 BY FAILING TOOWN OR CONTROL AND APPROPRIATELY REGISTER SUCH OFFICES WITHTHE EXCHANGE; AND VIOLATED EXCHANGE RULES 342(D), 345 AND345(A)/02 BY FAILING TO APPROPRIATELY REGISTER SUCH PERSONNELWITH THE EXCHANGE AND BY FAILING TO EMPLOY THE BOMS AND RRS INEUROPE OR MEET THE REQUIREMENTS FOR SUCH RRS TO HAVE THESTATUS OF INDEPENDENT CONTRACTORS. THE FIRM HAS CONSENTEDTO A CENSURE, A FINE OF $250,000, AND AN UNDERTAKING.
Current Status: Final
222©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type: Other
Other Product Type(s):
Resolution Date: 08/10/2001
Resolution:
Other Sanctions Ordered: CONSENT TO CENSURE, FINE OF $250,000 AND AN UNDERTAKING TOCOMPLY WITH SPECIFIC EXCHANGE REQUIREMENTS AND SUBMIT AWRITTEN RESPONSE.
Sanction Details: **6/28/2001**EVENT: DECISION (HPD 01-118) ISSUED BY NYSE HEARINGPANEL.DECISION: AS SET FORTH IN THE HEARING PANEL DECISION,WHICH WAS BASED ON A STIPULATION OF FACTS AND CONSENT TOPENALTY, RAYMOND JAMES & ASSOCIATES, INC. (THE "FIRM"), VIOLATEDEXCHANGE RULES 342(A), 342(C) AND 342.12 BY FAILING TO PROVIDE FORAND EXTABLISH OWNERSHIP OR CONTROL OVER OFFICES IN EUROPEAND APPROPRIATELY REGISTER THEM; VIOLATED EXCHANGE RULES342(D) AND 345 BY FAILING TO EMPLOY QUALIFIED PERSONS ACCEPTABLETO THE EXCHANGE WHO WERE IN CHARGE OF THE FIRM'S OFFICES INEUROPE; AND VIOLATED EXCHANGE RULE 345 AND 345(A)/02 (PUBLISHEDRULE INTERPRETATION) BY PERMITTING PERSONS TO PERFORM ASREGISTERED REPRESENTATIVES WITHOUT EITHER EMPLOYING THEM ORCONTRACTING SUCH PERSONS AS INDEPENDENT CONTRACTORS. THEFIRM WAS CENSURED, FINED $250,000 AND UNDERTOOK TO COMPLY WITHSPECIFIC EXCHANGE REQUIREMENTS AND TO SUBMIT A WRITTENRESPONSE.
Firm Statement **8/10/2001**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450
Sanctions Ordered: CensureMonetary/Fine $250,000.00
Decision
Disclosure 86 of 120
i
Reporting Source: Regulator
Allegations: NASD RULES 2110, 2320 AND SEC RULE 11AC1-4 - FAILED TO USEREASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS AND BY FAILING TO EXECUTECUSTOMER MARKET ORDERS FULLY AND PROMPTLY; AND, FAILED TOIMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTE,WHEN EACH SUCH ORDER WAS AT A PRICE BETTER THAN ITS PUBLICQUOTE, OR AT A PRICE EQUAL TO ITS PUBLIC QUOTE WHEN SUCH QUOTEWAS PRICED EQUAL TO THE NATIONAL BEST BID OR OFFER IN SUCHSECURITY AND THAT ORDER REPRESENTED MORE THAN A DE MINIMSCHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFERIN EACH SUCH SECURITY.
Current Status: Final
223©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/15/2001
Docket/Case Number: CMS010028
Principal Product Type: Equity - OTC
Other Product Type(s):
NASD RULES 2110, 2320 AND SEC RULE 11AC1-4 - FAILED TO USEREASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS AND BY FAILING TO EXECUTECUSTOMER MARKET ORDERS FULLY AND PROMPTLY; AND, FAILED TOIMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTE,WHEN EACH SUCH ORDER WAS AT A PRICE BETTER THAN ITS PUBLICQUOTE, OR AT A PRICE EQUAL TO ITS PUBLIC QUOTE WHEN SUCH QUOTEWAS PRICED EQUAL TO THE NATIONAL BEST BID OR OFFER IN SUCHSECURITY AND THAT ORDER REPRESENTED MORE THAN A DE MINIMSCHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFERIN EACH SUCH SECURITY.
Resolution Date: 03/15/2001
Resolution:
Other Sanctions Ordered:
Sanction Details: PAY $1,137.50, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERSAND PROVIDE PROOF OF PAYMENT OF THE RESTITUTION NO LATER THAN120 DAYS AFTER ACCEPTANCE OF THIS AWC.
Sanctions Ordered: CensureMonetary/Fine $25,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: 03/29/01GS: NASD RULES 2110, 2320 AND SEC RULE 11AC1-4 - FAILED TOUSE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS AND BY FAILING TO EXECUTECUSTOMER MARKET ORDERS FULLY AND PROMPTLY; AND FAILED TOIMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTE,WHEN EACH SUCH ORDER WAS AT A PRICE BETTER THAN ITS PUBLICQUOTE, OR AT A PRICE EQUAL TO ITS PUBLIC QUOTE WHEN SUCH QUOTEWAS PRICED EQUAL TO THE NATIONAL BEST BID OR OFFER IN SUCHSECURITY AND THAT ORDER REPRESENTED MORE THAN A DE MINIMUSCHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFERIN EACH SUCH SECURITY.
Current Status: Final
224©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Disgorgement
Other Sanction(s)/ReliefSought:
Date Initiated: 03/15/2001
Docket/Case Number: CMS010028
Principal Product Type: Equity - OTC
Other Product Type(s):
03/29/01GS: NASD RULES 2110, 2320 AND SEC RULE 11AC1-4 - FAILED TOUSE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS AND BY FAILING TO EXECUTECUSTOMER MARKET ORDERS FULLY AND PROMPTLY; AND FAILED TOIMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTE,WHEN EACH SUCH ORDER WAS AT A PRICE BETTER THAN ITS PUBLICQUOTE, OR AT A PRICE EQUAL TO ITS PUBLIC QUOTE WHEN SUCH QUOTEWAS PRICED EQUAL TO THE NATIONAL BEST BID OR OFFER IN SUCHSECURITY AND THAT ORDER REPRESENTED MORE THAN A DE MINIMUSCHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFERIN EACH SUCH SECURITY.
Resolution Date: 03/15/2001
Resolution:
Other Sanctions Ordered:
Sanction Details: PAY $1,137.50, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERSAND PROVIDE PROOF OF PAYMENT OF THE RESTITUTION NO LATER THAN120 DAYS AFTER ACCEPTANCE OF THIS AWC. FINE PAID 04/10/2001.
Sanctions Ordered: CensureMonetary/Fine $25,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 87 of 120
i
Reporting Source: Regulator
Allegations: 04-10-00, SEC RULES 17(A)(2),(3), NASD RULE 2110 - RESPONDENTMEMBER EFFECTED DEFEASANCE ESCROW TRANSACTIONS WITHMUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENTWHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THEPARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING THE PERTINENTTAX REGULATIONS. THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THEPRICES IT CHARGED WERE NOT REASONABLY RELATED TO THEPREVAILING WHOLESALE MARKET PRICES OF THE SECURITIES. THEEXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX-EXEMPT STATUS OFTHOSE MUNICIPALITIES REFUNDING BONDS AND DIVERTED MONEY FROMTHE U.S. TREASURY TO THE FIRM WHEN THE TRANSACTION WAS INPOSITIVE ARBITRAGE OR REDUCED THE SAVINGS AVAILABLE TO THEMUNICIPALITIES FROM THE REFUNDINGS WHEN THE TRANSACTION WASIN NEGATIVE ARBITRAGE.
Current Status: Final
225©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/05/2000
Docket/Case Number: C05000018
Principal Product Type: Other
Other Product Type(s):
04-10-00, SEC RULES 17(A)(2),(3), NASD RULE 2110 - RESPONDENTMEMBER EFFECTED DEFEASANCE ESCROW TRANSACTIONS WITHMUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENTWHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THEPARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING THE PERTINENTTAX REGULATIONS. THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THEPRICES IT CHARGED WERE NOT REASONABLY RELATED TO THEPREVAILING WHOLESALE MARKET PRICES OF THE SECURITIES. THEEXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX-EXEMPT STATUS OFTHOSE MUNICIPALITIES REFUNDING BONDS AND DIVERTED MONEY FROMTHE U.S. TREASURY TO THE FIRM WHEN THE TRANSACTION WAS INPOSITIVE ARBITRAGE OR REDUCED THE SAVINGS AVAILABLE TO THEMUNICIPALITIES FROM THE REFUNDINGS WHEN THE TRANSACTION WASIN NEGATIVE ARBITRAGE.
Resolution Date: 04/05/2000
Resolution:
Other Sanctions Ordered: WITHIN 10 BUSINESS DAYS, MAKE PAYMENTS TOTALING $847,140.99RELATED TO SALES OF DEFEASANCE ESCROW SECURITIES TO CERTAINMUNICIPAL ISSUERS IN CONNECTION WITH ADVANCE REFUNDINGS INNEGATIVE ARBITRAGE. PAY $2,757,176.53 TO THE U.S. TREASURY UNDERAN AGREEMENT SIMULTANEOUSLY ENTERED INTO AMONG THE FIRM, THEIRS, AND THE U.S. ATTORNEY FOR THE SOUTHERN DISTRICT OF NEWYORK. AT THE TIME PAYMENTS ARE MADE TO THE MUNICIPALITIES ANDTHE U.S. TREASURY, COPIES OF THE PAYMENTS AND ANY COVERLETTERS SHALL BE SENT TO DISTRICT NO. 5.
Sanction Details: 11-01-00, $197,500 PAID 4/17/00
Sanctions Ordered: Censure
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: AS PART OF A GLOBAL SETTLEMENT BY SEVENTEEN BROKER-DEALERS,THE NASD INSTITUTED AND SETTLED DISCIPLINARY PROCEEDINGSAGAINST SEVEN BROKER-DEALERS, INCLUDING RAYMOND JAMES &ASSOCIATES, INC., ALLEGING UNLAWFUL, UNDISCLOSED OVERCHARGESIN CONNECTION WITH THE PRICING OF ESCROW SECURITIES SOLD TOCERTAIN MUNICIPAL BOND ISSUERS FOR USE IN ADVANCE REFUNDINGTRANSACTIONS.
Current Status: Final
226©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Disgorgement
Other Sanction(s)/ReliefSought:
CENSURE
Date Initiated: 04/06/2000
Docket/Case Number: C05000018
Principal Product Type: Debt - Government
Other Product Type(s):
AS PART OF A GLOBAL SETTLEMENT BY SEVENTEEN BROKER-DEALERS,THE NASD INSTITUTED AND SETTLED DISCIPLINARY PROCEEDINGSAGAINST SEVEN BROKER-DEALERS, INCLUDING RAYMOND JAMES &ASSOCIATES, INC., ALLEGING UNLAWFUL, UNDISCLOSED OVERCHARGESIN CONNECTION WITH THE PRICING OF ESCROW SECURITIES SOLD TOCERTAIN MUNICIPAL BOND ISSUERS FOR USE IN ADVANCE REFUNDINGTRANSACTIONS.
Resolution Date: 04/05/2000
Resolution:
Other Sanctions Ordered:
Sanction Details: RAYMOND JAMES & ASSOCIATES, INC. AGREED TO PAY DISGORGEMENTTO CERTAIN ISSUERS IN THE AMOUNT OF $847,140.99, AND TO THE U.S.TREASURY IN THE AMOUNT $2,757,176.53 FOR A TOTAL AMOUNT OF$3,604,317.52.
Firm Statement RAYMOND JAMES & ASSOCIATES, INC. SIMULTANEOUSLY SETTLED ANACTION THAT HAD BEEN BROUGHT UNDER THE FALSE CLAIMS ACT. THISACTION IS ALSO RELATED TO THE MARK-UPS CHARGED ON ESCROWSECURITIES SOLD TO CERTAIN MUNICIPAL BOND ISSUERS.
Sanctions Ordered: CensureDisgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
Disclosure 88 of 120
i
Reporting Source: Regulator
Allegations: NASD RULES 2110 AND 2320 AND SEC RULE 11AC1-4 - RESPONDENTMEMBER FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THEBEST INTER-DEALER MARKET BY FAILING TO EXECUTE FIVE CUSTOMERORDERS IN A TIMELY MANNER; AND, FAILED TO DISPLAY IMMEDIATELYCUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AT ITS PUBLICQUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULDHAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY RELATEDTO THOSE ORDERS.
Current Status: Final
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Initiated By: THE NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/31/2000
Docket/Case Number: CMS000008
Principal Product Type: Other
Other Product Type(s):
NASD RULES 2110 AND 2320 AND SEC RULE 11AC1-4 - RESPONDENTMEMBER FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THEBEST INTER-DEALER MARKET BY FAILING TO EXECUTE FIVE CUSTOMERORDERS IN A TIMELY MANNER; AND, FAILED TO DISPLAY IMMEDIATELYCUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AT ITS PUBLICQUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULDHAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY RELATEDTO THOSE ORDERS.
Resolution Date: 01/31/2000
Resolution:
Other Sanctions Ordered:
Sanction Details: CENSURED AND FINED $7500.00
Sanctions Ordered: CensureMonetary/Fine $7,500.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: THE NATIONAL ASSOCIATION OF SECURITIES DEALERS
Principal Sanction(s)/ReliefSought:
Censure
Date Initiated: 01/31/2000
Docket/Case Number: CMS000008
Principal Product Type: Other
Other Product Type(s):
Allegations: 02/15/00GS: NASD RULES 2110 AND 2320 AND SEC RULE 11AC1-4 -RESPONDENT MEMBER FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET BY FAILING TO EXECUTEFIVE CUSTOMER ORDERS IN A TIMELY MANNER; AND FAILED TO DISPLAYIMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AT ITSPUBLIC QUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITYRELATED TO THOSE ORDERS.
Current Status: Final
228©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Resolution Date: 01/31/2000
Resolution:
Other Sanctions Ordered:
Sanction Details: NONE
Sanctions Ordered: CensureMonetary/Fine $7,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 89 of 120
i
Reporting Source: Regulator
Allegations: *11/17/1999*EVENT:STIPULATION AND CONSENT TO PENALTY FILED BYNYSE DIVISION OF ENFORCEMENT AND PENDINGA.WITHOUT ADMITTING OR DENYING GUILT, RAYMOND JAMES CONSENTSTO: 1.FINDINGS BY THE HEARING PANEL THAT IT VIOLATED:A.EXCHANGERULE 342(A) AND (B) BY FAILING TO:I REASONABLY SUPERVISE ANDCONTROL ITS BUSINESS ACTIVITIES;II)PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL;III)ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO DETERMINE THAT DELEGATED AUTHORITY ANDRESPONSIBILITY WAS BEING EXERCISED;B IV)REASONABLY SUPERVISEAND CONTROL THE ACTIVITIES OF ITS EMPLOYEES WITH RESPECT TOCOMPLIANCE WITH APPLICABLE EXCHANGE RULES AND SECURITIESEXCHANGE ACT REGULATIONS CONCERNING ORDERRECORDS AND ALLOCATION OF SHARES TO CUSTOMERACCOUNTS;B.EXCHANGE RULE 342(C) BY FAILING TO OBTAIN THE PRIORCONSENT OF THE EXCHANGE BEFORE CHANGING THE LOCATION OF ABRANCH OFFICE;C.EXCHANGE RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES REASONABLY DESIGNED TO IDENTIFY TRADES INEMPLOYEE AND FAMILY-RELATED ACCOUNTS THAT MAY VIOLATE RULESPROHIBITING INSIDER TRADING AND MANIPULATIVE ANDDECEPTIVE DEVICES;D.EXCHANGE RULE 345(A) BY PERMITTING CERTAINEMPLOYEES TO PERFORM REGULARLY THE DUTIESCUSTOMARILYPERFORMED BY SUPERVISORS WITHOUT SUCH PERSONSHAVING BEEN REGISTERED WITH, QUALIFIED BY, AND ACCEPTABLETO THE EXCHANGE;E. EXCHANGE RULE 345.17(B) BY FAILING TO TIMELYFILE WITH THE EXCHANGE CERTAIN AMENDMENTS TO ONE OR MOREFORMS U-5; F.EXCHANGE RULE 351(A) AND (D) BY FAILING TO PROMPTLYREPORT TO THE EXCHANGE CERTAIN MATTERS AS REQUIRED BY THERULE, G.EXCHANGE RULE 410 BY FAILING TO: (I)MAKE AND PRESERVEREQUIRED RECORDS RELATING TO CUSTOMER ORDERS EXECUTED ONTHE FLOOR OF THE EXCHANGE; AND(II) FAILING TO OBTAIN APPROPRIATEWRITTEN SUPERVISORY APPROVAL FOR ACCOUNT DESIGNATIONCHANGES PRIOR TO EFFECTING SUCH CHANGES;H.REGULATIONS 240.17A-3 AND 240.17A-4, PROMULGATED PURSUANT TO SECTION 17 OF THESECURITIES EXCHANGE ACT AND EXCHANGE RULE 440*CONTINUED 13*
Current Status: Final
229©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Initiated By: NYSE OF ENFORCEMENT.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 11/07/1999
Docket/Case Number: HPD#00-11
Principal Product Type: Other
Other Product Type(s):
*11/17/1999*EVENT:STIPULATION AND CONSENT TO PENALTY FILED BYNYSE DIVISION OF ENFORCEMENT AND PENDINGA.WITHOUT ADMITTING OR DENYING GUILT, RAYMOND JAMES CONSENTSTO: 1.FINDINGS BY THE HEARING PANEL THAT IT VIOLATED:A.EXCHANGERULE 342(A) AND (B) BY FAILING TO:I REASONABLY SUPERVISE ANDCONTROL ITS BUSINESS ACTIVITIES;II)PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL;III)ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO DETERMINE THAT DELEGATED AUTHORITY ANDRESPONSIBILITY WAS BEING EXERCISED;B IV)REASONABLY SUPERVISEAND CONTROL THE ACTIVITIES OF ITS EMPLOYEES WITH RESPECT TOCOMPLIANCE WITH APPLICABLE EXCHANGE RULES AND SECURITIESEXCHANGE ACT REGULATIONS CONCERNING ORDERRECORDS AND ALLOCATION OF SHARES TO CUSTOMERACCOUNTS;B.EXCHANGE RULE 342(C) BY FAILING TO OBTAIN THE PRIORCONSENT OF THE EXCHANGE BEFORE CHANGING THE LOCATION OF ABRANCH OFFICE;C.EXCHANGE RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES REASONABLY DESIGNED TO IDENTIFY TRADES INEMPLOYEE AND FAMILY-RELATED ACCOUNTS THAT MAY VIOLATE RULESPROHIBITING INSIDER TRADING AND MANIPULATIVE ANDDECEPTIVE DEVICES;D.EXCHANGE RULE 345(A) BY PERMITTING CERTAINEMPLOYEES TO PERFORM REGULARLY THE DUTIESCUSTOMARILYPERFORMED BY SUPERVISORS WITHOUT SUCH PERSONSHAVING BEEN REGISTERED WITH, QUALIFIED BY, AND ACCEPTABLETO THE EXCHANGE;E. EXCHANGE RULE 345.17(B) BY FAILING TO TIMELYFILE WITH THE EXCHANGE CERTAIN AMENDMENTS TO ONE OR MOREFORMS U-5; F.EXCHANGE RULE 351(A) AND (D) BY FAILING TO PROMPTLYREPORT TO THE EXCHANGE CERTAIN MATTERS AS REQUIRED BY THERULE, G.EXCHANGE RULE 410 BY FAILING TO: (I)MAKE AND PRESERVEREQUIRED RECORDS RELATING TO CUSTOMER ORDERS EXECUTED ONTHE FLOOR OF THE EXCHANGE; AND(II) FAILING TO OBTAIN APPROPRIATEWRITTEN SUPERVISORY APPROVAL FOR ACCOUNT DESIGNATIONCHANGES PRIOR TO EFFECTING SUCH CHANGES;H.REGULATIONS 240.17A-3 AND 240.17A-4, PROMULGATED PURSUANT TO SECTION 17 OF THESECURITIES EXCHANGE ACT AND EXCHANGE RULE 440*CONTINUED 13*
Resolution Date: 03/07/2000
Resolution:
Other Sanctions Ordered:
Sanction Details: *2/4/2000*DECISION: VIOLATED RULE 342(A) AND (B) BY FAILING TOREASONABLY SUPERVISE ITS BUSINESS ACTIVITIES; VIOLATED RULE342(C) BY FAILING TO OBTAIN PRIOR EXCHANGE CONSENT TO CHANGE ABRANCH LOCATION; VIOLATED RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES DESIGNED TO IDENTIFY TRADES IN EMPLOYEE ACCOUNTS;VIOLATED RULE 345 BY PERMITTING EMPLOYEES TO PERFORMSUPERVISORY DUTIES WITHOUT APPROPRIATE REGISTRATION ANDQUALIFICATION; VIOLATED RULE 345.17(B) BY FAILING TO TIMELY FILE U-5AMENDMENTS; VIOLATED RULE 351(A) AND (D) BY FAILING TO PROMPTLYREPORT REQUIRED MATTERS; VIOLATED RULE 410 BY FAILING TO MAKEAND PRESERVE REQUIRED RECORDS; VIOLATED SEC REGS. 240.17A-3AND A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND PRESERVEREQUIRED RECORDS; VIOLATED RULE 343(A) BY FAILING TO OBTAINPERMISSION FOR A BRANCH TO SHARE SPACE WITH AN INVESTMENTADVISOR; VIOLATED RULE 343(D) BY FAILING TO DISPLAY THEEXCHANGE'S MEMBERSHIP CERTIFICATE; VIOLATED RULE 472.30 BYPERMITTING A BRANCH TO ISSUE COMMUNICATIONS TO THE PUBLICCONTAINING INACCURATE INFORMATION; VIOLATED EXCHANGE RULE408(B) BY FAILING TO PROVIDE FOR APPROPRIATE REVIEW OFDISCRETIONARY ACCOUNTS; VIOLATED RULE 346(B) BY FAILING TOOBTAIN WRITTEN REQUESTS AND CONSENTS FOR REGISTEREDREPRESENTATIVE'S OUTSIDE BUSINESS ACTIVITY; AND VIOLATED RULE346(E) BY FAILING TO OBTAIN EXCHANGE PERMISSION FOR AREGISTERED REPRESENTATIVE TO DEVOTE LESS THAN HIS ENTIRE TIMETO FIRM BUSINESS BY ENGAGING IN FIRM PARENT'S BUSINESS -CONSENT TO CENSURE AND $165,000 FINE.
Sanctions Ordered: CensureMonetary/Fine $165,000.00
Decision
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*2/4/2000*DECISION: VIOLATED RULE 342(A) AND (B) BY FAILING TOREASONABLY SUPERVISE ITS BUSINESS ACTIVITIES; VIOLATED RULE342(C) BY FAILING TO OBTAIN PRIOR EXCHANGE CONSENT TO CHANGE ABRANCH LOCATION; VIOLATED RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES DESIGNED TO IDENTIFY TRADES IN EMPLOYEE ACCOUNTS;VIOLATED RULE 345 BY PERMITTING EMPLOYEES TO PERFORMSUPERVISORY DUTIES WITHOUT APPROPRIATE REGISTRATION ANDQUALIFICATION; VIOLATED RULE 345.17(B) BY FAILING TO TIMELY FILE U-5AMENDMENTS; VIOLATED RULE 351(A) AND (D) BY FAILING TO PROMPTLYREPORT REQUIRED MATTERS; VIOLATED RULE 410 BY FAILING TO MAKEAND PRESERVE REQUIRED RECORDS; VIOLATED SEC REGS. 240.17A-3AND A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND PRESERVEREQUIRED RECORDS; VIOLATED RULE 343(A) BY FAILING TO OBTAINPERMISSION FOR A BRANCH TO SHARE SPACE WITH AN INVESTMENTADVISOR; VIOLATED RULE 343(D) BY FAILING TO DISPLAY THEEXCHANGE'S MEMBERSHIP CERTIFICATE; VIOLATED RULE 472.30 BYPERMITTING A BRANCH TO ISSUE COMMUNICATIONS TO THE PUBLICCONTAINING INACCURATE INFORMATION; VIOLATED EXCHANGE RULE408(B) BY FAILING TO PROVIDE FOR APPROPRIATE REVIEW OFDISCRETIONARY ACCOUNTS; VIOLATED RULE 346(B) BY FAILING TOOBTAIN WRITTEN REQUESTS AND CONSENTS FOR REGISTEREDREPRESENTATIVE'S OUTSIDE BUSINESS ACTIVITY; AND VIOLATED RULE346(E) BY FAILING TO OBTAIN EXCHANGE PERMISSION FOR AREGISTERED REPRESENTATIVE TO DEVOTE LESS THAN HIS ENTIRE TIMETO FIRM BUSINESS BY ENGAGING IN FIRM PARENT'S BUSINESS -CONSENT TO CENSURE AND $165,000 FINE.
Regulator Statement *3/7/2000*THE DECISION IS NOW FINAL AND EFFECTIVEIMMEDIATELY.CONTACT PEGGY GERMINO 212 656-8450.
iReporting Source: Firm
Allegations: *11/17/1999*EVENT:STIPULATION AND CONSENT TO PENALTY FILED BYNYSE DIVISION OF ENFORCEMENT AND PENDING. WITHOUT ADMITTINGOR DENYING GUILT, RAYMOND JAMES CONSENTS TO FINDINGS BY THEHEARING PANEL THAT IT VIOLATED EXCHANGE RULE 342(A)AND (B)BYFAILING TO:I RESONABLY SUPERVISE AND CONTROL ITS BUSINESSACTIVITIES; II)PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL;III)ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO DETERMINE THAT DELEGATED AUTHORITYAND RESPONSIBILITY WAS BEING EXERCISED;B IV)REASONABLYSUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES WITHRESPECT TO COMPLIANCE WITH APPLICABLE EXCHANGE RULES ANDSECURITIES EXCHANGE ACT REGULATIONS CONCERNING ORDERRECORDS AND ALLOCATION OF SHARES TO CUSTOMERACCOUNTS;B.EXCHANGE RULE 342(C)BY FAILING TO OBTAIN THE PRIORCONSENT OF THE EXCHANGE BEFORE CHANGING THE LOCATION OF ABRANCH OFFICE;C.EXCHANGE RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES REASONABLY DESIGNED TO IDENTIFY TRADES INEMPLOYEE AND FAMILY-RELATED ACCOUNTS THAT MAY VIOLATE RULESPROHIBITING INSIDER TRADING AND MANIPULATIVE AND DECEPTIVEDEVICES;D.EXCHANGE RULE 345(A)BY PERMITTING CERTAIN EMPLOYEESTO PERFORM REGULARLY THE DUTIES CUSTOMARILY PERFORMED BYSUPERVISORS WITHOUT SUCH PERSONS HAVING BEEN REGISTEREDWITH, QUALIFIED BY, AND ACCEPTABLE TO THE EXCHANGE;E.EXCHANGERULE 345.17(B)BY FAILING TO TIMELY FILE WITH THE EXCHANGE CERTAINAMENDMENTS TO ONE OR MORE FORMS U-5;F.EXCHANGE RULE351(A)AND (D)BY FAILING TO PROMPTLY REPORT TO THE EXCHANGECERTAIN MATTERS AS REQUIRED BY THE RULE, G.EXCHANGE RULE 410BY FAILING TO:(I)MAKE AND PRESERVE REQUIRED RECORDS RELATINGTO CUSTOMER ORDERS EXECUTED ON THE FLOOR OF THE EXCHANGE;AND(II)FAILING TO OBTAIN APPROPRIATE WRITTEN SUPERVISORYAPPROVAL FOR ACCOUNT DESIGNATION CHANGES PRIOR TO EFFECTINGSUCH CHANGES;H.REGULATIONS 240.17A-3 AND 240.17A4, PROMULGATEDPURSUANT TO SECTION 17 OF THE SECURITIES EXCHANGE ACT ANDEXCHANGE RULE 440*CONTINUED 13*
Current Status: Final
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Initiated By: NYSE DIVISION OF ENFORCEMENT
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 11/07/1999
Docket/Case Number: HPD#00-11
Principal Product Type: Other
Other Product Type(s):
*11/17/1999*EVENT:STIPULATION AND CONSENT TO PENALTY FILED BYNYSE DIVISION OF ENFORCEMENT AND PENDING. WITHOUT ADMITTINGOR DENYING GUILT, RAYMOND JAMES CONSENTS TO FINDINGS BY THEHEARING PANEL THAT IT VIOLATED EXCHANGE RULE 342(A)AND (B)BYFAILING TO:I RESONABLY SUPERVISE AND CONTROL ITS BUSINESSACTIVITIES; II)PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL;III)ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO DETERMINE THAT DELEGATED AUTHORITYAND RESPONSIBILITY WAS BEING EXERCISED;B IV)REASONABLYSUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES WITHRESPECT TO COMPLIANCE WITH APPLICABLE EXCHANGE RULES ANDSECURITIES EXCHANGE ACT REGULATIONS CONCERNING ORDERRECORDS AND ALLOCATION OF SHARES TO CUSTOMERACCOUNTS;B.EXCHANGE RULE 342(C)BY FAILING TO OBTAIN THE PRIORCONSENT OF THE EXCHANGE BEFORE CHANGING THE LOCATION OF ABRANCH OFFICE;C.EXCHANGE RULE 342.21 BY FAILING TO IMPLEMENTPROCEDURES REASONABLY DESIGNED TO IDENTIFY TRADES INEMPLOYEE AND FAMILY-RELATED ACCOUNTS THAT MAY VIOLATE RULESPROHIBITING INSIDER TRADING AND MANIPULATIVE AND DECEPTIVEDEVICES;D.EXCHANGE RULE 345(A)BY PERMITTING CERTAIN EMPLOYEESTO PERFORM REGULARLY THE DUTIES CUSTOMARILY PERFORMED BYSUPERVISORS WITHOUT SUCH PERSONS HAVING BEEN REGISTEREDWITH, QUALIFIED BY, AND ACCEPTABLE TO THE EXCHANGE;E.EXCHANGERULE 345.17(B)BY FAILING TO TIMELY FILE WITH THE EXCHANGE CERTAINAMENDMENTS TO ONE OR MORE FORMS U-5;F.EXCHANGE RULE351(A)AND (D)BY FAILING TO PROMPTLY REPORT TO THE EXCHANGECERTAIN MATTERS AS REQUIRED BY THE RULE, G.EXCHANGE RULE 410BY FAILING TO:(I)MAKE AND PRESERVE REQUIRED RECORDS RELATINGTO CUSTOMER ORDERS EXECUTED ON THE FLOOR OF THE EXCHANGE;AND(II)FAILING TO OBTAIN APPROPRIATE WRITTEN SUPERVISORYAPPROVAL FOR ACCOUNT DESIGNATION CHANGES PRIOR TO EFFECTINGSUCH CHANGES;H.REGULATIONS 240.17A-3 AND 240.17A4, PROMULGATEDPURSUANT TO SECTION 17 OF THE SECURITIES EXCHANGE ACT ANDEXCHANGE RULE 440*CONTINUED 13*
Resolution Date: 02/01/2000
Resolution:
Other Sanctions Ordered:
Sanction Details: THE HEARING PANEL, IN ACCEPTING THE STIPULATION OF FACTS ANDCONSENT TO PENALTY, FOUND THE FIRM GUILTY AS SET FORTH ABOVEBY UNANIMOUS VOTE. IN VIEW OF THE ABOVE FINDINGS, THE HEARINGPANEL, BY UNANIMOUS VOTE, IMPOSED THE PENALTY CONSENTED TO BYTHE FIRM OF A CENSURE AND A FINE OF $165,000.00.
Firm Statement *CONTINUED FROM #7*BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMERORDERS;I.EXCHANGE RULE 343(A)BY FAILING TO OBTAIN THEPERMISSION OF THE EXCHANGE FOR A BRANCH OFFICE TO SHAREOFFICE SPACE WITH AN INVESTMENT ADVISOR AFFILIATED WITH THEFIRM'S PARENT CORPORATION;J.EXCHANGE RULE 343(D)BY FAILING TODISPLAY THE EXCHANGE'S CERTIFICATE OF MEMBERSHIP IN A BRANCHOFFICE;K.EXCHANGE RULE 472.30 IN THAT IT PERMITTED A BRANCHOFFICE TO ISSUE COMMUNICATIONS TO THE PUBLIC THAT CONTAINEDINACCURATE INFORMATION REGARDING THE OFFICE'S AFFILIATION WITHTHE MEMBER ORGANIZATION;L.EXCHANGE RULE 408(B)BY, IN ONEBRANCH OFFICE, FAILING TO PROVIDE FOR FREQUENT APPROPRIATEREVIEW OF DISCRETIONARY ACCOUNTS BY A PERSON DELEGATED SUCHRESPONSIBILITY UNDER EXCHANGE RULE 342(B)(1), AND TO MAINTAIN AWRITTEN STATEMENT OF SUPERVISORY PROCEDURES GOVERNINGDISCRETIONARY ACCOUNTS IN THAT BRANCH;M.EXCHANGE RULE 346(B)BY FAILING TO OBTAIN WRITTEN REQUESTS FROM, AND PROVIDEWRITTEN CONSENT TO, CERTAIN REGISTERED REPRESENTATIVES TOENGAGE IN OUTSIDE BUSINESS ACTIVITIES;AND N.EXCHANGE RULE346(E) BY FAILING TO OBTAIN THE PERMISSION OF THE EXCHANGE FOR AREGISTERED REPRESENTATIVE WHO WAS ASSIGNED OR DELEGATEDRESPONSIBILITY OR AUTHORITY PURSUANT TO RULE 342, TO DEVOTELESS THAN HIS ENTIRE TIME DURING BUSINESS HOURS TO THEBUSINESS OF SUCH MEMBER ORGANIZATION BY ENGAGING IN THEBUSINESS OF THE FIRM'S PARENT CORPORATION.2.THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE IN THEAMOUNT OF $165.000. CONTACT PEGGY GERMINO 212 656-8450.
Sanctions Ordered: CensureMonetary/Fine $165,000.00
Decision
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*CONTINUED FROM #7*BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMERORDERS;I.EXCHANGE RULE 343(A)BY FAILING TO OBTAIN THEPERMISSION OF THE EXCHANGE FOR A BRANCH OFFICE TO SHAREOFFICE SPACE WITH AN INVESTMENT ADVISOR AFFILIATED WITH THEFIRM'S PARENT CORPORATION;J.EXCHANGE RULE 343(D)BY FAILING TODISPLAY THE EXCHANGE'S CERTIFICATE OF MEMBERSHIP IN A BRANCHOFFICE;K.EXCHANGE RULE 472.30 IN THAT IT PERMITTED A BRANCHOFFICE TO ISSUE COMMUNICATIONS TO THE PUBLIC THAT CONTAINEDINACCURATE INFORMATION REGARDING THE OFFICE'S AFFILIATION WITHTHE MEMBER ORGANIZATION;L.EXCHANGE RULE 408(B)BY, IN ONEBRANCH OFFICE, FAILING TO PROVIDE FOR FREQUENT APPROPRIATEREVIEW OF DISCRETIONARY ACCOUNTS BY A PERSON DELEGATED SUCHRESPONSIBILITY UNDER EXCHANGE RULE 342(B)(1), AND TO MAINTAIN AWRITTEN STATEMENT OF SUPERVISORY PROCEDURES GOVERNINGDISCRETIONARY ACCOUNTS IN THAT BRANCH;M.EXCHANGE RULE 346(B)BY FAILING TO OBTAIN WRITTEN REQUESTS FROM, AND PROVIDEWRITTEN CONSENT TO, CERTAIN REGISTERED REPRESENTATIVES TOENGAGE IN OUTSIDE BUSINESS ACTIVITIES;AND N.EXCHANGE RULE346(E) BY FAILING TO OBTAIN THE PERMISSION OF THE EXCHANGE FOR AREGISTERED REPRESENTATIVE WHO WAS ASSIGNED OR DELEGATEDRESPONSIBILITY OR AUTHORITY PURSUANT TO RULE 342, TO DEVOTELESS THAN HIS ENTIRE TIME DURING BUSINESS HOURS TO THEBUSINESS OF SUCH MEMBER ORGANIZATION BY ENGAGING IN THEBUSINESS OF THE FIRM'S PARENT CORPORATION.2.THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE IN THEAMOUNT OF $165.000. CONTACT PEGGY GERMINO 212 656-8450.
Disclosure 90 of 120
i
Reporting Source: Firm
Initiated By: DELAWARE SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 02/26/1999
Docket/Case Number: 98-08-02
Principal Product Type: No Product
Other Product Type(s):
Allegations: ON FEBRUARY 26, 1999, RAYMOND JAMES (RJA) ENTERED INTO ANAGREEMENT WITH THE DELAWARE SECURITIES DIVISION. THE DIVISIONALLEGES THAT TEN REPRESENTATIVES OF RJA TRANSACTEDINVESTMENT ADVISORY BUSINESS IN DELAWARE AFTER DECEMBER 31,1997 AFTER REGISTRATIONS EXPIRED FOR FAILURE TO RENEW FORCALENDAR YEAR 1998, AND THAT RJA WAS THEREBY IN VIOLATION OF 6DEL, SS731(E). RJA ALLEGES THAT IT ISSUED ITS CHECK TO PAY THERENEWAL FEES FOR CALENDAR YEAR 1998, WHICH PAYMENT THEDIVISION ALLEGES IT DID NOT RECEIVE.
Current Status: Final
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Resolution Date: 02/26/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: SOLELY FOR PURPOSES OF RESOLVING THIS MATTER AMICABLY,RAYMOND JAMES & ASSOCIATES AGREES TO A CENSURE AND SHALLREMIT TO THE DIVISION OF SECURITIES A CHECK IN THE AMOUNT OF$10,000.00 MADE PAYABLE TO THE "INVESTOR PROTECTION FUND", ANDTHE DIVISION SHALL NOT PURSUE ANY LEGAL ACTION AGAINST RJA ORTHE REPRESENTATIVES.
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Decision
Disclosure 91 of 120
i
Reporting Source: Firm
Initiated By: STATE OF NORTH DAKOTA
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
Date Initiated: 12/31/1996
Docket/Case Number: UNKNOWN
Principal Product Type: No Product
Other Product Type(s):
Allegations: ALLEGED THAT FIRM OFFERED INVESTMENTS IN ROYAL CROWNCORPORATION BONDS TO RESIDENTS OF NORTH DAKOTA WHILEINVESTMENTS WERE NOT REGISTERED OR EXEMPT UNDER ND LAW.
Current Status: Final
Resolution Date: 06/12/1997
Resolution:
Other Sanctions Ordered:
Sanction Details: CONSENT ORDER FROM STATE OF NORTH DAKOTA AND $2,000.00 FINE.
Firm Statement THE FIRM CLAIMED THAT THE BONDS WERE EXEMPTED BY VIRTUE OFTHE FACT THAT ROYAL CROWN'S (RC COLA) PARENT CORPORATION,TRIARC COMPANIES, INC. IS LISTED IN A QUALIFIED MANUAL ANDEXEMPTED FROM REGISTRATION UNDER NDCC 10-04-06(8).
Sanctions Ordered: Monetary/Fine $2,000.00
Decision
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Firm Statement THE FIRM CLAIMED THAT THE BONDS WERE EXEMPTED BY VIRTUE OFTHE FACT THAT ROYAL CROWN'S (RC COLA) PARENT CORPORATION,TRIARC COMPANIES, INC. IS LISTED IN A QUALIFIED MANUAL ANDEXEMPTED FROM REGISTRATION UNDER NDCC 10-04-06(8).
Disclosure 92 of 120
i
Reporting Source: Firm
Initiated By: PHILADELPHIA STOCK EXCHANGE
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
Date Initiated: 01/27/1999
Docket/Case Number: 98-14
Principal Product Type: Options
Other Product Type(s):
Allegations: THE COMMITTEE ALLEGED THAT FROM JULY 14, 1998 THROUGH JULY 23,1998, RJA VIOLATED EXCHANGE RULE 1001 IN THAT RJA HELD LONG SIDEPOSITIONS FOR TWO CUSTOMER ACCOUNTS WHICH WERE COMMONLYCONTROLLED BY THE SAME CUSTOMER, WHILE IT KNEW OR SHOULDHAVE KNOWN THAT, WHEN AGGREGATED, SUCH COMMONLYCONTROLLED CUSTOMER ACCOUNTS WOULD EXCEED THE APPLICABLEPOSITION LIMIT FOR THE OPTIONS BY EFFECTING SUCH TRANSACTIONS.
Current Status: Final
Resolution Date: 01/27/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: THE COMMITTEE DETERMINED TO ACCEPT RESPONDENT'S OFFER OFSETTLEMENT AND DIRECTS THE IMPOSITION OF A FINE OF $1,500.00.
Sanctions Ordered: Monetary/Fine $1,500.00
Decision
Disclosure 93 of 120
i
Reporting Source: Firm
Allegations: THE VIRGINIA SECURITIES DIVISION ALLEGES THAT RJA TRANSACTEDBUSINESS IN THE COMMONWEALTH AS AN UNREGISTERED INVESTMENTADVISOR IN VIOLATION OF VIRGINIA COSE SS 13.1-504A, AND EMPLOYEDUNREGISTERED INVESTMENT ADVISOR REPRESENTATIVES IN VIOLATIONOF VIRGINIA CODE SS 13.1-504C.
Current Status: Final
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Initiated By: COMMONWEALTH OF VIRGINIA, EX REL.
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 03/01/1994
Docket/Case Number: SEC940057
Principal Product Type: No Product
Other Product Type(s):
Allegations: THE VIRGINIA SECURITIES DIVISION ALLEGES THAT RJA TRANSACTEDBUSINESS IN THE COMMONWEALTH AS AN UNREGISTERED INVESTMENTADVISOR IN VIOLATION OF VIRGINIA COSE SS 13.1-504A, AND EMPLOYEDUNREGISTERED INVESTMENT ADVISOR REPRESENTATIVES IN VIOLATIONOF VIRGINIA CODE SS 13.1-504C.
Resolution Date: 05/27/1994
Resolution:
Other Sanctions Ordered:
Sanction Details: THE COMMISSION ACCEPTED THE OFFER OF SETTLEMENT MADE BY RJA.WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THEDIVISION OF SECURITIES AND RETAIL FRANCHISING, RJA CONSENTED TOA FINE OF $12,000.00 AND AGREED TO OFFER RECISION TO A NUMBER OFCUSTOMERS. FINE WAS PAID: 05/20/1994.
Sanctions Ordered: Monetary/Fine $12,000.00
Decision
Disclosure 94 of 120
i
Reporting Source: Firm
Initiated By: CHICAGO BOARD OF OPTION EXCHANGE
Date Initiated: 12/10/1974
Docket/Case Number: 74-0102
Principal Product Type: No Product
Other Product Type(s):
Allegations: THE ALLEGATIONS INVOLVED THE CONDUCTING OF BUSINESS WITHCUSTOMERS WITHOUT STRICT ADHERENCE TO PROPER PROCEDURES ASSPELLED OUT IN THE RULES OF THE EXCHANGE.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
CIVIL AND ADMINISTRATIVE PENALTY (IES)/FINE(S)
Other Product Type(s):
Resolution Date: 03/17/1975
Resolution:
Other Sanctions Ordered:
Sanction Details: THE BCC OF CBOE CONCLUDED THAT THE CONDUCT OF RJA AND ROBERTF. SHUCK, III WAS IN VIOLATION OF EXCHANGE RULES 4.1, 4.2, 9.7 AND 9.8AND THAT THE FINE OF $1,000.00 BE ISSUED.
Firm Statement IN A REPLY TO THE BCC OF THE CBOE DATED JANUARY 14, 1975, EACHALLEGATION WAS ANSWERED IN DETAIL AND PARTICULARS OF EACHTRANSACTION WERE FULLY EXPLAINED.
Sanctions Ordered: Monetary/Fine $1,000.00
Decision
Disclosure 95 of 120
i
Reporting Source: Firm
Initiated By: GEORGIA SECURITY COMMISSION
Principal Sanction(s)/ReliefSought:
Prohibition
Other Sanction(s)/ReliefSought:
CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S), OTHER FINANCIAL.
Date Initiated: 08/24/1988
Docket/Case Number: 50-88-959622
Principal Product Type: No Product
Other Product Type(s):
Allegations: ALLEGED SERVICING OF CLIENTS ACCOUNTS BY UNREGISTEREDAGENTS.
Current Status: Final
Resolution Date: 09/07/1988
Resolution:
Sanctions Ordered: Monetary/Fine $10,000.00
Decision
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Other Sanctions Ordered: OTHER FINANCIAL: $3,000.00
Sanction Details: GEORGIA SECURITY COMMISSION ISSUED AN ORDER OF PROHIBITIONCIVIL PENALTY. RAYMOND JAMES & ASSOCIATES, INC. PAID $3,000.00 FORCOSTS AND A FINE OF $10,000.00.
Sanctions Ordered: Monetary/Fine $10,000.00
Disclosure 96 of 120
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Reporting Source: Firm
Initiated By: STATE OF INDIANA
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 08/08/1985
Docket/Case Number: 85-0082CA
Principal Product Type: No Product
Other Product Type(s):
Allegations: FAILURE TO SUPERVISE. ORDERED TO SHOW CAUSE WHY AN ORDERSUSPENDING OR REVOKING BROKER/DEALER REGISTRATION OF RJA ANDAGENT REGISTRATION OF WILLIAM D. THATCHER AND ROBERT J. HOOKSHOULD NOT BE ENTERED.
Current Status: Final
Resolution Date: 01/31/1986
Resolution:
Other Sanctions Ordered: OTHER FINANCIAL -- $5,000.00
Sanction Details: BY MUTUAL AGREEMENT WITH THE INDIANA SECURITIES DIVISION, RJAAGREES TO PAY COSTS OF INVESTIGATION OF $5,000.00 AND IS HEREBYCENSURED. THATCHER AGREES TO WITHDRAW HIS AGENT'SREGISTRATION FROM THE STATE OF INDIANA AND FURTHER AGREES NOTTO APPLY FOR REGISTRATION AS AN AGENT FOR A PERIOD OF TWOYEARS. THATCHER IS HEREBY CENSURED. NO PORTION OF THE COSTSOF INVESTIGATION WAS WAIVED.
Sanctions Ordered: CensureCease and Desist/Injunction
Decision
Disclosure 97 of 120
i
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Disclosure 97 of 120
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
$7,000.00 FINE
Date Initiated: 07/26/1999
Docket/Case Number: CMS990080
Principal Product Type: Other
Other Product Type(s):
Allegations: RESPONDENT MEMBER: FAILED TO DISPLAY IMMEDIATELY CUSTOMERLIMIT ORDERS, WHEN THE ORDERS WERE AT A PRICE THAT WOULD HAVEIMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY RELATED TOTHOSE ORDERS, OR WHEN THE FULL SIZE OF THE ORDERS WERE PRICEDEQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OROFFER AND THE ORDERS REPRESENTED MORE THAN A DE MINIMUSCHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OROFFER IN EACH SECURITY; WHEN ACTING AS A PRINCIPAL FOR ITS OWNACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION TO THECUSTOMER THAT THE PRICE TO THE CUSTOMER WAS AN AVERAGE OFTHE TRADE PRICES REPORTED BY THE FIRM TO ACT, IN VIOLATION OFSEC RULE 10B-10; FAILED TO ESTABLISH, MAINTAIN AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE SEC ORDER EXECUTION RULES ANDTHE NASD'S RULE RELATING TO LOCKED AND CROSSED MARKETS. (SECRULES 10B-10, 11AC1-4, NASD RULES 2110, 3010)
Current Status: Final
Resolution Date: 07/26/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: $7,000.00 FINE; CENSURE
Regulator Statement 02-08-00, $7,000 PAID ON 8/24/99, INVOICE #99-MS-701
Sanctions Ordered: CensureMonetary/Fine $7,000.00
Acceptance, Waiver & Consent(AWC)
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iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 04/27/1999
Docket/Case Number: CMS990080
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: FAILED TO EXECUTE ORDERS, AND FAILURE TO SUPERVISE.
Current Status: Final
Resolution Date: 07/23/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: VIOLATION OF SEC EXCHANGE ACT RULE 11A-4 AND SEC RULE 10B-10;VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. NOTICE OFACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED. RJA CONSENTSTO A CENSURE AND FINE OF $7,000.00. ($1,000.00 FOR THE SEC RULE 10B-10 VIOLATIONS, $5,000.00 FOR THE SUPERVISION VIOLATIONS AND$1,000.00 FOR THE SEC DISPLAY RULE VIOLATIONS).
Sanctions Ordered: CensureMonetary/Fine $7,000.00
Acceptance, Waiver & Consent(AWC)
Disclosure 98 of 120
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Reporting Source: Regulator
Initiated By: PHILADELPHIA STOCK EXCHANGE
Date Initiated: 06/04/1980
Docket/Case Number:
Principal Product Type:
Allegations:
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Principal Product Type:
Other Product Type(s):
Resolution Date: 06/13/1980
Resolution:
Regulator Statement PHLX - JUNE 13, 1980JUNE 4, 1980 - OFFER OF SETTLEMENT ACCEPTED BY COMMITTEE ONFLOOR PROCEDURE. CONSENTED TO THE IMPOSITION OF A PENALTY OFA REPRIMAND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.
Settled
iReporting Source: Firm
Initiated By: PHILADELPHIA STOCK EXCHANGE
Principal Sanction(s)/ReliefSought:
Reprimand
Other Sanction(s)/ReliefSought:
Date Initiated: 11/27/1979
Docket/Case Number: UNKNOWN
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: DURING THE PERIOD 3/19/1979, THROUGH AND INCLUDING 06/18/1979,AGENTS FOR RESPONDENT FAILED TO COMMUNICATE TO THE EXCHANGEA BID AND OFFER FOR PUBLICATION. THE ACTS, PRACTICES ANDCONDUCT AFORESAID CONSTITUTE SEPARATE AND DISTINCT VIOLATIONSOF EXCHANGE RULE 105 BY RESPONDENT RJA. PENALTY NOT TOEXCEED: A REPRIMAND OF RJA.
Current Status: Final
Resolution Date: 06/04/1980
Resolution:
Other Sanctions Ordered: LETTER OF REPRIMAND
Sanctions Ordered:
Decision & Order of Offer of Settlement
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Other Sanctions Ordered: LETTER OF REPRIMAND
Sanction Details: RJA WAIVED RIGHT TO HEARING OR REVIEW AND AGREED TO OFFER OFSETTLEMENT MARCH 6, 1980. COMMITTEE ON FLOOR PRACTICEACCEPTED OFFER OF SETTLEMENT 06/04/1980.
Disclosure 99 of 120
i
Reporting Source: Regulator
Initiated By: SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/11/1999
Docket/Case Number:
Principal Product Type: No Product
Other Product Type(s):
Allegations: TRADED NASDAQ STOCKS FOR ITS OWN ACCOUNTS AND FOR THEACCOUNTS OF INSTITUTIONAL AND RETAIL INVESTORS.
Current Status: Final
Resolution Date: 01/11/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: RAYMOND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSINGANY VIOLATION OF AND COMMITTING OR CAUSING ANY FUTUREVIOLATION OF SECTIONS 15(C)(1)AND (2), AND 17(A)OF THE EXCHANGEACT, AND RULES 15C1-2, 15C2-7, AND 17A-3 THEREUNDER; SHALL PAY ACIVIL PENALTY IN THE AMOUNT OF $400,000 WITHIN 10 BUSINESS DAYS;SHALL PAY DISGORGEMENT IN THE AMOUNT OF $7,431.00 WITHIN 10BUSINESS DAYS PURSUANT TO SECTION 21C(E) OF THE EXCHANGE ACT;RAYMOND SHALL, WITHIN 90 DAYS OF THE DATE OF THE ENTRY OF THISORDER, PROVIDE TO THE INDEPENDENT CONSULTANT APPOINTED BYTHE SEC A DESCRIPTION OF ITS POLICIES, PROCEDURES AND PRACTICESRELATING TO PREVENTION OR DETECTION OF THE TYPES OF IMPROPERCONDUCT.
Sanctions Ordered: Monetary/Fine $400,000.00Disgorgement/RestitutionCease and Desist/Injunction
Decision & Order of Offer of Settlement
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RAYMOND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSINGANY VIOLATION OF AND COMMITTING OR CAUSING ANY FUTUREVIOLATION OF SECTIONS 15(C)(1)AND (2), AND 17(A)OF THE EXCHANGEACT, AND RULES 15C1-2, 15C2-7, AND 17A-3 THEREUNDER; SHALL PAY ACIVIL PENALTY IN THE AMOUNT OF $400,000 WITHIN 10 BUSINESS DAYS;SHALL PAY DISGORGEMENT IN THE AMOUNT OF $7,431.00 WITHIN 10BUSINESS DAYS PURSUANT TO SECTION 21C(E) OF THE EXCHANGE ACT;RAYMOND SHALL, WITHIN 90 DAYS OF THE DATE OF THE ENTRY OF THISORDER, PROVIDE TO THE INDEPENDENT CONSULTANT APPOINTED BYTHE SEC A DESCRIPTION OF ITS POLICIES, PROCEDURES AND PRACTICESRELATING TO PREVENTION OR DETECTION OF THE TYPES OF IMPROPERCONDUCT.
Regulator Statement [TOP] 02/11/99 SEC NEWS DIGEST, ISSUE NO. 99-6, DATED 1/11/99,ENFORCEMENT PROCEEDINGS DISCLOSES; SEC INSTITUTEDADMINISTRATIVE PROCEEDINGS AGAINST 28 NASDAQ MARKET MAKINGFIRMS PURSUANT TO SEC.15(B)AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND, AS TO ONE FIRM, PURSUANT TO SECTION 203(K) OFTHE INVESTMENT ADVISERS ACT OF 1940. SIMULTANEOUSLY WITH THEFILING OF THE ACTION, ALL OF THE RESPONDENTS CONSENTED,WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, TO ORDERSIMPOSING CIVIL MONETARY PENALTIES OF $26,302,500, DISGORGEMENTOF WRONGFUL GAINS TOTALING $791,525, SUSPENSIONS OR BARS,CEASE AND DESIST ORDERS AND OTHER SANCTIONS. *** 2/11/99 SECADMINISTRATIVE PROCEEDING FILE NO. 3-9803 DATED 1/11/99 DISCLOSES;RAYMOND JAMES & ASSOCIATES, INC. TRADED NASDAQ STOCKS FOR ITSOWN ACCOUNTS AND FOR THE ACCOUNTS OF INSTITUTIONAL AND RETAILINVESTORS. IT IS ORDERED, PURSUANT TO SEC. 15(B) AND 21C OF THEEXCHANGE ACT, THAT RAYMOND SHALL CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATION OF AND COMMITTING ORCAUSING ANY FUTURE VIOLATION OF SECTIONS 15(C)(1)AND (2), AND17(A)OF THE EXCHANGE ACT, AND RULES 15C1-2, 15C2-7, AND 17A-3THEREUNDER; SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $400,000WITHIN 10 BUSINESS DAYS; SHALL PAY DISGORGEMENT IN THE AMOUNTOF $7,431.00 WITHIN 10 BUSINESS DAYS PURSUANT TO SECTION 21C(E)OF THE EXCHANGE ACT; RAYMOND SHALL, WITHIN 90 DAYS OF THE DATEOF THE ENTRY OF THIS ORDER, PROVIDE TO THE INDEPENDENTCONSULTANT APPOINTED BY THE SEC A DESCRIPTION OF ITS POLICIES,PROCEDURES AND PRACTICES RELATING TO PREVENTION ORDETECTION OF THE TYPES OF IMPROPER CONDUCT. (REL. NO. 34-40922,FILE NO. 3-9803)
iReporting Source: Firm
Initiated By: SECURITIES AND EXCHANGE COMMISSION
Date Initiated: 01/11/1999
Docket/Case Number: 3-9803
Allegations: ON JANUARY 11, 1999, THE SEC BROUGHT ACTION AGAINST ALMOST ALLOF THE MAJOR NASDAQ MARKET MAKERS IN CONNECTION WITH THEIR1994 MARKET MAKING ACTIVITIES. THE COMMISSION ALLEGED THAT IN1994 MARKET MAKERS, INCLUDING RJA VIOLATED PROVISIONS OF THEFEDERAL SECURITIES LAWS IN CONNECTION WITH THEIR MARKETMAKING ACTIVITIES IN NASDAQ SECURITIES.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Docket/Case Number: 3-9803
Principal Product Type: Equity - OTC
Other Product Type(s):
Resolution Date: 01/11/1999
Resolution:
Other Sanctions Ordered:
Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMES &ASSOCIATES, INC. AGREED TO PAY A CIVIL PENALTY OF $400,000.00 ANDDISGORGEMENT OF $7,431.00 TO SETTLE THE MATTER. IN ADDITION, ITAGREED TO A CEASE AND DESIST ORDER AND TO SUBMIT CERTAIN OF ITSPOLICIES TO AN INDEPENDENT CONSULTANT. THE RELEVENT ORDER ISCAPTIONED: IN RE NASDAQ MARKET MAKERS: JANUARY 11, 1999[RELEASE NO. 34-40900] AND IN RE: RAYMOND JAMES & ASSOCIATES,INC.; JANUARY 11, 1999 [RELEASE NO. 34-40922].
Sanctions Ordered: Monetary/Fine $400,000.00Disgorgement/RestitutionCease and Desist/Injunction
Consent
Disclosure 100 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/20/1998
Docket/Case Number: CMS980069 AWC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Other Sanction(s)/ReliefSought:
Resolution Date: 07/20/1998
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980069 AWC.
ON JULY 20, 1998, RAYMOND JAMES ASSOCIATES, INC. (RAJA) WASNOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'SDEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORYCOUNCIL. THE AWC ALLEGES THAT THE FOLLOWING VIOLATIONSOCCURRED:
RAJA FAILED TO EXECUTE 13 ORDERS WHICH WERE PRESENTED TO RAJAAT RAJA'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT EQUALTO OR LESS THAN ITS PUBLISHED QUOTATION SIZE AND, THEREFORE,FAILED TO HONOR ITS PUBLISHED QUOTATION. THIS CONDUCTCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF SEC RULE11Ac1-1 ("SEC FIRM QUOTE RULE"), NASD CONDUCT RULE 3320 ANDNASD MARKETPLACE RULE 4613(b) ("NASD FIRM QUOTE RULES").
RAJA FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE APPLICABLE SECURITIES LAWS ANDREGULATIONSCONCERNING THE SEC'S FIRM QUOTE RULE AND NASD FIRM QUOTERULES.
RAJA WAS CENSURED AND FINED $5,500.
***** $5,000 PAID ON 9/4/98, INVOICE NO. 98-MS-676 ******
Sanctions Ordered: CensureMonetary/Fine $5,500.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Allegations: ALLEGED FAILURE TO EXECUTE ORDERS AND FAILED TO SUPERVISE.
Current Status: Final
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 01/05/1998
Docket/Case Number: CMS980069
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: ALLEGED FAILURE TO EXECUTE ORDERS AND FAILED TO SUPERVISE.
Resolution Date: 07/20/1998
Resolution:
Other Sanctions Ordered:
Sanction Details: VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. NOTICE OFACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED. RJA CONSENTSTO A CENSURE AND A FINE OF $5,500.00. ($500.00 FOR THE BACKING AWAYVIOLATIONS AND $5,000.00 FOR THE SUPERVISORY VIOLATION).
Sanctions Ordered: CensureMonetary/Fine $5,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 101 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/08/1998
Docket/Case Number: CMS970065
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: VIOLATIONS OF MARKETPLACE RULE 4632(A); 6620(A); 4642(A);6130(B);AND NASD CONDUCT RULE 2110 AND IM 2110-2;3010
Current Status: Final
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Other Sanction(s)/ReliefSought:
Resolution Date: 01/08/1998
Resolution:
Other Sanctions Ordered:
Sanction Details: FINED $17,5000
Regulator Statement [TOP]LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS970065.ON 1/8/98, RAYMOND JAMES AND ASSOCIATES, INC. (RAJA)WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION ANDTHE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES;RAJA FAILED TO DESIGNATE AS LATE TO ACT, 50 TRANSACTIONS INNASDAQ NATIONAL MARKET SECURITIES; IMPROPERLY DESIGNATED AS ".T" TO ACT 12 TRANSACTIONS IN NASDAQ NATIONAL MARKETSECURITIES; FAILED TO REPORT TO ACT THE CORRECT TIME OFEXECUTION IN 36 TRANSACTIONS IN NASDAQ NATIONAL MARKETSECURITIES; AND FAILED TO REPORT TO ACT THE TIME OF EXECUTION INFOUR TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES,CONSTITUTING VIOLATIONS OF MARKETPLACE RULE 4632(A) AND AVIOLATION OF NASD CONDUCT RULE 2110; FAILED TO DESIGNATE AS LATETO ACT 5 TRANSACTIONS IN NASDAQ SMALLCAP SECURITIES; FAILED TOREPORT TO ACT THE CORRECT TIME OF EXECUTION IN 3 TRANSACTIONSIN NASDAQ SMALLCAP SECURITIES; AND FAILED TO REPORT TO ACT THETIME OF EXECUTION IN ONE TRANSACTION IN A NASDAQ SMALLCAPSECURITY. THIS CONSTITUTES VIOLATIONS OF NASD MARKETPLACE RULE4642(A); FAILED TO DESIGNATE AS LATE TO ACT 2 TRANSACTIONS IN OTCEQUITY SECURITIES; AND FAILED TO REPORT TO ACT THE CORRECT TIMEOF EXECUTION IN ONE TRANSACTION IN AN OTC EQUITY SECURITY.THISCONSTITUTES VIOLATIONS OF NASD MARKETPLACE RULE 6620(A);FAILEDTO ACCEPT OR DECLINE IN ACT 11 TRANSACTIONS IN ELIGIBLESECURITIES WITHIN 20 MINUTES AFTER EXECUTION.THIS CONSTITUTESVIOLATIONS OF NASD MARKETPLACE RULE 6130(B); FAILED TOCONTEMPORANEOUSLY EXECUTE 18 CUSTOMER LIMIT ORDERS AFTER ITTRADED FOR ITS MARKET MAKING ACCOUNT AT A PRICE THAT WOULDSATISFY EACH CUSTOMER LIMIT ORDER. THIS CONSTITUTES VIOLATIONSOF NASD CONDUCT RULE 2110 AND IM 2110-2. IN ADDITION FAILED TOESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORYPROCEDURES. THIS CONSTITUTES A VIOLATION OF NASD CONDUCTRULES 2110 AND 3010. RAJA WAS CENSURED AND FINED $17,5000.
Sanctions Ordered: CensureMonetary/Fine $17,500.00
Acceptance, Waiver & Consent(AWC)
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iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 11/26/1997
Docket/Case Number: CMS970065-AWC
Principal Product Type: Equity - OTC
Other Product Type(s):
Allegations: OTC TRADE REPORTING VIOLATIONS AND FAILURE TO SUPERVISE.
Current Status: Final
Resolution Date: 01/08/1998
Resolution:
Other Sanctions Ordered:
Sanction Details: NOTICE OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED. RJAWAS CENSURED AND FINED $17,500.00.
Sanctions Ordered: CensureMonetary/Fine $17,500.00
Acceptance, Waiver & Consent(AWC)
Disclosure 102 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Date Initiated: 12/15/1997
Docket/Case Number: CAF970006
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 12/15/1997
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement ON DECEMBER 15, 1997, THE DEPARTMENT OF ENFORCEMENT NOTIFIEDRESPONDENT RAYMOND JAMES & ASSOCIATES, INC. THAT THE LETTEROFACCEPTANCE, WAIVER AND CONSENT NO. CAF970006 WAS ACCEPTED;THEREFORE THE FIRM IS CENSURED AND FINED $10,000 - (MSRB RULESG-8(a)(xv) AND G-36 - RESPONDENT MEMBER, SERVING AS SOLE ORMANAGING UNDERWRITER IN PRIMARY OFFERINGS OF MUNICIPALSECURITIES, FAILED TO MAINTAIN RECORDS; AND FAILED TO TIMELYSUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THEMSRB)
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Acceptance, Waiver & Consent(AWC)
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 03/17/1997
Docket/Case Number: CAF970006
Principal Product Type: No Product
Other Product Type(s):
Allegations: VIOLATIONS OF MSRB RULES G-36 AND G-8(A)(XV)
Current Status: Final
Resolution Date: 12/15/1997
Resolution: Consent
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Resolution Date: 12/15/1997
Other Sanctions Ordered:
Sanction Details: RJA HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING ORDENYING THE ALLEGED VIOLATIONS TO THE IMPOSITION OF A CENSUREAND A FINE OF $10,000.00. THE FIRM ALSO REPRESENTED TO THE STAFFTHAT IT HAS EFFECTED NEW PROCEDURES TO ENSURE FUTURECOMPLIANCE WITH MSRB RULES G-36 AND G-8(A)(XV).
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Disclosure 103 of 120
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Reporting Source: Regulator
Allegations: **10/24/97** EVENT :STIPULATION AND CONSENTTO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT,RAYMOND JAMES CONSENTS TO 1. FINDINGS BY THE HEARING PANELTHATIT VIOLATED: a. SEA REGULATION 240.15c(e) BY FAILING TO PREPAREITS RESERVE FORMULA COMPUTATION IN ACCORDANCE WITH THE**REQUIREMENTS OF THAT REGULATION b. SEA REGULATION 240.17-3AND EXCHANGE RULE 440 IN THAT THE FIRM'S COMPUTATION OF ITS NETCAPITAL WAS INACCURATE AND NOT PREPARED IN ACCORDANCE WITHSEAREGULATION 240.15c3-1; c. SEA REGULATION 240.17a-5 BY FILINGINACCURATE FOCUS REPORTS; d. EXCHANGE RULE 431 BY FAILING TOCOMBINE OR AGGREGATE ACCOUNTS UNDER COMMON CONTROL ANDFAILINGTO MAKE THE CONCENTRATION REDUCTION REQUIRED BY THAT RULE; e.SECTION 220.16 OF REGULATION T PROMULGATED BY THE BOARD OFGOVERNORS OF THE FEDERAL RESERVE SYSTEM BY PLEDGINGBORROWEDSECURITIES FOR PURPOSES CONTRARY TO THE SPECIFIC PURPOSESALLOWED BY THAT REGULATION; f. SEA REGULATION 240.17a-3 BY: (1)FAILING TO RECORD, ON THE DATE RECEIVED, CHECKS AND/OR WIREDFUNDS RECEIVED FROM CUSTOMERS LATE IN THE DAY; AND (2)MAINTAINING A STOCK RECORD THAT DID NOT PROPERLY REFLECTTHOSELOCATIONS OF "SECURITIES LONG" THAT ARE RECOGNIZED AS "GOODCONTROL LOCATIONS" AS DEFINED IN SEA REGULATION 240.15c3-3; g.EXCHANGE RULE 342.30 BY FAILING TO TIMELY ISSUE THE REQUISITEANNUAL REPORT CONCERNING THE FIRMS'S SUPERVISION ANDCOMPLIANCEEFFORTS; h. SEA REGULATION 240.15c3-3 BY: (1) FAILING TO ENSURETHAT THE FIRM'S ALLOCATION SYSTEM WAS OPERATING IN ACCORDANCEWITH THAT REGULATION; AND (2) FAILING TO PROMPTLY OBTAIN ANDTHEREAFTER MAINTAIN THE PHYSICAL POSSESSION OR CONTROL OF ALLFULLY-PAID SECURITIES CARRIED BY THE FIRM FOR THE ACCOUNTS OFITS CUSTOMERS; i. EXCHANGE RULE 440.20 BY FAILING TO IDENTIFYSUSPENSE ACCOUNTS OF ITS BUSINESS ACTIVITIES; (2) FAILING TOPROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL;$35,000.
Current Status: Final
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Initiated By: NYSE DIVISION OF ENFORCEMENT NYSE DIVISIONOF ENFOR*See FAQ #1*
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/24/1997
Docket/Case Number: 97-157
Principal Product Type:
Other Product Type(s):
**10/24/97** EVENT :STIPULATION AND CONSENTTO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT,RAYMOND JAMES CONSENTS TO 1. FINDINGS BY THE HEARING PANELTHATIT VIOLATED: a. SEA REGULATION 240.15c(e) BY FAILING TO PREPAREITS RESERVE FORMULA COMPUTATION IN ACCORDANCE WITH THE**REQUIREMENTS OF THAT REGULATION b. SEA REGULATION 240.17-3AND EXCHANGE RULE 440 IN THAT THE FIRM'S COMPUTATION OF ITS NETCAPITAL WAS INACCURATE AND NOT PREPARED IN ACCORDANCE WITHSEAREGULATION 240.15c3-1; c. SEA REGULATION 240.17a-5 BY FILINGINACCURATE FOCUS REPORTS; d. EXCHANGE RULE 431 BY FAILING TOCOMBINE OR AGGREGATE ACCOUNTS UNDER COMMON CONTROL ANDFAILINGTO MAKE THE CONCENTRATION REDUCTION REQUIRED BY THAT RULE; e.SECTION 220.16 OF REGULATION T PROMULGATED BY THE BOARD OFGOVERNORS OF THE FEDERAL RESERVE SYSTEM BY PLEDGINGBORROWEDSECURITIES FOR PURPOSES CONTRARY TO THE SPECIFIC PURPOSESALLOWED BY THAT REGULATION; f. SEA REGULATION 240.17a-3 BY: (1)FAILING TO RECORD, ON THE DATE RECEIVED, CHECKS AND/OR WIREDFUNDS RECEIVED FROM CUSTOMERS LATE IN THE DAY; AND (2)MAINTAINING A STOCK RECORD THAT DID NOT PROPERLY REFLECTTHOSELOCATIONS OF "SECURITIES LONG" THAT ARE RECOGNIZED AS "GOODCONTROL LOCATIONS" AS DEFINED IN SEA REGULATION 240.15c3-3; g.EXCHANGE RULE 342.30 BY FAILING TO TIMELY ISSUE THE REQUISITEANNUAL REPORT CONCERNING THE FIRMS'S SUPERVISION ANDCOMPLIANCEEFFORTS; h. SEA REGULATION 240.15c3-3 BY: (1) FAILING TO ENSURETHAT THE FIRM'S ALLOCATION SYSTEM WAS OPERATING IN ACCORDANCEWITH THAT REGULATION; AND (2) FAILING TO PROMPTLY OBTAIN ANDTHEREAFTER MAINTAIN THE PHYSICAL POSSESSION OR CONTROL OF ALLFULLY-PAID SECURITIES CARRIED BY THE FIRM FOR THE ACCOUNTS OFITS CUSTOMERS; i. EXCHANGE RULE 440.20 BY FAILING TO IDENTIFYSUSPENSE ACCOUNTS OF ITS BUSINESS ACTIVITIES; (2) FAILING TOPROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL;$35,000.
Resolution Date: 12/19/1997
Resolution:
Other Sanctions Ordered:
Sanction Details: **NOVEMBER 24, 1997** DECISION 97-157 ISSUED BYNYSE HEARING PANEL. DECISION: VIOLATED SECURITIES EXCHANGE ACT("SEA") REGULATION 240.15c-3(e) BY FAILING TO CORRECTLY PREPAREITS RESERVE FORMULA COMPUTATION, VIOLATED SEA REGULATION240.17a-3 AND EXCHANGE RULE 440 IN THAT THE FIRM'S NET CAPITALCOMPUTATION WAS INACCURATE, VIOLATED SEA REGULATION 240.17a-5BY FILING INACCURATE FOCUS REPORTS, VIOLATED EXCHANGE RULE 431BY FAILING TO COMBINE ACCOUNTS UNDER COMMON CONTROL ANDMAKETHE REQUIRED CONCENTRATION REDUCTION, VIOLATED SECTION 220.16OF REGULATION T BY PLEDGING BORROWED SECURITIES IMPROPERLY,VIOLATED SEA REGULATION 240.17a-3 BY FAILING TO RECORD CHECK ORWIRED FUNDS ON THE DATE RECEIVED AND MAINTAINING A STOCKRECORDTHAT DID NOT PROPERLY REFLECT LOCATIONS OF SECURITIES LONG,VIOLATED EXCHANGE RULE 342.30 BY FAILING TO TIMELY ISSUE THEANNUAL REPORT ON SUPERVISION AND COMPLIANCE, VIOLATED SEAREGULATION 240.15c3-3 BY FAILING TO ENSURE THAT THE ALLOCATIONSYSTEM WAS OPERATING PROPERLY AND FAILING TO OBTAIN ANDMAINTAIN THE REQUIRED POSSESSION AND CONTROL OF CERTAINSECURITIES, VIOLATED EXCHANGE RULE 440.20 BY FAILING TOINDENTIFY SUSPENSE ACCOUNTS, AND VIOLATED EXCHANGE RULE 342BYFAILING TO REASONABLY SUPERVISE AND CONTROL, PROVIDE FORAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, ANDESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW -- CONSENTTO CENSURE AND $35,000 FINE.
Sanctions Ordered: CensureMonetary/Fine $35,000.00
Consent
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**NOVEMBER 24, 1997** DECISION 97-157 ISSUED BYNYSE HEARING PANEL. DECISION: VIOLATED SECURITIES EXCHANGE ACT("SEA") REGULATION 240.15c-3(e) BY FAILING TO CORRECTLY PREPAREITS RESERVE FORMULA COMPUTATION, VIOLATED SEA REGULATION240.17a-3 AND EXCHANGE RULE 440 IN THAT THE FIRM'S NET CAPITALCOMPUTATION WAS INACCURATE, VIOLATED SEA REGULATION 240.17a-5BY FILING INACCURATE FOCUS REPORTS, VIOLATED EXCHANGE RULE 431BY FAILING TO COMBINE ACCOUNTS UNDER COMMON CONTROL ANDMAKETHE REQUIRED CONCENTRATION REDUCTION, VIOLATED SECTION 220.16OF REGULATION T BY PLEDGING BORROWED SECURITIES IMPROPERLY,VIOLATED SEA REGULATION 240.17a-3 BY FAILING TO RECORD CHECK ORWIRED FUNDS ON THE DATE RECEIVED AND MAINTAINING A STOCKRECORDTHAT DID NOT PROPERLY REFLECT LOCATIONS OF SECURITIES LONG,VIOLATED EXCHANGE RULE 342.30 BY FAILING TO TIMELY ISSUE THEANNUAL REPORT ON SUPERVISION AND COMPLIANCE, VIOLATED SEAREGULATION 240.15c3-3 BY FAILING TO ENSURE THAT THE ALLOCATIONSYSTEM WAS OPERATING PROPERLY AND FAILING TO OBTAIN ANDMAINTAIN THE REQUIRED POSSESSION AND CONTROL OF CERTAINSECURITIES, VIOLATED EXCHANGE RULE 440.20 BY FAILING TOINDENTIFY SUSPENSE ACCOUNTS, AND VIOLATED EXCHANGE RULE 342BYFAILING TO REASONABLY SUPERVISE AND CONTROL, PROVIDE FORAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, ANDESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW -- CONSENTTO CENSURE AND $35,000 FINE.
Regulator Statement CONTACT: PEGGY L. GERMINO (212)656-8450 U-6 ELECTRONICALLY ENTERED BY NYSE4; TRANS #400002-35697**NOVEMBER 24, 1997** UNLESS A REVIEW BY THE NYSE BOARD OFDIRECTORS IS REQUESTED, THIS DECISION WILL BECOME FINAL 25CALENDAR DAYS AFTER NOTICE OF THE HEARING PANEL'SDETERMINATIONHAS BEEN SERVED UPON THE RESPONDENT. CONTACT: MS. PEGGY L.GERMINO AT (212) 8450 U-6 ELECTRONICALLY ENTERED BY NYSE1; TRANS #400015-01298**1/9/98** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: PEGGY L. GERMINO (212) 656-8450.
iReporting Source: Firm
Initiated By: NEW YORK STOCK EXCHANGE
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 10/24/1997
Docket/Case Number: UNKNOWN
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s):
Allegations: BOOKS AND RECORDS VIOLATION(S); FAILURE TO MEET FINANCIALSTANDARDS; FAILURE TO SUPERVISE; FAILURE TO FILE FINANCIALREPORTS.
Current Status: Final
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Other Sanction(s)/ReliefSought:
Resolution Date: 10/24/1997
Resolution:
Other Sanctions Ordered:
Sanction Details: VIOLATION OF SEA REGULATIONS 240.15C(E), 240.17-3, 240.15C3-1,240.15C3-3, 240.17A-5; EXCHANGE FULES 431,342.30, AND 440.20; SECTION220.16 OF REGULATION T. WITHOUT ADMITTING OR DENYING GUILT, RJAAGREES AND CONSENTS TO THE IMPOSITION OF A CENSURE AND$35,000.00 FINE.
Sanctions Ordered: CensureMonetary/Fine $35,000.00
Consent
Disclosure 104 of 120
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Reporting Source: Regulator
Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECT*See FAQ #1*
Principal Sanction(s)/ReliefSought:
Date Initiated: 10/25/1995
Docket/Case Number: 2083-S-9/94
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
Allegations: THE FLORIDA DEPARTMENT OF BANKING AND FINANCEALLEGED THAT RAYMOND JAMES AND ASSOCIATES, INC. AND DANIELSTEWART FAILED TO PROPERLY SUPERVISE THE ACTIVITIES OFASSOCIATED PERSONS IN THE FIRM'S BOCA RATON AND FORTLAUDERDALEBRANCH OFFICES. SPECIFICALLY, THE DEPARTMENT ALLEGES THATRESPONDENTS FAILED TO ENFORCE PROCEDURES RELATING TO THIRDPARTY DISBURSEMENTS OF CUSTOMER FUNDS, INTER-ACCOUNTTRANSFERSAND ALLOWED AN ASSOCIATED PERSON TO DEPOSIT HIS PERSONALFUNDSINTO CUSTOMER ACCOUNTS.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 10/25/1995
Resolution:
Other Sanctions Ordered:
Sanction Details: ON OCTOBER 25, 1995, THE FLORIDA DEPARTMENT OFBANKING AND FINANCE ISSUED A FINAL ORDER ENTERING INTO ASTIPULATION AND CONSENT AGREEMENT WITH RESPONDENTS RAYMONDJAMES AND ASSOCIATES, INC. AND DANIEL STEWART. THE FINAL ORDERINCORPORATES THE STIPULATION AND CONSENT AGREEMENT IN WHICHRESPONDENTS AGREE TO (WHILE NEITHER ADMITTING NOR DENYINGTHEALLEGATIONS): CEASE AND DESIST FROM ANY AND ALL FUTUREVIOLATIONS OF CHAPTER 517, FLORIDA STATUTES, AND THE RULESTHEREUNDER; RESPONDENT RAYMAOND JAMES AND ASSOCIATES INC.AGREES TO PAY AN ADMINISTRATIVE FINE OF $10,000 AND RESPONDENTDANIEL STEWART AGREES TO PAY AN ADMINISTRATIVE FINE OF $2,500.
Regulator Statement CONTACT: WILLIAM F. REILLY (904) 488-9805.
Sanctions Ordered: Monetary/Fine $10,000.00Cease and Desist/Injunction
Decision
iReporting Source: Firm
Initiated By: STATE OF FLORIDA
Date Initiated: 09/01/1994
Docket/Case Number: 2083-S-9/94 & 2084-S-9/94
Principal Product Type: No Product
Other Product Type(s):
Allegations: ALLEGED THAT RJA AND DAINEL STEWART FAILED TO PROPERLYSUPERVISE THE ACTIVITIES OF ASSOCIATED PERSONS IN THE FIRM'S FT.LAUDERDALE BRANCH OFFICE. SPECIFICALLY, THE DEPARTMENTALLEGES THAT RESPONDENTS FAILED TO ENFORCE PROCEDURESRELATING TO THIRD PARTY DISBURSEMENTS OF CUSTOMER FUNDS ANDINTER-ACCOUNT TRANSFERS.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Resolution Date: 10/25/1995
Resolution:
Other Sanctions Ordered: SPECIAL STIPULATION
Sanction Details: FLORIDA ISSUED A FINAL ORDER ENTERING INTO A STIPULATION ANDCONSENT AGREEMENT IN WHICH RESPONDENTS AGREE TO CEASE ANDDESIST FROM ANY AND ALL FUTURE VIOLATIONS OF CHAPTER 517, FLSTATUTES, AND THE RULES THEREUNDER. RESPONDENT RJA AGREES TOPAY AN ADMINISTRATIVE FINE OF $10,000.00 AND RESPONDENT DANIELSTEWART AGREES TO PAY AN ADMINISTRATIVE FINE OF $2,500.00
Sanctions Ordered: Monetary/Fine $10,000.00
Decision
Disclosure 105 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 06/12/1973
Docket/Case Number: N-V-309
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 11/15/1973
Resolution:
Other Sanctions Ordered:
Sanction Details:
Sanctions Ordered: Monetary/Fine $25.00
Decision
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Sanction Details:
Regulator Statement NASDAQ COMPLAINT N-V-309 FILED 6-12-73 10-1-73 FINED $25.0011-15-73 FINAL
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 06/12/1973
Docket/Case Number: N-V-309
Principal Product Type: Other
Other Product Type(s): UNKNOW - CRD DATA CONVERSION
Allegations: FAILED TO REPORT ITS NASDAQ VOLUME.
Current Status: Final
Resolution Date: 10/01/1973
Resolution:
Other Sanctions Ordered:
Sanction Details: RJA WAS FINED $25.00. FINE PAID: 11/15/1973.
Sanctions Ordered: Monetary/Fine $25.00
Decision
Disclosure 106 of 120
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Reporting Source: Regulator
Initiated By: NEW YORK STOCK EXCHANGE
Date Initiated: 12/29/1978
Docket/Case Number: DEC. 78-84
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Other Product Type(s):
Resolution Date: 12/29/1978
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement 12/29/78: NYSE: SUBMITTED A STIPULATION OF FACTS ANDCONSENT TO PENALTY, FOR THE SOLE PURPOSE OF SETTLINGTHIS DISCIPLINARY PROCEEDING AND WITHOUT ADMITTING ORDENYING GUILT, WAS FOUND TO THE ENGAGED IN CONDUCTINCONSISTENT WITH JUST AND EQUITABLE PRINCIPALS OFTRADE. CONSENT TO A CENSURE: AND A FINE OF $4,000.(DEC. 78-74)
Sanctions Ordered: CensureMonetary/Fine $4,000.00
Consent
iReporting Source: Firm
Initiated By: NEW YORK STOCK EXCHANGE
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 12/29/1978
Docket/Case Number: DEC. 78-84
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATE CONVERSION
Allegations: ALLEGED CONDUCT INCONSISTENT WITH JUST AND EQUITABLEPRINCIPALS OF TRADE.
Current Status: Final
Resolution Date: 12/29/1978
Resolution: Consent
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Resolution Date: 12/29/1978
Other Sanctions Ordered:
Sanction Details: SUBMITTED A STIPULATION OF FACTS AND CONSENT TO PENALTY, FORTHE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING ANDWITHOUT ADMITTING OR DENYING GUILT, WAS FOUND TO HAVE ENGAGEDIN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPALS OFTRADE. CONSENTED TO CENSURE AND FINE OF $4,000.00.
Sanctions Ordered: CensureMonetary/Fine $4,000.00
Disclosure 107 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 02/15/1977
Docket/Case Number: AWC-47
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 02/15/1977
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement ON FEBRUARY 15 1977, DISTRICT NO. 7 NOTIFIED RESPONDENT RAYMONDJAMES & ASSOCIATES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVERAND CONSENT NO. AWC-47 WAS ACCEPTED; THEREFORE, THE FIRM WASCENSURED AND FINED $100 - (ARTICLE III, SECTION 1 OF THE RULESOF FAIR PRACTICE - RESPONDENT MEMBER MAINTAINED INACCURATENASDAQ VOLUME REPORTS.
FINES AND COSTS 3/10/77 FC#6777 PAID.
Sanctions Ordered: CensureMonetary/Fine $100.00
Consent
258©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User GuidanceON FEBRUARY 15 1977, DISTRICT NO. 7 NOTIFIED RESPONDENT RAYMONDJAMES & ASSOCIATES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVERAND CONSENT NO. AWC-47 WAS ACCEPTED; THEREFORE, THE FIRM WASCENSURED AND FINED $100 - (ARTICLE III, SECTION 1 OF THE RULESOF FAIR PRACTICE - RESPONDENT MEMBER MAINTAINED INACCURATENASDAQ VOLUME REPORTS.
FINES AND COSTS 3/10/77 FC#6777 PAID.
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 02/15/1977
Docket/Case Number: AWC-47
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: MAINTAINED INACCURATE NASDAQ VOLUME REPORTS.
Current Status: Final
Resolution Date: 02/15/1977
Resolution:
Other Sanctions Ordered:
Sanction Details: VIOLATION OF ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OFFAIR PRACTICE. RJA WAS CENSURED AND FINED $100.00 PLUS COSTS.FINE PAID: 03/10/1977.
Sanctions Ordered: CensureMonetary/Fine $100.00
Consent
Disclosure 108 of 120
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Reporting Source: Regulator
Allegations: IN THE ADMINISTRATIVE COMPLAINT DATED JANUARY28, 1994, THE MASSACHUSETTS SECURITIES DIVISION (MSD) ALLEGEDTHAT CYPRESS EQUIPMENT FUND, RAYMOND JAMES & ASSOCIATES,INVESTMENT MANAGEMENT & RESEARCH, ROBERT THOMAS SECURITIES,WILLIAM HAAS AND STEPHEN COOK SOLD UNREGISTERED NON-EXEMPTSECURITIES OF THE FUND IN VIOLATION OF M.G.L. c.110A SECTION301. THE MSD ALSO ALLEGED THAT RESPONDENTS VIOLATED M.G.L.c.110A SECTION 101 BY FAILING TO DISCLOSE THE SECURITIES' LACKOF REGISTRATION, THAT RESPONDENTS ENGAGED IN DISHONEST ANDUNETHICAL PRACTICES, AND THAT RJA, IM&R AND ROBERT THOMASFAILED TO REASONABLY SUPERVISE THEIR AGENTS.
Current Status: Final
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Initiated By: MASSACHUSETTS SECURITIES DIVISION
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/28/1994
Docket/Case Number: 92-007-E
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
IN THE ADMINISTRATIVE COMPLAINT DATED JANUARY28, 1994, THE MASSACHUSETTS SECURITIES DIVISION (MSD) ALLEGEDTHAT CYPRESS EQUIPMENT FUND, RAYMOND JAMES & ASSOCIATES,INVESTMENT MANAGEMENT & RESEARCH, ROBERT THOMAS SECURITIES,WILLIAM HAAS AND STEPHEN COOK SOLD UNREGISTERED NON-EXEMPTSECURITIES OF THE FUND IN VIOLATION OF M.G.L. c.110A SECTION301. THE MSD ALSO ALLEGED THAT RESPONDENTS VIOLATED M.G.L.c.110A SECTION 101 BY FAILING TO DISCLOSE THE SECURITIES' LACKOF REGISTRATION, THAT RESPONDENTS ENGAGED IN DISHONEST ANDUNETHICAL PRACTICES, AND THAT RJA, IM&R AND ROBERT THOMASFAILED TO REASONABLY SUPERVISE THEIR AGENTS.
Resolution Date: 11/22/1994
Resolution:
Other Sanctions Ordered:
Sanction Details: ON NOVEMBER 22, 1994 RESPONDENTS ENTERED INTO ACONSENT ORDER WITHOUT ADMITTING OR DENYING FINDINGS OF FACTSORCONCLUSIONS OF LAW. RESPONDENT UNDERTOOK THE FOLLOWING:THATTHEY DISCLOSED ALL OFFER AND SALES OF THE FUND IN THECOMMONWEALTH; THAT THE FUND, RJA, IM&R AND ROBERT THOMASDISCLOSED ALL DISCIPLINARY ACTIONS AGAINST THEM REQUIRED TO BEDISCLOSED; RJA, IM&R, AND ROBERT THOMAS WILL REVISE THEIRCOMPLAINCE MANUALS TO REQUIRE AGENTS WHO TRANSACT BUSINESSINSECURITIES IN THE COMMONWELATH TO COMPLY WITH THE ACT; THEFUNDWILL OFFER RESCISSION TO ALL MASSACHUSETTS INVESTORS IN THEFUND; THE FUND, RJA, IM&R AND ROBERT THOMAS WILL IMPLEMENT ANDMAINTAIN PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH THEACT;THE FUND, RJA, IM&R AND ROBERT THOMAS WILL COMPLY WITH ALLPROVISION OF THE ACT. THE ORDER IMPOSED SANCTIONS OF A $5,000FINE EACH UPON BY THE FUND, RJA, IM&R AND ROBERT THOMAS;DISGORGEMENT OF COMMISSIONS BY THE FUND, RJA, IM&R AND ROBERTTHOMAS; AND A BAR UPON THE FUND FROM UTILIZING EXEMPTIONSECTION 402 (b)(9) FOR FIVE YEARS. NO SANCTIONS WERE IMPOSEDUPON HAAS OR COOK.
Sanctions Ordered: Monetary/Fine $5,000.00Disgorgement/Restitution
Consent
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ON NOVEMBER 22, 1994 RESPONDENTS ENTERED INTO ACONSENT ORDER WITHOUT ADMITTING OR DENYING FINDINGS OF FACTSORCONCLUSIONS OF LAW. RESPONDENT UNDERTOOK THE FOLLOWING:THATTHEY DISCLOSED ALL OFFER AND SALES OF THE FUND IN THECOMMONWEALTH; THAT THE FUND, RJA, IM&R AND ROBERT THOMASDISCLOSED ALL DISCIPLINARY ACTIONS AGAINST THEM REQUIRED TO BEDISCLOSED; RJA, IM&R, AND ROBERT THOMAS WILL REVISE THEIRCOMPLAINCE MANUALS TO REQUIRE AGENTS WHO TRANSACT BUSINESSINSECURITIES IN THE COMMONWELATH TO COMPLY WITH THE ACT; THEFUNDWILL OFFER RESCISSION TO ALL MASSACHUSETTS INVESTORS IN THEFUND; THE FUND, RJA, IM&R AND ROBERT THOMAS WILL IMPLEMENT ANDMAINTAIN PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH THEACT;THE FUND, RJA, IM&R AND ROBERT THOMAS WILL COMPLY WITH ALLPROVISION OF THE ACT. THE ORDER IMPOSED SANCTIONS OF A $5,000FINE EACH UPON BY THE FUND, RJA, IM&R AND ROBERT THOMAS;DISGORGEMENT OF COMMISSIONS BY THE FUND, RJA, IM&R AND ROBERTTHOMAS; AND A BAR UPON THE FUND FROM UTILIZING EXEMPTIONSECTION 402 (b)(9) FOR FIVE YEARS. NO SANCTIONS WERE IMPOSEDUPON HAAS OR COOK.
Regulator Statement Not Provided
iReporting Source: Firm
Initiated By: COMMONWEALTH OF MASSACHUSETTS
Principal Sanction(s)/ReliefSought:
Disgorgement
Other Sanction(s)/ReliefSought:
Date Initiated: 01/28/1994
Docket/Case Number: 92-007-E
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: ALLEGES THAT THE INDIVIDUAL RESPONDENTS SOLD AN INSIGNIFICANTAMOUNT OF CYPRESS EQUIPMENT FUND, LD. IN THE STATE OF MA BASEDUPON THE OPINION OF OUTSIDE COUNSEL THAT IT WAS EXEMPT FROMREGISTRATION. THE STATE OF MA SUBSEQUENTLY FILED AN ACTIONALLEGING, AMONG OTHER THINGS THAT CYPRESS EQUIPMENT FUNDWAS NOT PROPERLY REGISTERED NOR ANY EXEMPTION AVAILABLE TOREGISTRATION.
Current Status: Final
Resolution Date: 11/22/1994
Resolution:
Other Sanctions Ordered:
Sanction Details: M/G/L/C.110A SECTION 301; M.G.L.C.110A SECTION 101. RESPONDENTSUNDERTOOK TO DISCLOSE ALL OFFERS & SALES OF THE FUND IN MA, TODISCLOSE ALL DISCIPLINARY ACTIONS REQUIRED TO BE DISCLOSED, TOREVISE COMPLIANCE MANUALS TO REQUIRE AGENTS TO COMPLY WITHMA LAW. TO IMPLEMENT & MAINTAIN PROCEDURES TO ENSURECOMPLIANCE WITH THE ACT. DISGORGEMENT OF COMMISSIONS.RESPONDENTS WERE EACH ORDERED TO PAY A FINE OF $5,000.00. THEPROCEEDING WAS DISMISSED AS TO RESPONDENTS RJA, RTS AND IM&R,AND DISMISSED WITHOUT SANCTIONS AS TO HAAS AND COOK.
Sanctions Ordered: Monetary/Fine $5,000.00Disgorgement/Restitution
Consent
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www.finra.org/brokercheck User GuidanceM/G/L/C.110A SECTION 301; M.G.L.C.110A SECTION 101. RESPONDENTSUNDERTOOK TO DISCLOSE ALL OFFERS & SALES OF THE FUND IN MA, TODISCLOSE ALL DISCIPLINARY ACTIONS REQUIRED TO BE DISCLOSED, TOREVISE COMPLIANCE MANUALS TO REQUIRE AGENTS TO COMPLY WITHMA LAW. TO IMPLEMENT & MAINTAIN PROCEDURES TO ENSURECOMPLIANCE WITH THE ACT. DISGORGEMENT OF COMMISSIONS.RESPONDENTS WERE EACH ORDERED TO PAY A FINE OF $5,000.00. THEPROCEEDING WAS DISMISSED AS TO RESPONDENTS RJA, RTS AND IM&R,AND DISMISSED WITHOUT SANCTIONS AS TO HAAS AND COOK.
Disclosure 109 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 12/10/1992
Docket/Case Number: C05940029
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 03/15/1994
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement ON MARCH 15, 1994, DISTRICT NO. 5 NOTIFIED RAYMOND JAMES &ASSOCIATES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C05940029 WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED AND FINED $2,500 - (ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE - IN CONTRAVENTION OF THE BOARDOF GOVERNORS FREE-RIDING AND WITHHOLDING INTERPRETATION,RESPONDENT MEMBER FAILED TO MAKE A BONA FIDE PUBLICDISTRIBUTION AT THE PUBLIC OFFERING PRICE OF SECURITIES OF APUBLIC OFFERING WHICH LATER TRADED AT A PREMIUM IN THESECONDARY MARKET).
$2,500.00 PAID ON 3/29/94, INVOICE #C0594-0029.
Sanctions Ordered: CensureMonetary/Fine $2,500.00
Consent
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ON MARCH 15, 1994, DISTRICT NO. 5 NOTIFIED RAYMOND JAMES &ASSOCIATES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C05940029 WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED AND FINED $2,500 - (ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE - IN CONTRAVENTION OF THE BOARDOF GOVERNORS FREE-RIDING AND WITHHOLDING INTERPRETATION,RESPONDENT MEMBER FAILED TO MAKE A BONA FIDE PUBLICDISTRIBUTION AT THE PUBLIC OFFERING PRICE OF SECURITIES OF APUBLIC OFFERING WHICH LATER TRADED AT A PREMIUM IN THESECONDARY MARKET).
$2,500.00 PAID ON 3/29/94, INVOICE #C0594-0029.
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 12/10/1992
Docket/Case Number: C05940029
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATE CONVERSION
Allegations: RJA VIOLATED THE "FREE-RIDING AND WITHHOLDING: INTERPRETATIONOF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN CONNECTION WITHTHE SALE OF SECURITIES INVOLVED IN A PUBLIC OFFERING WHICH LATERTRADED AT A PREMIUN IN THE SECONDARY MARKET ("HOT ISSUE").
Current Status: Final
Resolution Date: 03/15/1994
Resolution:
Other Sanctions Ordered:
Sanction Details: RJA ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THEALLEGATIONS, TO THE ENTRY OF FINDINGS BY THE DBCC FOR DISTRICTNO. 5 AND THE NATIONAL BUSINESS CONDUCT COMMITTEE AND ACENSURE AND FINE IN THE AMOUNT OF $2,500.00. DATE PAID: 03/29/1994.NO PART OF THE FINE WAS WAIVED.
Sanctions Ordered: CensureMonetary/Fine $2,500.00
Consent
Disclosure 110 of 120
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Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Allegations:
Current Status: Final
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 03/15/1972
Docket/Case Number: N-V-89
Principal Product Type:
Other Product Type(s):
Resolution Date: 08/24/1972
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement NASDAQ COMPLAINT N-V-89 FILED 03/15/7207/10/72 FINED $2507/20/72 PAID FINE08/24/72 FINAL
Sanctions Ordered: Monetary/Fine $25.00
Decision
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 03/15/1972
Docket/Case Number: N-V-89
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: FAILED TO REPORT ITS NASDAQ VOLUME.
Current Status: Final
Resolution: Decision264©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Resolution Date: 08/24/1972
Resolution:
Other Sanctions Ordered:
Sanction Details: RAYMOND JAMES & ASSOCIATES, INC. ON 07/10/1971 WAS FINED $25.00.FINE PAID: 07/20/1972.
Sanctions Ordered: Monetary/Fine $25.00
Decision
Disclosure 111 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 05/19/1993
Docket/Case Number: CMS930022 A.W.C.
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 05/19/1993
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement MARKET SURVEILLANCE COMPLAINT NO. CMS930022 AWC: THEFOLLOWINGLETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON 5/19/93ALLEGES TRADE REPORTING VIOLATIONS OF SCHEDULE G, SECTION 2;PRICE AND VOLUME REPORTING VIOLATIONS OF SCHEDULE H, SECTION2;ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE, SECTION10b OF THE EXCHANGE ACT OF 1934 AND RULE 10b-10(a)(1) AND(a)(8) RESEPCIVELY THEREUNDER, AND ARTICLE III, SECTINS 1 AND27 OF THE RULES OF FAIR PRACTICE WAS ACCEPTED BY NBCC ON8/26/93. CENSURE AND $7,500 FINE. **$7,500.00 PAID ON 9/13/93 INVOICE #93-MS-676**
Sanctions Ordered: CensureMonetary/Fine $7,500.00
Consent
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MARKET SURVEILLANCE COMPLAINT NO. CMS930022 AWC: THEFOLLOWINGLETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON 5/19/93ALLEGES TRADE REPORTING VIOLATIONS OF SCHEDULE G, SECTION 2;PRICE AND VOLUME REPORTING VIOLATIONS OF SCHEDULE H, SECTION2;ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE, SECTION10b OF THE EXCHANGE ACT OF 1934 AND RULE 10b-10(a)(1) AND(a)(8) RESEPCIVELY THEREUNDER, AND ARTICLE III, SECTINS 1 AND27 OF THE RULES OF FAIR PRACTICE WAS ACCEPTED BY NBCC ON8/26/93. CENSURE AND $7,500 FINE. **$7,500.00 PAID ON 9/13/93 INVOICE #93-MS-676**
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES/FINE(S)
Date Initiated: 05/22/1992
Docket/Case Number: CMS930022 A.W.C.
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: THE MARKET SURVEILLANCE COMMITTEE ALLEGES TRADE REPORTINGVIOLATIONS AND PRICE AND VOLUME VIOLATIONS DURING THE PERIODOF MAY 1, 1992 THROUGH MAY 22, 1992.
Current Status: Final
Resolution Date: 08/26/1993
Resolution:
Other Sanctions Ordered:
Sanction Details: VIOLATIONS OF SCHEDULE G, SECTION 2, SCHEDULE H, SECTION 2 TOTHE ASSOCIATION'S BY-LAWS AND ARTICLE III, SECTION 1 OF THEASSOCIATION'S RULES OF FAIR PRACTICE. RJA ACCEPTED ANDCONSENTED TO THE IMPOSITION OF A CENSURE AND $7,500.00 FINE.FINE PAID 09/13/1993.
Sanctions Ordered: CensureMonetary/Fine $7,500.00
Consent
Disclosure 112 of 120
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Reporting Source: Regulator
Allegations: FAILURE TO DESIGNATED MANAGER, BOOKS ANDRECORDS VIOLATIONS, UNREGISTERED BRANCH OFFICE MANAGER,FAILURETO SUPERVISE.
Current Status: Final
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Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECT*See FAQ #1*
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/29/1991
Docket/Case Number: 1547-S-791
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
Allegations: FAILURE TO DESIGNATED MANAGER, BOOKS ANDRECORDS VIOLATIONS, UNREGISTERED BRANCH OFFICE MANAGER,FAILURETO SUPERVISE.
Resolution Date: 07/29/1991
Resolution:
Other Sanctions Ordered:
Sanction Details: FOLLOWING THE EXECUTION OF A STIPULATION ANDCONSENT AGREEMENT, THE DEPARTMENT ISSUED A FINAL ORDER. FIRMAGREES TO CEASE AND DESIST ALL VIOLATIONS OF THE PROVISIONS OFCHAPTER 517, FLORIDA STATUTES, AGREES TO NOT ENGAGE INPROHIBITED BUSINESS PRACTICES, AND AGREES TO PAY A FINE OF$5,000.00 AND REIMBURSE THE DEPARTMENT FOR THE COST OF THEAUDIT.
Regulator Statement Not Provided
Sanctions Ordered: Monetary/Fine $5,000.00Cease and Desist/Injunction
Consent
iReporting Source: Firm
Initiated By: STATE OF FLORIDA
Allegations: THAT RAYMOND JAMES & ASSOCIATES, INC. AND WILLIAM BROWN, JAMESFEIT, AND WILLIAM BUNN ALLOWED WILLIAM BUNN TO ACT AS MANAGERWITHOUT APPROVAL FROM THE DIVISION.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
MONETARY FINE
Date Initiated: 12/06/1990
Docket/Case Number: 91-187-DOS
Principal Product Type: No Product
Other Product Type(s):
Resolution Date: 07/30/1991
Resolution:
Other Sanctions Ordered:
Sanction Details: BY MUTUAL AGREEMENT WITH THE STATE OF FLORIDA, RJA IS CENSUREDAND AGREED TO PAY A FINE OF $5,000.00. WILLIAM BROWN PAID A FINEOF $1,000.00. WILLIAM BUNN AGREED NOT TO ACT AS A PRINCIPAL FOR APERIOD OF 1 YEAR PROVIDED CERTAIN CONDITIONS WERE MET. BUNN,BROWN AND FEIT WERE ALSO CENSURED. NO PORTION OF THE PENALTYWAS WAIVED.
Sanctions Ordered: CensureMonetary/Fine $5,000.00
Decision
Disclosure 113 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 02/06/1990
Docket/Case Number: MS-902 AWC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Resolution Date: 04/18/1990
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement MARKET SURVEILLANCE COMMITTEE CONDUCT #MS-902 AWC (A): LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 6, 1990AGAINST RESPONDENT RAYMOND JAMES & ASSOCIATES. ALLEGINGVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME. THE LETTEROFACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKETSURVEILLANCE COMMITTEE ON MARCH 13, 1990 AND BY THE NATIONALBUSINESS CONDUCT COMMITTEE ON APRIL 18, 1990. $250 FINE. ***$250.00 PAID ON 5/14/90 INVOICE #90-MS-515***
Sanctions Ordered: Monetary/Fine $250.00
Consent
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 02/06/1990
Docket/Case Number: MS-902-AWC
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATE CONVERSION
Allegations: FAILED TO REPORT ITS NASDAQ VOLUME.
Current Status: Final
Resolution Date: 04/18/1990
Resolution:
Other Sanctions Ordered:
Sanction Details: LETTER OF ACCEPTANCE, WAIVER AND CONSENT. VIOLATION OF PART VI,SECTION 4(A) OF SCHEDULE D. RAYMOND JAMES & ASSOCIATES, INC.WAS FINED $250.00 WHICH WAS PAID ON 05/14/1990.
Sanctions Ordered: Monetary/Fine $250.00
Consent
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Sanction Details: LETTER OF ACCEPTANCE, WAIVER AND CONSENT. VIOLATION OF PART VI,SECTION 4(A) OF SCHEDULE D. RAYMOND JAMES & ASSOCIATES, INC.WAS FINED $250.00 WHICH WAS PAID ON 05/14/1990.
Disclosure 114 of 120
i
Reporting Source: Regulator
Initiated By: CHICAGO BOARD OF OPTION EXCHANGE
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/17/1988
Docket/Case Number: 87-0121(A)
Principal Product Type: Other
Other Product Type(s): UNSPECIFIED TYPE OF FINANCIAL PRODUCT.
Allegations: RAYMOND JAMES & ASSOCIATES, INC., AN EXCHANGE MEMBERORGANIZATION, FAILED ADEQUATELY TO SUPERVISE WILLIAM D.THATCHER, A FORMER REGISTERED REPRESENTATIVE AT RAYMONDJAMES' DAYTONA BEACH, FLORIDA BRANCH OFFICE, BY ALLOWINGTHATCHER TO EFFECT NUMEROUS STOCK AND OPTION TRANSACTIONSON A DISCRETIONARY BASIS IN 10 PUBLIC CUSTOMER ACCOUNTS, WHICHTRANSACTIONS WERE ALSO UNSUITABLE BASED UPON EACHCUSTOMER'S INVESTMENT EXPERIENCE, INVESTMENT OBJECTIVES,ABILITY TO BEAR THE RISKS ASSOCIATED WITH THE INVESTMENTS, ANDSIZE AND FREQUENCY OF THE TRANSACTIONS. IN ADDITION, RAYMONDJAMES FAILED ADEQUATELY TO SUPERVISE THATCHER BY ALLOWINGTHATCHER TO EFFECT A PURCHASE OF RAYMOND JAMES COMMONSTOCK ON A DISCRETIONARY BASIS IN 2 PUBLIC CUSTOMER ACCOUNTSWHICH RESULTED IN A CONFLICT OF INTEREST DUE TO THATCHER'SASSOCIATION WITH RAYMOND JAMES. FURTHER, DURING A 3 MONTHPERIOD, RAYMOND JAMES FAILED TO PROVIDE ITS CUSTOMERS WITHMARKET-TO-MARKET PRICE AND MARKETVALUE OF EACH OPTION POSITION HELD IN THEIR ACCOUNTS.FINALLY RAYMOND JAMES FAILED ADEQUATELY TO SUPERVISE WILLIAMF. O'ROURKE, THE BRANCH OFFICE MANAGER RESPONSIBLE FOR THATOFFICE.
Current Status: Final
Resolution Date: 10/17/1988
Resolution: Settled
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Other Sanctions Ordered:
Sanction Details: IN CONNECTION WITH THE CONDUCT DESCRIBED ABOVE.SANCTION: A CENSURE AND A $10,000 FINE. THIS CASE WAS RESOLVED BYAN OFFER OF SETTLEMENT WHEREBY THE RESPONDENT DID NOT ADMITOR DENY THAT CBOE/SEC RULES HAD BEEN VIOLATED. DOCKET/CASE NO.87-0121(A), DATED OCTOBER 17, 1988.
Sanctions Ordered: CensureMonetary/Fine $10,000.00
iReporting Source: Firm
Initiated By: CHICAGO BOARD OF OPTION EXCHANGE
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 01/12/1988
Docket/Case Number: 87-0121(2) & (C)
Principal Product Type: Equity Listed (Common & Preferred Stock)
Other Product Type(s): FINANCIAL OPTIONS
Allegations: ALLEGE RJA FAILED TO SUPERVISE WILLIAM D. THATCHER BY ALLOWINGTHATCHER TO EFFECT NUMEROUS STOCK AND OPTION TRANSACTIONSON A DISCRETIONARY BASIS WITHOUT PRIOR WRITTEN AUTHORIZATIONAND APPROVAL.
Current Status: Final
Resolution Date: 10/17/1988
Resolution:
Other Sanctions Ordered:
Sanction Details: THE COMMITTEE DETERMINED TO ACCEPT THE RESPONDENT'S OFFEROS SETTLEMENT BASED UPON ITS CONCLUSIONS OF VIOLATIONS OFEXCHANGE RULES 4.2, 9.8 AND 9.12. RJA CONSENTS TO A CENSURE AND$10,000.00 FINE WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.
Sanctions Ordered: CensureMonetary/Fine $10,000.00
Consent
Disclosure 115 of 120
i
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Disclosure 115 of 120
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/19/1988
Docket/Case Number: MS-703-AWC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 08/11/1988
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-703-AWC:
LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED APRIL 19,1988 AGAINST RESPONDENT RAYMOND JAMES & ASSOCIATES, INC.ALLEGING VIOLATIONS OF PART VI, SECTION 4(a) OF SCHEDULE D INTHAT RESPONDENT FAILED TO REPORTS ITS NASDAQ VOLUME.
THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JUNE 28, 1988 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON AUGUST 11, 1988. $500FINE
$500 FINE PAID 9/2/88
Sanctions Ordered: Monetary/Fine $500.00
Consent
iReporting Source: Firm
Allegations: ALLEGING VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRJA FAILED TO REPORT ITS NASDAQ VOLUME.
Current Status: Final
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 04/19/1988
Docket/Case Number: MS-703-AWC
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: ALLEGING VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRJA FAILED TO REPORT ITS NASDAQ VOLUME.
Resolution Date: 08/11/1988
Resolution:
Other Sanctions Ordered:
Sanction Details: LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THEMARKET SURVEILLANCE COMMITTEE ON JUNE 28, 1988 AND BY THE NBCCON AUGUST 11, 1988. $500.00 FINE WHICH WAS PAID: 09/02/1988.
Sanctions Ordered: Monetary/Fine $500.00
Consent
Disclosure 116 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 12/02/1987
Docket/Case Number: MS-643-AWC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Resolution Date: 02/22/1988
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-643-AWC:
LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILEDDECEMBER2, 1987 AGAINST RESPONDENT RAYMOND, JAMES & ASSOCIATES, INC.ALLEGING VIOLATIONS OF PART VI, SECTION 4(a) OF SCHEDULE D INTHAT RESPONDENT FAILED TO REPORT ITS NASDAQ VOLUME.
THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEEONFEBRUARY 4, 1988 AND BY THE NATIONAL BUSINESS CONDUCTCOMMITTEEON FEBRUARY 22, 1988. $500 FINE
$500 FINE PAID 12/23/87
Sanctions Ordered: Monetary/Fine $500.00
Consent
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 12/03/1987
Docket/Case Number: MS-643-AWC
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: FAILED TO REPORT ITS NASDQ VOLUME.
Current Status: Final
Resolution Date: 02/22/1988
Resolution: Consent
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Resolution Date: 02/22/1988
Other Sanctions Ordered:
Sanction Details: VIOLATIONS OF PART VI, SECTION 4(A) OF THE ASSOCIATION'S RULES OFFAIR PRACTICE. FINED RJA $500.00. PAID: 12/23/1987.
Sanctions Ordered: Monetary/Fine $500.00
Disclosure 117 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/21/1986
Docket/Case Number: MS-437
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 05/12/1987
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement MARKET SURVEILLANCE COMMITTEE #MS-437:
COMPLAINT FILED ON OCTOBER 21, 1986 BY THE MARKET SURVEILLANCECOMMITTEE (COMMITTEE) NAMING AS RESPONDENTS RAYMOND, JAMESANDASSOCITES, INC. (RAJA), FRED T. LUGINSLAND (LUGINSLAND ANDHARVEY HERTZ (HERTZ).
THE COMPLAINT CONTAINS SIX SEPERATE CAUSES. THE FIRST FIVECUASES RELATE TO THE DIVIDING OF ORDERS INTO SMALLER PARTS(ORDER SPLITTING) FOR THE PURPOSE OF SOES EXECUTION, INVIOLATION OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE. LUGINSLAND IS NAMED IN CAUSES ONE, TWO AND THREE AND HERTZIS NAMED IN CAUSES ONE, TWO FOUR AND FIVE.
THE SIXTH CAUSE OF COMPLAINT CHARGES RAJA WITH VIOLATIONS OFARTICLE III, SECTIONS 1 AND 27 FOR A FAILURE TO ESTABLISH,MAINTAIN AND ENFORCE WRITTEN PROCEDURES WHICH WOULD HAVEENABLED IT TO PROPERLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH THE RULES RELATIVE TOTHE VIOLATIONS ALLEGED IN THE FIRST FIVE CAUSES OF COMPLAINT.
ALL THREE RESPONDENTS SUBMITTED OFFERS OF SETTLEMENT(OFFERS)WHICH WERE ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ONAPRIL 9, 1987 AND BY THE NBCC ON MAY 12, 1987. UNDER THE TERMSOF THE OFFERS, EACH RESPONDENT IS CENSURED AND FINED $5,750FORWHICH THEY ARE JOINTLY AND SEVERALLY LIABLE.
NFC #240-$5000.00 PAID 6/30/87, $750.00 PAID 9/2/87.
Sanctions Ordered: CensureMonetary/Fine $5,750.00
Consent
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MARKET SURVEILLANCE COMMITTEE #MS-437:
COMPLAINT FILED ON OCTOBER 21, 1986 BY THE MARKET SURVEILLANCECOMMITTEE (COMMITTEE) NAMING AS RESPONDENTS RAYMOND, JAMESANDASSOCITES, INC. (RAJA), FRED T. LUGINSLAND (LUGINSLAND ANDHARVEY HERTZ (HERTZ).
THE COMPLAINT CONTAINS SIX SEPERATE CAUSES. THE FIRST FIVECUASES RELATE TO THE DIVIDING OF ORDERS INTO SMALLER PARTS(ORDER SPLITTING) FOR THE PURPOSE OF SOES EXECUTION, INVIOLATION OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE. LUGINSLAND IS NAMED IN CAUSES ONE, TWO AND THREE AND HERTZIS NAMED IN CAUSES ONE, TWO FOUR AND FIVE.
THE SIXTH CAUSE OF COMPLAINT CHARGES RAJA WITH VIOLATIONS OFARTICLE III, SECTIONS 1 AND 27 FOR A FAILURE TO ESTABLISH,MAINTAIN AND ENFORCE WRITTEN PROCEDURES WHICH WOULD HAVEENABLED IT TO PROPERLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH THE RULES RELATIVE TOTHE VIOLATIONS ALLEGED IN THE FIRST FIVE CAUSES OF COMPLAINT.
ALL THREE RESPONDENTS SUBMITTED OFFERS OF SETTLEMENT(OFFERS)WHICH WERE ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ONAPRIL 9, 1987 AND BY THE NBCC ON MAY 12, 1987. UNDER THE TERMSOF THE OFFERS, EACH RESPONDENT IS CENSURED AND FINED $5,750FORWHICH THEY ARE JOINTLY AND SEVERALLY LIABLE.
NFC #240-$5000.00 PAID 6/30/87, $750.00 PAID 9/2/87.
iReporting Source: Firm
Initiated By: NATIONAL ASOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 10/21/1986
Docket/Case Number: MS-437
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: THE MARKET SURVEILLANCE COMMITTEE ALLEGES VIOLATIONS OFARTICLE III, SECTION 1 AND 27 OF THE ASSOCIATION'S RULES OF FAIRPRACTICE, AND FAILURE TO PROPERLY SUPERVISE.
Current Status: Final
Resolution Date: 05/12/1987
Resolution: Consent
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Resolution Date: 05/12/1987
Other Sanctions Ordered:
Sanction Details: RJA, HARVEY HERTZ AND FRED T. LUGINSLAND WERE CENSURED ANDJOINTLY AND SEVERALLY LIABLE FOR A FINE OF $5,750.00. FINE PAID09/02/1987.
Sanctions Ordered: Monetary/Fine $5,750.00
Disclosure 118 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/23/1986
Docket/Case Number: MS-311-AWC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 04/23/1986
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement 7/3/86: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-311-AWC:LETTER OF ACCEPTANCE, WAIVER AND CONSENT ISSUED ON APRIL 23,1986, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULED OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENT FAILED TOREPORT ITS NASDAQ VOLUME IN FIVE SECURITIES ON 9/5/85, NINESECURITIES ON 2/3/86, AND TWENTY SECURITIES ON 2/10/86. AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 5/20/86 ANDBYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON 6/24/86. $250 FINE
Sanctions Ordered: Monetary/Fine $250.00
Consent
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7/3/86: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-311-AWC:LETTER OF ACCEPTANCE, WAIVER AND CONSENT ISSUED ON APRIL 23,1986, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULED OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENT FAILED TOREPORT ITS NASDAQ VOLUME IN FIVE SECURITIES ON 9/5/85, NINESECURITIES ON 2/3/86, AND TWENTY SECURITIES ON 2/10/86. AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 5/20/86 ANDBYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON 6/24/86. $250 FINE
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
MONETARY PENALTY(IES)/FINE(S)
Date Initiated: 04/23/1986
Docket/Case Number: MS-311-AWC
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: BY MARKET SURVEILLANCE COMMITTEE - FAILED TO REPORT ITS NASDAQVOLUME.
Current Status: Final
Resolution Date: 08/28/1986
Resolution:
Other Sanctions Ordered:
Sanction Details: RJA CONSENTED TO A FINE OF $250.00.
Sanctions Ordered: Monetary/Fine $250.00
Consent
Disclosure 119 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Date Initiated: 04/15/1983
Docket/Case Number: ATL-707-SC
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Resolution Date: 06/24/1983
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement NASD COMPLAINT #ATL-707-SC, FILED 4/15/83 NAMING RAYMOND,JAMES &ASSOCIATES, INC. AND HARVEY HERTZ ALLEGING VIOLATION OF SECTIONI ARTICLE III OF THE RULES OF FAIR PRACTICE. ************SUMMARY COMPLAINT ACCEPTED MAY 11, 1983 WHEREIN RESPONDENTSARECENSURED AND FINED $250.00, JOINTLY AND SEVERALLY. IF NO FURTHERACTION, DECISION IS FINAL JUNE 24, 1983.******JUNE 24, 1983 -DECISION IS FINAL. *********** $250.00 PAID J&S 5-18-83.
Sanctions Ordered: CensureMonetary/Fine $250.00
Decision
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 04/15/1983
Docket/Case Number: ATL-707-SC
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: ALLEGES VIOLATION OF SECTION 1, ARTICLE III OF THE ASSOCIATION'SRULES OF FAIR PRACTICE WITH RESPECT TO FREE-RIDING ANDWITHHOLDING REGARDING "HOT ISSUE".
Current Status: Final
Resolution Date: 06/24/1983
Resolution: Decision
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Resolution Date: 06/24/1983
Other Sanctions Ordered:
Sanction Details: ON 05/11/83 A PENALTY OF CENSURE AGAINST EACH RESPONDENT ANDJOINT FINES OF $250.00 WERE LEVIED. FINEW WERE PAID 05/18/1983.
Sanctions Ordered: CensureMonetary/Fine $250.00
Disclosure 120 of 120
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/29/1965
Docket/Case Number: ATL-329
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 06/13/1965
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement COMPLAINT NO. ATL-329 FILED JANUARY 29, 1965 AGAINST RAYMONDJAMES & ASSOCIATES, INC. ALLEGING VIOLATIONS OF ARTICLE III,SECION 1 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTMEMBER PREPARED SALES LITERATURE AND CORRESPONDENCEDESIGNED TOINDUCE THE PURCHASE OF INVESTMENT COMPANIES SHARES THATFAILEDTO COMPLY WIHT THE SEC STATEMENT OF POLICY.
DECISION RENDERED MAY 14, 1965 WHEREIN RESPONDENT MEMBER ISCENSURED, FINED $250 AND ASSESSED COSTS OF THE PROCEEDINGS INTHE AMOUNT OF $16.00. IF NO FURTHER ACTION, DECISION IS FINALJUNE 13, 1965.
JUNE 13, 1965 - DECISION IS FINAL. ASSESSED COSTS $16. PD. FC
Sanctions Ordered: CensureMonetary/Fine $250.00
Decision
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COMPLAINT NO. ATL-329 FILED JANUARY 29, 1965 AGAINST RAYMONDJAMES & ASSOCIATES, INC. ALLEGING VIOLATIONS OF ARTICLE III,SECION 1 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTMEMBER PREPARED SALES LITERATURE AND CORRESPONDENCEDESIGNED TOINDUCE THE PURCHASE OF INVESTMENT COMPANIES SHARES THATFAILEDTO COMPLY WIHT THE SEC STATEMENT OF POLICY.
DECISION RENDERED MAY 14, 1965 WHEREIN RESPONDENT MEMBER ISCENSURED, FINED $250 AND ASSESSED COSTS OF THE PROCEEDINGS INTHE AMOUNT OF $16.00. IF NO FURTHER ACTION, DECISION IS FINALJUNE 13, 1965.
JUNE 13, 1965 - DECISION IS FINAL. ASSESSED COSTS $16. PD. FC
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
OTHER FINANCIAL
Date Initiated: 01/29/1965
Docket/Case Number: ATL-329
Principal Product Type: Other
Other Product Type(s): UNKNOWN - CRD DATA CONVERSION
Allegations: SALES MATERIAL NOT CONFORMING TO SEC STATEMENT OF POLICY.
Current Status: Final
Resolution Date: 06/13/1965
Resolution:
Other Sanctions Ordered: OTHER FINANCIAL: $16.00
Sanction Details: RJA WAS CENSURED AND FINED $250.00 PLUS COSTS OF $16.00.
Sanctions Ordered: CensureMonetary/Fine $250.00
Decision
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Regulatory - Pending
This type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.
Disclosure 1 of 1
Reporting Source: Regulator
Initiated By: NYSE AMERICAN LLC
Principal Sanction(s)/ReliefSought:
Date Initiated: 04/27/2018
Docket/Case Number: 2014040982001
Principal Product Type: Options
Other Product Type(s):
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT (LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELYREPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223INSTANCES.THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONSPRIMARILY RESULTED FROM: ITS ENTRY OF AN INCORRECT EFFECTIVEDATE WHEN SUBMITTING CERTAIN POSITIONS TO THE LOPR; AND ITSFAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLEOPTIONS POSITIONS AS ACTING IN-CONCERT.
THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTINGOF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPRSUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTSACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRMALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITHRESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS,INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER,FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017. REASONABLEWSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THE IDENTIFICATION OF THEINDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; (II) THE SUPERVISORYSTEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR;(III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW SUCH REVIEWSSHALL BE DOCUMENTED.
Current Status: Pending
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Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH$200,000 SHALL BE PAID TO THE EXCHANGE. THE FIRM WAS REQUIRED TOSUBMIT A WRITTEN REPORT WHICH CONFIRMS THAT IT HAS COMPLETEDREMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED IN THE AWC WITHIN120 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC.THE BALANCE OF THE FIRM'S FINE WILL BE PAID TO NYSE ARCA, INC.,PURSUANT TO A SEPARATE SETTLEMENT AGREEMENT.THIS AWC SHALL BECOME FINAL ON JUNE 9, 2018.
Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISIONOF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TOCONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTINGSYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESEFINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADETO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORYPRACTICES AND PROCEDURES.CASE # 20140409820 (INCL. MERGED CASE NO. 20150455242
Sanctions Ordered:
iReporting Source: Firm
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT(LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM: ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN POSITIONS TOTHE LOPR; AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITSREPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLESUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONSPOSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONSWITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKEDANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TOTHE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMSOF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVEADEQUATE WSPS UNTIL JANUARY 2017.REASONABLE WSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THEIDENTIFICATION OF THE INDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION;(II) THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THEAPPROPRIATE SUPERVISOR; (III) THE FREQUENCY OF SUCH REVIEWS;AND (IV) HOW SUCH REVIEWS SHALL BE DOCUMENTED.
Current Status: Pending
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Initiated By: NYSE AMERICAN LLC
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/27/2018
Docket/Case Number: 2014040982001
Principal Product Type: Options
Other Product Type(s):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT(LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, ANDINACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPRREPORTING VIOLATIONS PRIMARILY RESULTED FROM: ITS ENTRY OF ANINCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN POSITIONS TOTHE LOPR; AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITSREPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLESUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONSPOSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONSWITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKEDANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TOTHE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMSOF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVEADEQUATE WSPS UNTIL JANUARY 2017.REASONABLE WSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THEIDENTIFICATION OF THE INDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION;(II) THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THEAPPROPRIATE SUPERVISOR; (III) THE FREQUENCY OF SUCH REVIEWS;AND (IV) HOW SUCH REVIEWS SHALL BE DOCUMENTED.
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH$200,000 SHALL BE PAID TO THE EXCHANGE. THE FIRM WAS REQUIRED TOSUBMIT A WRITTEN REPORT WHICH CONFIRMS THAT IT HAS COMPLETEDREMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED IN THE AWC WITHIN120 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC. THEBALANCE OF THE FIRM'S FINE WILL BE PAID TO NYSE ARCA,INC.,PURSUANT TO A SEPARATE SETTLEMENT AGREEMENT. THIS AWC SHALLBECOME FINAL ON JUNE 9,2018.
Firm Statement IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISIONOF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TOCONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTINGSYSTEMS,PRACTICES, AND PROCEDURES, AND TO REPORT THESEFINDINGS TO FINRA; AND (II) THE EFFORTS ANDENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, ANDSUPERVISORY PRACTICES AND PROCEDURES. CASE # 20140409820 (INCL.MERGED CASE NO. 20150455242)
Sanctions Ordered:
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IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISIONOF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BYRETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TOCONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTINGSYSTEMS,PRACTICES, AND PROCEDURES, AND TO REPORT THESEFINDINGS TO FINRA; AND (II) THE EFFORTS ANDENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, ANDSUPERVISORY PRACTICES AND PROCEDURES. CASE # 20140409820 (INCL.MERGED CASE NO. 20150455242)
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Arbitration Award - Award / Judgment
Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.
Disclosure 1 of 73
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/28/2000
00-02925
ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-EXECUTIONPRICE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$2,537.50
AWARD AGAINST PARTY
05/18/2001
$87.50
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 2 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
NASD
02/15/2001
01-00494
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$336,703.21 286©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
$336,703.21
AWARD AGAINST PARTY
04/08/2002
$47,300.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 3 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
03/06/2001
01-01043
ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$500,000.00
AWARD AGAINST PARTY
03/21/2002
$185,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 4 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
NASD
04/05/2001
01-01632
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NOOTHER CONTROVERSY INVOLVED
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Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
01-01632
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS
$50,000.00
AWARD AGAINST PARTY
02/11/2002
$880.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 5 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
10/24/2001
01-05256
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; DO NOT USE-NOOTHER CONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$13,000,000.00
AWARD AGAINST PARTY
12/08/2004
$432,014.77
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 6 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
NASD
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE
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Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
04/08/2002
02-01864
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUALFUNDS
$1,205,495.94
AWARD AGAINST PARTY
10/01/2003
$310,610.56
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 7 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/03/2002
02-02874
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$40,592.86
AWARD AGAINST PARTY
05/27/2003
$30,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 8 of 73
i
Reporting Source: Regulator
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Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
05/28/2002
02-02906
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NOOTHER CONTROVERSY INVOLVED
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
Unspecified Damages
AWARD AGAINST PARTY
04/10/2003
$3,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 9 of 73
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/24/2002
02-03893
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE
ANNUITIES; COMMON STOCK; MUTUAL FUNDS; OTHER TYPES OFSECURITIES
$2,595,000.00
AWARD AGAINST PARTY
10/14/2004
$130,500.01
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
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Disclosure 10 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/22/2002
02-04717
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
Unspecified Damages
AWARD AGAINST PARTY
04/29/2004
$45,300.01
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 11 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
09/25/2002
02-04989
DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$400,000.00
AWARD AGAINST PARTY
02/19/2004
$395,965.00
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There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 12 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
11/14/2002
02-06610
ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$266,286.75
AWARD AGAINST PARTY
12/18/2003
$198,285.74
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 13 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
NASD
04/15/2003
02-07764
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$1,000,000.00
AWARD AGAINST PARTY
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Disposition Date:
Sum of All Relief Awarded:
10/13/2004
$290,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 14 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
06/04/2003
03-03225
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$10,853.00
AWARD AGAINST PARTY
01/02/2004
$11,277.79
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 15 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
NASD
06/09/2004
04-03717
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS
293©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
AWARD AGAINST PARTY
09/30/2005
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 16 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/09/2006
06-03601
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$650,000.00
AWARD AGAINST PARTY
06/19/2007
$39,375.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 17 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
FINRA
04/01/2008
08-00750
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE
294©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
08-00750
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$13,458.13
AWARD AGAINST PARTY
11/12/2008
$13,670.63
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 18 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
04/07/2008
08-00988
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$700,000.00
AWARD AGAINST PARTY
04/29/2009
$48,879.25
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 19 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE
295©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
02/26/2009
09-00137
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES
$4,200,000.00
AWARD AGAINST PARTY
02/01/2011
$250,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 20 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
02/24/2009
09-00826
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE
AUCTION RATE SECURITIES; DO NOT USE-NO OTHER TYPE OF SECINVOLVE
$1,400,000.00
AWARD AGAINST PARTY
08/20/2010
$925,000.01
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 21 of 73
i
296©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
06/11/2009
09-03324
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE
AUCTION RATE SECURITIES
$125,000.00
AWARD AGAINST PARTY
07/01/2010
$90,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 22 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
07/13/2009
09-03475
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER
AUCTION RATE SECURITIES
$12,000,000.00
AWARD AGAINST PARTY
07/19/2010
$0.00297©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Sum of All Relief Awarded: $0.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 23 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
09/17/2009
09-04932
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY
AUCTION RATE SECURITIES
$5,400,000.00
AWARD AGAINST PARTY
11/10/2010
$0.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 24 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
FINRA
11/30/2010
10-04885
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER
AUCTION RATE SECURITIES
298©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
$518,203.70
AWARD AGAINST PARTY
05/24/2012
$518,203.70
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 25 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
08/13/2012
12-02272
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-BREACH OF CONTRACT
COMMON STOCK
$1,500,000.03
AWARD AGAINST PARTY
06/21/2013
$707,350.66
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 26 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Allegations:
FINRA
12/04/2012
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; TRADINGDISPUTES-MANIPULATION
299©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
12/04/2012
12-03949
COLLATERALIZED MORTGAGE OBLIGATIONS
$13,000,000.00
AWARD AGAINST PARTY
06/09/2015
$10,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 27 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
02/28/2013
13-00131
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE
COMMON STOCK; MUTUAL FUNDS
$47,444.29
AWARD AGAINST PARTY
11/27/2013
$39,802.69
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 28 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
FINRA
ACCOUNT RELATED-OTHER
300©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
05/02/2013
13-01233
AWARD AGAINST PARTY
11/08/2013
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 29 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
07/11/2014
14-02056
ACCOUNT ACTIVITY-CHURNING
$2,006,596.00
AWARD AGAINST PARTY
02/24/2017
$761,770.97
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 30 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
FINRA
ACCOUNT RELATED-BREACH OF CONTRACT
301©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
08/15/2014
14-02440
COMMON STOCK
$36,138.00
AWARD AGAINST PARTY
04/30/2015
$12,146.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 31 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
09/15/2015
15-02267
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT
ANNUITIES; COMMON STOCK
Unspecified Damages
AWARD AGAINST PARTY
03/21/2017
$500,375.01
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 32 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; EXECUTIONS-EXECUTION ERROR
302©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
10/20/2016
16-02930
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; EXECUTIONS-EXECUTION ERROR
COMMON STOCK
$2,741,160.86
AWARD AGAINST PARTY
12/05/2017
$162,820.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 33 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
FINRA
11/03/2016
16-03199
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE;ACCOUNT RELATED-OTHER
401(K); COMMON STOCK; LIMITED PARTNERSHIPS; OTHER TYPES OFSECURITIES
$1,800,000.01
AWARD AGAINST PARTY
02/09/2018
$254,250.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
303©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Disclosure 34 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/05/1988
88-01940
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$72,000.00
AWARD AGAINST PARTY
05/23/1991
$43,896.38
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 35 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
01/01/1988
88-03619
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$21,200.00
AWARD AGAINST PARTY
01/24/1990
$7,000.00
304©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 36 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/31/1989
88-03886
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$935,460.00
AWARD AGAINST PARTY
04/24/1991
$22,914.23
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 37 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
NASD
01/01/1989
89-00427
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS
Unspecified Damages
AWARD AGAINST PARTY
06/12/1990 305©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Disposition Date:
Sum of All Relief Awarded:
06/12/1990
$3,400.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 38 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
01/01/1989
89-00800
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS
$3,750.00
AWARD AGAINST PARTY
06/12/1990
$7,600.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 39 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
NASD
01/01/1989
89-00801
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS
$16,550.00 306©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
$16,550.00
AWARD AGAINST PARTY
06/12/1990
$19,100.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 40 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
01/01/1989
89-00802
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS
$4,000.00
AWARD AGAINST PARTY
06/12/1990
$7,800.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 41 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
NASD
08/27/1990
90-02329
DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-COMPENSATION; EMPLOYMENT-OTHER
307©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
90-02329
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$432,000.00
AWARD AGAINST PARTY
07/11/1991
$77,500.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 42 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
11/19/1990
90-02424
ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATEINVESTMENT TRUST
$60,312.00
AWARD AGAINST PARTY
09/30/1991
$32,508.60
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 43 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
NASD
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; UNKNOWN TYPE OF CONTROVERSIES
308©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
12/07/1990
90-03355
LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES
$7,196.00
AWARD AGAINST PARTY
10/31/1991
$7,075.25
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 44 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
06/28/1991
91-01248
ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;UNKNOWN TYPE OF CONTROVERSIES
OPTIONS; UNKNOWN TYPE OF SECURITIES
$65,000.00
AWARD AGAINST PARTY
03/03/1992
$16,274.50
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 45 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY
309©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
11/05/1991
91-03261
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY
COMMON STOCK; LIMITED PARTNERSHIPS; MUTUAL FUNDS; OPTIONS
$1,376,653.00
AWARD AGAINST PARTY
06/16/1993
$219,329.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 46 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
05/22/1992
92-00881
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS;OPTIONS; STOCK INDEX FUTURES
$374,000.00
AWARD AGAINST PARTY
12/29/1992
$5,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 47 of 73
i
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Disclosure 47 of 73
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/31/1992
92-02872
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS
$5,000.00
AWARD AGAINST PARTY
05/11/1993
$5,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 48 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/10/1993
93-02886
ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS
$3,455.20
AWARD AGAINST PARTY
05/26/1994
$3,455.20
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
311©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Disclosure 49 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
12/27/1993
93-04855
ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$500,000.01
AWARD AGAINST PARTY
10/17/1996
$115,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 50 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
01/25/1994
94-00235
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE
$300,000.00
AWARD AGAINST PARTY
12/05/1995
$169,302.00
312©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 51 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
03/25/1994
94-00804
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENTSECURITIES; LIMITED PARTNERSHIPS
$1,863,138.00
AWARD AGAINST PARTY
07/13/1996
$11,471.63
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 52 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
NASD
03/24/1994
94-00862
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$50,000.00
AWARD AGAINST PARTY313©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Disposition:
Disposition Date:
Sum of All Relief Awarded:
AWARD AGAINST PARTY
08/08/1995
$67,500.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 53 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
06/07/1994
94-00877
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$342,000.00
AWARD AGAINST PARTY
11/16/1995
$119,296.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 54 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
NASD
11/02/1994
94-03316
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE 314©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$25,000.00
AWARD AGAINST PARTY
06/14/1996
$6,615.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 55 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
02/13/1995
95-00230
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS; REAL ESTATE INVESTMENT TRUST
$100,001.00
AWARD AGAINST PARTY
08/09/1996
$165,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 56 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Allegations:
NASD
04/05/1995
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED
315©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
04/05/1995
95-00817
ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE
$5,100.00
AWARD AGAINST PARTY
10/05/1995
$67.50
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 57 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
04/25/1995
95-01847
ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$251,953.79
AWARD AGAINST PARTY
12/15/1997
$10,750.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 58 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE 316©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/20/1995
95-03212
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES
$15,339.15
AWARD AGAINST PARTY
08/02/1996
$17,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 59 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
08/03/1995
95-03735
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES
$579,000.00
AWARD AGAINST PARTY
05/21/1997
$125,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 60 of 73
i
317©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
09/19/1995
95-04412
DO NOT USE-NO OTHER CONTROVERSY INVOLVED; DO NOT USE-OTHER-OTHER ; OTHER-CLEARING DISPUTES; TRADING DISPUTES-OTHER
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES
$75,335.50
AWARD AGAINST PARTY
01/10/1997
$75,335.50
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 61 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
04/18/1996
96-00988
ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE;DO NOT USE-NO OTHER CONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$43,454.77
AWARD AGAINST PARTY
06/13/1997
$43,454.77
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
318©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Disclosure 62 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
05/03/1996
96-01571
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$14,400.00
AWARD AGAINST PARTY
06/12/1997
$13,123.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 63 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
NASD
11/14/1996
96-01860
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS
$306,157.18
AWARD AGAINST PARTY
05/28/1999
319©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Sum of All Relief Awarded: $58,600.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 64 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/30/1996
96-02817
ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$1,000,000.00
AWARD AGAINST PARTY
05/30/1997
$0.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 65 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
NASD
08/28/1996
96-03229
ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$1,000,000.00
320©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Disposition:
Disposition Date:
Sum of All Relief Awarded:
AWARD AGAINST PARTY
03/19/1998
$1,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 66 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
02/27/1997
96-04386
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$28,560.00
AWARD AGAINST PARTY
10/08/1997
$3,200.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 67 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
NASD
02/12/1997
97-00052
ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE
321©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
97-00052
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES
$17,000.00
AWARD AGAINST PARTY
02/24/1998
$12,500.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 68 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
05/07/1997
97-01823
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$7,000.00
AWARD AGAINST PARTY
12/10/1997
$75.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 69 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
NASD
ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
322©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
06/19/1998
98-02107
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$58,052.30
AWARD AGAINST PARTY
10/20/1999
$40,000.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 70 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
11/17/1998
98-04207
ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES
$82,430.00
AWARD AGAINST PARTY
03/24/2000
$78,356.03
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 71 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
323©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
05/03/1999
99-01630
ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$5,000,000.00
AWARD AGAINST PARTY
03/21/2000
$397,508.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 72 of 73
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
12/31/1999
99-05560
ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE
$25,059.00
AWARD AGAINST PARTY
04/18/2000
$1,584.00
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 73 of 73
i
324©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
01/12/2000
99-05614
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING
COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITEDPARTNERSHIPS; PREFERRED STOCK
Unspecified Damages
AWARD AGAINST PARTY
06/28/2001
$39,345.07
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
325©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
www.finra.org/brokercheck User Guidance
End of Report
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326©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.
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