fmsbonds, inc.fmsbonds, inc. crd# 7793 sec# 8-23280 main office location 4775 technology way boca...

BrokerCheck Report

FMSBONDS, INC.

Section Title

Report Summary

Firm History

CRD# 7793

1

8

Firm Profile 2 - 7

Page(s)

Firm Operations 9 - 14

Disclosure Events 15

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FMSBONDS, INC.

CRD# 7793

SEC# 8-23280

Main Office Location

4775 TECHNOLOGY WAYBOCA RATON, FL 33431Regulated by FINRA Florida Office

Mailing Address

4775 TECHNOLOGY WAYBOCA RATON, FL 33431

Business Telephone Number

800-741-1103

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 11

Arbitration 2

Firm Profile

This firm is classified as a corporation.

This firm was formed in Florida on 08/11/1978.

Its fiscal year ends in June.

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 11 types of businesses.

This firm is not affiliated with any financial orinvestment institutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 52 U.S. states and territories

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1©2021 FINRA. All rights reserved. Report about FMSBONDS, INC.

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This firm is classified as a corporation.

This firm was formed in Florida on 08/11/1978.

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 June.

FMSBONDS, INC.

SEC#

7793

8-23280

Main Office Location

Mailing Address

Business Telephone Number

Doing business as FMSBONDS, INC.

800-741-1103

Regulated by FINRA Florida Office



Other Names of this Firm

Name Where is it used

FMS BONDS AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VT, WA, WI,WV, WY


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FMS BONDS, INC. AK, AK, AL, AL, AR,AR, AZ, AZ, CA, CA,CO, CO, CT, CT, DC,DC, DE, DE, FL, FL,GA, GA, HI, HI, IA,IA, ID, ID, IL, IL, IN,IN, KS, KS, KY, KY,LA, LA, MA, MA, MD,MD, ME, ME, MI, MI,MN, MN, MO, MO,MS, MS, MT, MT, NC,NC, ND, ND, NE, NE

FMS,INC. FL

FMSBONDS.COM AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VT, WA, WI,WV, WY

TAX-FREE BONDS AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VT, WA, WI,WV, WY

TAX-FREE BONDS.COM AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VT, WA, WI,WV, WY


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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?

FEINSILVER, PAUL

CHAIRMAN OF THE BOARD

50% but less than 75%

No

Individual

08/1978

Yes

500389

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


KLOTZ, JAMES ARNOLD

PRESIDENT

50% but less than 75%

No

Individual

08/1978

Yes

500438



Position

Position Start Date

GUERRISE, MATTHEW ANTHONY

CHIEF COMPLIANCE OFFICER

Individual

08/2002

2673770






Direct Owners and Executive Officers (continued)

Firm Profile



Position Start Date


Less than 5%

No

08/2002

No

Position



Position Start Date


PARKER, ANNE MICHELLE

SROP AND CROP

Less than 5%

No

Individual

01/2000

No

2226034



Position



Position Start Date


SELIGSOHN, MICHAEL STEVEN

CHIEF OPERATIONS OFFICER, VICE PRESIDENT

Less than 5%

No

Individual

01/1994

Yes

2189850






Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


SWINARSKI, THEODORE ANTHONY

SENIOR VICE PRESIDENT - TRADING SUPERVISOR

Less than 5%

No

Individual

01/2015

Yes

1584451






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

No information reported.




Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.




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, 1 SRO and 52 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 12/01/1978

Self-Regulatory Organization Status Date Effective

FINRA Approved 01/24/1979




Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 07/27/1994

Alaska Approved 04/23/1999

Arizona Approved 04/26/1995

Arkansas Approved 07/19/1994

California Approved 01/21/1983

Colorado Approved 03/14/1991

Connecticut Approved 06/06/1994

Delaware Approved 05/19/1994

District of Columbia Approved 11/23/1994

Florida Approved 04/27/1983

Georgia Approved 02/28/1984

Hawaii Approved 05/12/1999

Idaho Approved 04/09/1999

Illinois Approved 04/28/1983

Indiana Approved 06/08/1994

Iowa Approved 06/10/1999

Kansas Approved 09/02/1994

Kentucky Approved 05/05/1983

Louisiana Approved 05/24/1994

Maine Approved 08/31/1994

Maryland Approved 03/31/1983

Massachusetts Approved 08/11/1994

Michigan Approved 07/20/1994

Minnesota Approved 07/06/1994

Mississippi Approved 06/10/1994

Missouri Approved 09/30/1994

Montana Approved 05/03/1999

Nebraska Approved 05/18/1999

Nevada Approved 10/24/1994

New Hampshire Approved 08/22/1994

New Jersey Approved 07/12/1983

New Mexico Approved 06/17/1994

New York Approved 01/02/1986

U.S. States &Territories

Status Date Effective

North Carolina Approved 03/09/1983

North Dakota Approved 04/22/1999

Ohio Approved 06/08/1994

Oklahoma Approved 06/06/1994

Oregon Approved 06/16/1994

Pennsylvania Approved 03/09/1987

Puerto Rico Approved 04/22/1999

Rhode Island Approved 05/03/1983

South Carolina Approved 10/05/1994

South Dakota Approved 04/28/1999

Tennessee Approved 07/21/1994

Texas Approved 09/26/1994

Utah Approved 04/28/1999

Vermont Approved 08/25/1994

Virginia Approved 05/13/1983

Washington Approved 07/06/1994

West Virginia Approved 06/15/1983

Wisconsin Approved 06/14/1994

Wyoming Approved 04/19/1999




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.

Other Types of Business

This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 11 types of businesses.

Types of Business

Broker or dealer selling corporate debt securities

Underwriter or selling group participant (corporate securities other than mutual funds)

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

Trading securities for own account

Private placements of securities

Other - FMSBONDS, INC. OFFERS BANK ISSUED FDIC INSURED CERTIFICATES OF DEPOSIT.




Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: WELLS FARGO CLEARING SERVICES, LLC

Business Address: ONE NORTH JEFFERSON AVENUEST. LOUIS, MO 63103

CRD #: 19616

Effective Date: 02/06/2013

Description: WELLS FARGO CLEARING SERVICES, LLC (F.K.A.) FIRST CLEARINGCORP., LLC., PROVIDES ACCESS TO QUALIFIED RETIREMENTACCOUNTS, MARGIN, EQUITIES, & OPTIONS TRANSACTIONS TOCUSTOMERS OF FMSBONDS, INC. ON A FULLY DISCLOSED,INTRODUCED BASIS.




Firm Operations

Industry Arrangements

This firm does not have books or records maintained by a third party.

This firm does not 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




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 not, 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.

This firm is not 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




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 0 11 0

Arbitration N/A 2 N/A




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.

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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 11

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED170 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERENOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGSSTATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTSCONCERNING 51 MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TOTHE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITSCUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN ANAMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE, OR THATTHE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICHCOULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION.

Current Status: Final




Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 03/02/2017

Docket/Case Number: 2015043950501

Principal Product Type: Debt - Municipal

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED170 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERENOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGSSTATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTSCONCERNING 51 MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TOTHE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITSCUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN ANAMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE, OR THATTHE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICHCOULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION.

Resolution Date: 03/02/2017

Resolution:

Other Sanctions Ordered: RESCISSION

Sanction Details: THE FIRM WAS CENSURED, FINED $210,000 AND MUST OFFER RESCISSIONTO CUSTOMERS WHO PURCHASED SECURITIES LISTED AT EITHER THEORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE,WHICHEVER IS HIGHER. THE FIRM BEGAN THE PROCESS OF OFFERINGRESCISSION TO AFFECTED CUSTOMERS BEFORE THE DATE OF THIS AWC.FINED PAID IN FULL ON 3/21/17.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $210,000.00

Acceptance, Waiver & Consent(AWC)


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iReporting Source: Firm

Initiated By: FINRA DEPARTMENT OF MARKET REGULATION


Censure


FINE, RESCISSION OFFER


Docket/Case Number: 20150439505-01



Allegations: FOR CERTAIN TRANSACTIONS DURING THE PERIOD 8/1/2013 THROUGH12/31/2015, FINRA ALLEGED THE FIRM VIOLATED MSRB RULE G-15(F) BYEFFECTING TRADES IN MUNICIPAL SECURITIES IN AMOUNTS LOWER THANTHE ALLOWABLE MINIMUM DENOMINATION OF THE ISSUE. THEDEPARTMENT ALSO ALLEGED THAT IN 29% OF THE TRANSACTIONS THEFIRM DID NOT PROPERLY DISCLOSE THIS FACT IN WRITING TO THECUSTOMER AT THE TIME OF THE TRADE, VIOLATING MSRB G-47.



Resolution:

Other Sanctions Ordered: RESCISSION OFFER

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE FINDINGS AND TO THE SANCTIONS. THE $210,000FINE WAS PAID IN FULL MARCH 13TH, 2017.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WE ACKNOWLEDGEAND CONSENT TO THE FINDINGS AND SANCTIONS LISTED IN THIS LETTER.WE WOULD LIKE TO POINT OUT, IN THIS EXHIBIT, NEARLY 80% OF THESALES TO RETAIL CUSTOMERS WERE MUNICIPAL BONDS THAT WERERATED INVESTMENT GRADE AND OR INSURED AT THE TIME OFPURCHASE.OF THE REMAINING 20% OF SALES TO RETAIL CUSTOMERS, MORE THAN20% WERE ADDING TO EXISTING POSITIONS WHICH WERE IN EXCESS OFTHE MINIMUM DENOMINATION.IN ADDITION, THIS EXHIBIT ALSO INCLUDES 13 TRANSACTIONS IN WHICHTHE FIRM WAS PROVIDING LIQUIDITY TO CUSTOMERS.IT IS ALSO NOTABLE THAT ALL THESE ISSUERS HAVE MADE PARTIALCALLS, OVER THE YEARS, FOR THESE BONDS WHICH INVARIABLYRESULTS IN PORTFOLIO HOLDINGS FALLING BELOW THE MINIMUMDENOMINATION.ALTHOUGH WE AGREE THESE INSTANCES ARE VIOLATIONS IN THE STRICTAPPLICATION OF THE RULE, WE BELIEVE OUR ACTIONS WERECONSISTENT WITH OUR INTENTIONS TO ALWAYS PROTECT OURCUSTOMERS AND PROVIDE THEM WITH A FAIR AND ORDERLY MARKETFOR THEIR BONDS.






WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WE ACKNOWLEDGEAND CONSENT TO THE FINDINGS AND SANCTIONS LISTED IN THIS LETTER.WE WOULD LIKE TO POINT OUT, IN THIS EXHIBIT, NEARLY 80% OF THESALES TO RETAIL CUSTOMERS WERE MUNICIPAL BONDS THAT WERERATED INVESTMENT GRADE AND OR INSURED AT THE TIME OFPURCHASE.OF THE REMAINING 20% OF SALES TO RETAIL CUSTOMERS, MORE THAN20% WERE ADDING TO EXISTING POSITIONS WHICH WERE IN EXCESS OFTHE MINIMUM DENOMINATION.IN ADDITION, THIS EXHIBIT ALSO INCLUDES 13 TRANSACTIONS IN WHICHTHE FIRM WAS PROVIDING LIQUIDITY TO CUSTOMERS.IT IS ALSO NOTABLE THAT ALL THESE ISSUERS HAVE MADE PARTIALCALLS, OVER THE YEARS, FOR THESE BONDS WHICH INVARIABLYRESULTS IN PORTFOLIO HOLDINGS FALLING BELOW THE MINIMUMDENOMINATION.ALTHOUGH WE AGREE THESE INSTANCES ARE VIOLATIONS IN THE STRICTAPPLICATION OF THE RULE, WE BELIEVE OUR ACTIONS WERECONSISTENT WITH OUR INTENTIONS TO ALWAYS PROTECT OURCUSTOMERS AND PROVIDE THEM WITH A FAIR AND ORDERLY MARKETFOR THEIR BONDS.

Disclosure 2 of 11

i


Initiated By: FINRA







Allegations: MSRB RULES G-17, G-30(A) - FMSBONDS, INC. PURCHASED MUNICIPALSECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLDMUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT ANAGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WASNOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALLRELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER,DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKETVALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OFANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THETRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THETRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPALSECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLARAMOUNT OF THE TRANSACTION.



Resolution: Acceptance, Waiver & Consent(AWC)





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 $13,500 FOR THE MSRBRULE VIOLATIONS. THE FIRM HAS PREVIOUSLY PAID A TOTAL OF $7,426.50IN RESTITUTION TO ADDRESS THE MSRB RULE VIOLATIONS. FINE PAID INFULL ON JANUARY 6, 2014.


No



Initiated By: FINRA MARKET REGULATION


Censure





Allegations: FINRA'S DEPARTMENT OF MARKET REGULATION ALLEGED THAT ON10/15/09, THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWNACCOUNT FROM CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANYMARK-DOWN OR MARK-UP) WHICH WAS DETERMINED TO BE NOT FAIRAND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANTFACTORS AT THE TIME OF THE TRANSACTION. THIS ACTION CONSTITUTESSEPARATE VIOLATIONS OF MSRB RULE G-17 AND G-30.IN ADDITION THEY ALLEGED THAT ON 10/6/09 AND ON 10/29/09 THE FIRMSOLD MUNICIPAL SECURITIES FROM ITS OWN ACCOUNT TO CUSTOMERSAT AGGREGATE PRICES (INCLUDING ANY MARK-DOWN OR MARK-UP)WHICH WERE DETERMINED TO BE NOT FAIR AND REASONABLE, TAKINGINTO ACCOUNT ALL RELEVANT FACTORS AT THE TIME OF THETRANSACTION. THIS ACTION CONSTITUTES SEPARATE VIOLATIONS OFMSRB RULE G-17 AND G-30.






Censure


FINE


Resolution:

Other Sanctions Ordered: NONE

Sanction Details: $13,500 WAS PAID IN FULL ON 12/26/2013.

Firm Statement FOUNDED IN 1978, FMSBONDS IS A FULL SERVICE BROKER DEALERSPECIALIZING IN MUNICIPAL BONDS. FOLLOWING THIS REVIEW, DURINGWHICH OUR FIRM FULLY COOPERATED WITH FINRA STAFF, FMSBONDS,WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CHOSE TO ACCEPTTHE FINDINGS FOR THE FOUR TRADES IN QUESTION, AND CONSENT TO ACENSURE AND FINE.

NOTWITHSTANDING THE ALLEGATIONS NOTED IN THE ABOVEDISCLOSURE, AND IN AN EFFORT TO PROVIDE CONTEXT TO THE FOURTRANSACTIONS AT ISSUE, WE FEEL IT IS IMPORTANT TO NOTE CERTAINFACTORS.

THE FIRM CONDUCTED OVER 14,200 TRANSACTIONS IN THE PRINCIPALCAPACITY DURING THIS REVIEW PERIOD AND FINRA DID NOT ALLEGE ANYWILLFUL OR FRAUDULENT CONDUCT BY THE FIRM.

FMSBONDS IS DETERMINED TO ALWAYS PURSUE THE BEST AVAILABLEEXECUTIONS FOR ITS CLIENTS.



Disclosure 3 of 11

i


Allegations: MSRB RULES G-8, G-17, G-27, G-32: THE FIRM FAILED TO DELIVER OFFICIALSTATEMENTS BY SETTLEMENT DATE TO NUMEROUS CUSTOMERS WHOPURCHASED NEW ISSUE MUNICIPAL SECURITIES DURING THE PRIMARYOFFERING DISCLOSURE PERIOD. IN ALL OF THESE TRANSACTIONS, THEFIRM WAS NEITHER AN UNDERWRITER NOR PART OF THE UNDERWRITINGSYNDICATE. HOWEVER, THE FIRM WAS REQUIRED TO DELIVER ANOFFICIAL STATEMENT TO EACH CUSTOMER BY SETTLEMENT DATE. THEFIRM FAILED TO KEEP A RECORD OF DELIVERIES OF OFFICIALSTATEMENTS TO PURCHASERS OF NEW ISSUE MUNICIPAL SECURITIES,AS REQUIRED BY MSRB RULE G-8(A)(XIII), WHICH REQUIRES BROKER-DEALERS TO KEEP A RECORD OF ALL DELIVERIES OF OFFICIALSTATEMENTS TO PURCHASERS OF NEW ISSUE MUNICIPAL SECURITIESREQUIRED TO BE PROVIDED UNDER MSRB RULE G-32. THE FIRM FAILEDTO ADOPT, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORYPROCEDURES PERTAINING TO: (1) THE FIRM'S OFFICIAL STATEMENTDELIVERY REQUIREMENTS TO CUSTOMERS WHO PURCHASED NEW ISSUEMUNICIPAL SECURITIES FOR SECONDARY MARKET TRANSACTIONS THATOCCURRED DURING THE PRIMARY OFFERING DISCLOSURE PERIOD,INCLUDING THOSE TRANSACTIONS IN WHICH THE FIRM WAS NOT ANUNDERWRITER NOR PART OF THE UNDERWRITING SYNDICATE, ASREQUIRED BY MSRB RULE G-32; AND (2) THE FIRM'S REQUIREMENTS TOMAINTAIN VARIOUS RECORDS PERTAINING TO ITS OBLIGATIONS TODELIVER OFFICIAL STATEMENTS TO CUSTOMERS WHO PURCHASED NEWISSUE MUNICIPAL SECURITIES, INCLUDING THOSE TRANSACTIONS INWHICH THE FIRM WAS NOT AN UNDERWRITER NOR PART OF THEUNDERWRITING SYNDICATE, AS REQUIRED BY MSRB RULE G-8.





Initiated By: FINRA


Other


N/A





MSRB RULES G-8, G-17, G-27, G-32: THE FIRM FAILED TO DELIVER OFFICIALSTATEMENTS BY SETTLEMENT DATE TO NUMEROUS CUSTOMERS WHOPURCHASED NEW ISSUE MUNICIPAL SECURITIES DURING THE PRIMARYOFFERING DISCLOSURE PERIOD. IN ALL OF THESE TRANSACTIONS, THEFIRM WAS NEITHER AN UNDERWRITER NOR PART OF THE UNDERWRITINGSYNDICATE. HOWEVER, THE FIRM WAS REQUIRED TO DELIVER ANOFFICIAL STATEMENT TO EACH CUSTOMER BY SETTLEMENT DATE. THEFIRM FAILED TO KEEP A RECORD OF DELIVERIES OF OFFICIALSTATEMENTS TO PURCHASERS OF NEW ISSUE MUNICIPAL SECURITIES,AS REQUIRED BY MSRB RULE G-8(A)(XIII), WHICH REQUIRES BROKER-DEALERS TO KEEP A RECORD OF ALL DELIVERIES OF OFFICIALSTATEMENTS TO PURCHASERS OF NEW ISSUE MUNICIPAL SECURITIESREQUIRED TO BE PROVIDED UNDER MSRB RULE G-32. THE FIRM FAILEDTO ADOPT, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORYPROCEDURES PERTAINING TO: (1) THE FIRM'S OFFICIAL STATEMENTDELIVERY REQUIREMENTS TO CUSTOMERS WHO PURCHASED NEW ISSUEMUNICIPAL SECURITIES FOR SECONDARY MARKET TRANSACTIONS THATOCCURRED DURING THE PRIMARY OFFERING DISCLOSURE PERIOD,INCLUDING THOSE TRANSACTIONS IN WHICH THE FIRM WAS NOT ANUNDERWRITER NOR PART OF THE UNDERWRITING SYNDICATE, ASREQUIRED BY MSRB RULE G-32; AND (2) THE FIRM'S REQUIREMENTS TOMAINTAIN VARIOUS RECORDS PERTAINING TO ITS OBLIGATIONS TODELIVER OFFICIAL STATEMENTS TO CUSTOMERS WHO PURCHASED NEWISSUE MUNICIPAL SECURITIES, INCLUDING THOSE TRANSACTIONS INWHICH THE FIRM WAS NOT AN UNDERWRITER NOR PART OF THEUNDERWRITING SYNDICATE, AS REQUIRED BY MSRB RULE G-8.


Resolution:



No






Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $100,000.


Initiated By: FINRA DEPARTMENT OF ENFORCEMENT


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


CENSURE





Allegations: AT VARIOUS TIMES DURING THE PERIOD FROM 7/1/2007 THROUGH5/31/2009, FINRA ALLEGED THAT THE FIRM NON-WILLFULLY VIOLATEDMSRB RULE G-32(A) BY FAILING TO MAIL HARDCOPIES OF OFFICIALSTATEMENTS, FOR CERTAIN MUNICIPAL SECURITIES SOLD DURING THENEW ISSUE PERIOD. IN THE INSTANCES MENTIONED ABOVE THE FIRM DIDNOT PARTICIPATE IN THE UNDERWRITING OR SELLING GROUP FOR THESENEW ISSUES. THE FIRM WAS ALSO SUBSEQUENTLY ALLEGED TO BE INNON-WILLFUL VIOLATION OF MSRB RULES G-8(A)(XIII) AND G-27 WHICHRESPECTIVELY REQUIRE FIRMS TO KEEP CERTAIN RECORD DETAILS, ANDMAINTAIN WRITTEN SUPERVISORY PROCEDURES IN RELATION TO THEPROVISIONS OUTLINED IN RULE G-32.



Resolution:

Other Sanctions Ordered: NONE.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO A CENSURE AND FINE IN THE AMOUNT DETAILED ABOVE.THE FINE WAS PAID IN FULL BY FMSBONDS ON 5/20/2011.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FMSBONDSCONTENDS THAT FOR THE PERIOD IN QUESTION THE FIRM MAINTAINEDCOMPLIANCE WITH MSRB G-32, IN INSTANCES WHERE WE HAVE ACTED ASTHE UNDERWRITER OF A NEW MUNICIPAL SECURITY.

IN ADDITION AND AS ACKNOWLEDGED BY FINRA WITHIN THE AWC LETTER, "MSRB RULE G-32 WAS AMENDED (EFFECTIVE JUNE 1, 2009) TO PERMITBROKER-DEALERS TO SATISFY THIS DELIVERY OBLIGATION BY NOTIFYINGCUSTOMERS HOW THEY MAY OBTAIN A COPY OF THE ISSUES' OFFICIALSTATEMENT ELECTRONICALLY." THIS AMENDMENT ESSENTIALLY ADOPTEDTHE "ACCESS EQUALS DELIVERY" STANDARD PREVIOUSLY ESTABLISHEDBY THE SEC IN DECEMBER 2005.

TO THAT END, BEGINNING IN 2008 AND CONTINUING THROUGH THEPRESENT DATE, FMSBONDS HAS BEEN POSTING THE OFFICIALSTATEMENTS FOR ALL NEW ISSUE MUNICIPAL SECURITIES THAT WECARRY IN OUR INVENTORY ON OUR WEBSITE. THIS WEBPAGE WITHINOUR SITE ALLOWS OFFICIAL STATEMENTS TO BE SEARCHED,DOWNLOADED AND PRINTED; THE PAGE ALSO CONTAINS A LINK TO THEHOMEPAGE OF MSRB'S EMMA WEBSITE.






Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FMSBONDSCONTENDS THAT FOR THE PERIOD IN QUESTION THE FIRM MAINTAINEDCOMPLIANCE WITH MSRB G-32, IN INSTANCES WHERE WE HAVE ACTED ASTHE UNDERWRITER OF A NEW MUNICIPAL SECURITY.

IN ADDITION AND AS ACKNOWLEDGED BY FINRA WITHIN THE AWC LETTER, "MSRB RULE G-32 WAS AMENDED (EFFECTIVE JUNE 1, 2009) TO PERMITBROKER-DEALERS TO SATISFY THIS DELIVERY OBLIGATION BY NOTIFYINGCUSTOMERS HOW THEY MAY OBTAIN A COPY OF THE ISSUES' OFFICIALSTATEMENT ELECTRONICALLY." THIS AMENDMENT ESSENTIALLY ADOPTEDTHE "ACCESS EQUALS DELIVERY" STANDARD PREVIOUSLY ESTABLISHEDBY THE SEC IN DECEMBER 2005.

TO THAT END, BEGINNING IN 2008 AND CONTINUING THROUGH THEPRESENT DATE, FMSBONDS HAS BEEN POSTING THE OFFICIALSTATEMENTS FOR ALL NEW ISSUE MUNICIPAL SECURITIES THAT WECARRY IN OUR INVENTORY ON OUR WEBSITE. THIS WEBPAGE WITHINOUR SITE ALLOWS OFFICIAL STATEMENTS TO BE SEARCHED,DOWNLOADED AND PRINTED; THE PAGE ALSO CONTAINS A LINK TO THEHOMEPAGE OF MSRB'S EMMA WEBSITE.

Disclosure 4 of 11

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Initiated By: FINRA



Principal Product Type: Debt - Corporate

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULES 2110, 2320, 3010, 6230(C)(8) - FMS BONDS, INC. INCORPORATE BOND TRANSACTIONS FOR OR WITH A CUSTOMER, FAILEDTO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING BEST EXECUTION OFCORPORATE DEBT SECURITIES. THE FIRM FAILED TO REPORT TO THETRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THE CORRECTTRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLESECURITIES.









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 $45,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING BESTEXECUTION OF CORPORATE DEBT SECURITIES WITHIN 30 BUSINESSDAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.


No








Docket/Case Number: REVIEW 2006005350301


Other Product Type(s): TRACE ELLIGIBLE SECURITIES

Allegations: FINRA ALLLEGED THE FIRM VIOLATED NASD RULE 2320 AND 2110 WITHRELATION TO NINE CORPORATE BOND TRANACTIONS OCCURING DURINGTHE PERIOD FROM 4/1/2005 THROUGH 6/30/2005. IN ADDITION FINRAALLEGED SEVEN VIOLATIONS OF RULE 6230(C)(8)DURING THE SAMEPERIOD.








NONE


Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRMCONSENTED TO A CENSURE AND FINE. THE FINE WAS PAID IN FULL BYFMSBONDS ON 3/18/2011. FIRM HAS ALSO UPATED ITS PROCEEDURESWITH REGARD TO BEST EXECUTION RULES.

Firm Statement IN NINE CORPORATE BOND TRANSACTIONS OCCURRING DURING THEPERIOD FROM APRIL 1, 2005 THROUGH JUNE 30, 2005, FINRA STAFFALLEGED THAT THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTERDEALER MARKET AND FAILED TO BUY ORSELL IN SUCH A MARKET SO THAT THE RESULTANT PRICE TO THECUSTOMER WAS AS FAVORABLE AS POSSIBLE. FINRA ALSO ALLEGEDTHAT ON SEVEN CORPORATE BOND TRANSACTIONS DURING THE SAMEPERIOD THE FIRM REPORTED AN INCORRECT TIME OF EXECUTION TOTHE TRADE REPORTING AND COMPLIANCE ENGINE "TRACE" SYSTEM.



Disclosure 5 of 11

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Initiated By: FINRA


Allegations: SEC SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934, SECRULE 10B-10, NASD RULE 2110, MSRB RULE G-15: THE FIRM ISSUEDCORPORATE BOND CONFIRMATIONS THAT DISCLOSED TO THECUSTOMER AN ERRONEOUS FIRM CAPACITY ON THE TRADES;SPECIFICALLY, THE CONFIRMATIONS INCORRECTLY STATED THAT THEFIRM WAS ACTING AS AN AGENT INSTEAD OF IN A PRINCIPAL CAPACITY.THE FIRM ISSUED MUNICIPAL BOND CONFIRMATIONS THAT DISCLOSED TOTHE CUSTOMER AN ERRONEOUS FIRM CAPACITY ON THE TRADES;SPECIFICALLY, THE CONFIRMATIONS INCORRECTLY STATED THAT THEFIRM WAS ACTING AS AN AGENT INSTEAD OF IN A PRINCIPAL CAPACITY.






Other


N/A


Principal Product Type: Other

Other Product Type(s): CORPORATE BOND AND MUNICIPAL BOND


Resolution:


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 $10,000.


No




Initiated By: FINRA DEPT OF ENFORCEMENT





Principal Product Type: No Product


Allegations: FINRA ALLEGED THAT THE FIRM THROUGH ITS FULLY DISCLOSEDINTRODUCING CLEARING FIRM, RIDGE CLEARING, VIOLATED SEC RULE10B-10, NASD RULE 2110, AND MSRB RULE G-15 BY ISSUING CERTAINCONFIRMATIONS THAT CONTAINED AN INCORRECT CAPACITY CODE.



http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2008011689301https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2008011689301





NONE


Resolution:

Other Sanctions Ordered: NONE

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM ACCEPTS ANDCONSENTS TO THE ADMINISTRATIVE FINE.

Firm Statement DURING THE PERIOD FROM JULY 15, 2008 THROUGH OCTOBER 14, 2008THE FIRM INCORRECTLY REPORTED THE CAPACITY CODE "AS AGENT"INSTEAD OF "AS PRINCIPAL" ON A LIMITED AMOUNT OF CONFIRMATIONSISSUED THROUGH ITS FULLY DISCLOSED, INTRODUCED CLEARING FIRM,RIDGE CLEARING. THIS UNITENTIONAL CODING OCCURRED AS A RESULTOF AN UPGRADE TO A NEW TRADING PLATFORM AND HAS SINCE BEENCORRECTED.



Disclosure 6 of 11

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Initiated By: FINRA





Principal Product Type: Other


Allegations: NASD RULES 2110, 6230(A) - FMSBONDS, INC. FAILED TO REPORT TO THETRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS INTRACE-ELIGIBLE SECURITIES IT WAS REQUIRED TO REPORT WITHIN 15MINUTES OF THE TIME OF EXECUTION.






Resolution:


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.


No

Sanctions Ordered: Monetary/Fine $5,000.00








Docket/Case Number: REVIEW 2007011198101



Allegations: FINRA ALLEGED THE FIRM VIOLATED NASD RULE 6230(A)AND RULE 2110,LATE REPORTING OF TRACE ELLIGIBLE TRANSACTIONS DURING THEPERIOD OF JULY 1, 2007 THROUGH SEPT. 30, 2007.



Resolution:


Sanction Details: ADMINISTRATIVE FINE WAS ISSUED, ACCEPTED AND PAID IN FULL ON02/18/2009.

Sanctions Ordered: Monetary/Fine $5,000.00





Sanction Details: ADMINISTRATIVE FINE WAS ISSUED, ACCEPTED AND PAID IN FULL ON02/18/2009.

Firm Statement FOLLOWING A FIRM-WIDE COMPUTER SYSTEM CONVERSION IN JULY 2007,FINRA ALLEGED THE FIRM VIOLATED NASD RULE 6230(A)AND RULE 2110,BY REPORTING A CERTAIN NUMBER OF TRANSACTIONS PAST THE 15MINUTE REPORTING REQUIREMENT TO THE TRACE SYSTEM DURING THEPERIOD OF JULY 1, 2007 THROUGH SEPT. 30, 2007.

Disclosure 7 of 11

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C07940043

Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement ON JUNE 20, 1994, DISTRICT NO. 7 NOTIFIED FIRST MIAMISECURITIES, INC. AND JAMES A. KLOTZ THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C07940043 WAS ACCEPTED;THEREFORE, RESPONDENTS MEMBER AND KLOTZ ARE CENSURED ANDFINED$5,000, JOINTLY AND SEVERALLY - (SECTION 8(c)(1)(A) OF THENASD'S GOVERNMENT SECURITIES RULES - RESPONDENT MEMBER,ACTINGTHROUGH RESPONDENT KLOTZ, CAUSED TO BE PUBLISHEDADVERTISEMENTSWHICH WERE NOT FILED PRIOR TO USE WITH THE NASD'S ADVERTISINGDEPARTMENT).

**$5,000 J&S PAID ON 7/27/94 INVOICE #94-07-451**


Consent




ON JUNE 20, 1994, DISTRICT NO. 7 NOTIFIED FIRST MIAMISECURITIES, INC. AND JAMES A. KLOTZ THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C07940043 WAS ACCEPTED;THEREFORE, RESPONDENTS MEMBER AND KLOTZ ARE CENSURED ANDFINED$5,000, JOINTLY AND SEVERALLY - (SECTION 8(c)(1)(A) OF THENASD'S GOVERNMENT SECURITIES RULES - RESPONDENT MEMBER,ACTINGTHROUGH RESPONDENT KLOTZ, CAUSED TO BE PUBLISHEDADVERTISEMENTSWHICH WERE NOT FILED PRIOR TO USE WITH THE NASD'S ADVERTISINGDEPARTMENT).

**$5,000 J&S PAID ON 7/27/94 INVOICE #94-07-451**


Initiated By: NASD


Censure


FINE OF $5,000


Docket/Case Number: C07940043-AWC



Allegations: NASD ALLEGED VIOLATIONS OF SECTIONS 8(C)(1)(A) OF THEASSOCIATION'S GOVERNMENT SECURITIES RULES - FAILING TO FILEADVERTISEMENTS WITH THE ASSOCIATIONS ADVERTISING DEPARTMENTWITHIN 10 DAYS OF FIRST USE.



Resolution:


Sanction Details: FINE OF $5,000.00 WAS PAID IN FULL.



Disclosure 8 of 11

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Allegations: THE BROKER-DEALER AGAIN FAILED TO COMPLY WITHTHE PROVISIONS OF SECTION 13.1-518.1 IN THAT IT FAILED TO FILEITS JUNE 30, 1991 ANNUAL AUDITED STATEMENT WITH THE DIVISIONWITHIN THE PRESCRIBED TEN DAY TIME LIMIT.





Initiated By: VIRGINIA - STATE CORPORATION COMMISSION -DIVISION *See FAQ #1*




Docket/Case Number: SEC920025

URL for Regulatory Action:



THE BROKER-DEALER AGAIN FAILED TO COMPLY WITHTHE PROVISIONS OF SECTION 13.1-518.1 IN THAT IT FAILED TO FILEITS JUNE 30, 1991 ANNUAL AUDITED STATEMENT WITH THE DIVISIONWITHIN THE PRESCRIBED TEN DAY TIME LIMIT.


Resolution:


Sanction Details: AS AN OFFER TO SETTLE ALL MATTERS ARISING FROMTHE ALLEGATIONS MADE AGAINST IT, THE BROKER-DEALER AGREES TOREFRAIN FROM ANY CONDUCT WHICH VIOLATES VIRGINIA CODE SECTION13.1-518.1 AS LONG AS REGISTERED UNDER THE ACT AND AGREES TOPAY A PENALTY IN THE AMOUNT OF $500.00.

Regulator Statement CONTACT SHERYL DEVAUN, REGISTRATION EXAMINER,804-786-7753.

Sanctions Ordered: Monetary/Fine $500.00

Consent


Initiated By: COMMONWEALTH OF VIRGINIA, EX REL. STATE CORPORATIONCOMMISSION


Docket/Case Number: SEC920025


Allegations: ALLEGED NON-COMPLIANCE WITH VIRGINIA'S CODE SECTION 13.1-518-1,FAILURE TO FILE THE FIRM'S JUNE 30TH, 1990, ANNUAL AUDITEDSTATEMENT WITHIN TEN DAYS OF PUBLICATION.






Other


FIRST MIAMI SECURITIES, INC. PAID A PENALTY OF $500.00.




Resolution:


Sanction Details: THE $500.00 PENALTY WAS PAID IN FULL.

Sanctions Ordered: Monetary/Fine $500.00

Dismissed

Disclosure 9 of 11

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Docket/Case Number: ATL-1219-AWC



Allegations:



Resolution:


Sanction Details:

Regulator Statement ON SEPTEMBER 21, 1990, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. ATL-1219-AWC (DISTRICT NO. 7) SUBMITTED BYRESPONDENTS FIRST MIAMI SECURITIES, INC. AND JAMES A. KLOTZ WASACCEPTED THEREFORE, THEY ARE CENSURED AND FINED $1,000,JOINTLYAND SEVERALLY - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OFFAIR PRACTICE - RESPONDENT MEMBER FAILED, AND RESPONDENTKLOTZPERMITTED IT TO FAIL, TO HAVE WRITTEN SUPERVISORY PROCEDURESWITH REGARD TO THE BRANCH OFFICE ACTIVITIES AND ANNUALINSPECTION OF THE FIRM'S BRANCH OFFICE, ANNUAL COMPLIANCERELATED MEETINGS WITH REGISTERED PERSONNEL AND ASSIGNMENTOFEACH REGISTERED PERSON TO AN INDIVIDUAL RESPONSIBLE FORSUPERVISION, AND THE FIRM'S WRITTEN SUPERVISORY PROCEDURESDESIGNATED AN INDIVIDUAL NOT ASSOCIATED WITH THE FIRM WITHRESPONSIBILITY FOR SUPERVISION OF THE GENERAL SECURITIESACTIVITIES). $1,000.00 J&S PAID ON 10/9/90 INVOICE #90-07-1106***


Consent




Regulator Statement ON SEPTEMBER 21, 1990, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. ATL-1219-AWC (DISTRICT NO. 7) SUBMITTED BYRESPONDENTS FIRST MIAMI SECURITIES, INC. AND JAMES A. KLOTZ WASACCEPTED THEREFORE, THEY ARE CENSURED AND FINED $1,000,JOINTLYAND SEVERALLY - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OFFAIR PRACTICE - RESPONDENT MEMBER FAILED, AND RESPONDENTKLOTZPERMITTED IT TO FAIL, TO HAVE WRITTEN SUPERVISORY PROCEDURESWITH REGARD TO THE BRANCH OFFICE ACTIVITIES AND ANNUALINSPECTION OF THE FIRM'S BRANCH OFFICE, ANNUAL COMPLIANCERELATED MEETINGS WITH REGISTERED PERSONNEL AND ASSIGNMENTOFEACH REGISTERED PERSON TO AN INDIVIDUAL RESPONSIBLE FORSUPERVISION, AND THE FIRM'S WRITTEN SUPERVISORY PROCEDURESDESIGNATED AN INDIVIDUAL NOT ASSOCIATED WITH THE FIRM WITHRESPONSIBILITY FOR SUPERVISION OF THE GENERAL SECURITIESACTIVITIES). $1,000.00 J&S PAID ON 10/9/90 INVOICE #90-07-1106***


Initiated By: NASD




CENSURE


Docket/Case Number: ATL-1219-AWC



Allegations: THE NASD ALLEGED VIOLATION OF ARTICLE III, SECTIONS 1 AND 27 OFTHE RULES OF FAIR PRACTICE.



Resolution:








Sanction Details: WITHOUT ADMITTING OR DENYING THE COMPLAINT ALLEGATIONS, THEFIRM CONSENTED TO THE FINDINGS AND TO THE CENSURE AND A$1,000.00 FINE. THE $1,000.00 FINE WAS PAID IN FULL OCTOBER 9TH, 1990.

Disclosure 10 of 11

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Initiated By: SECURITIES AND EXCHANGE COMMISSION




Docket/Case Number:



Allegations:



Resolution:


Sanction Details:

Regulator Statement SEC NEWS DIGEST, MARCH 8, 1983, ISSUE 83-45THE COMMISSION HAS AUTHORIZED AND ACCEPTED THE SETTLEMENTOFFERIN A PUBLIC ADMINISTRATIVE PROCEEDING AGAINST FIRST MIAMISECURITIES, INC., A NORTH MIAMI BEACH, FL MUNICIPAL SECURITIESFIRM, ITS PRESIDENT, JAMES A. KLOTZ, AND ITS CHAIRMAN, PAULFEINSILVER. FIRST MIAMI AND FEINSILVER WERE CENSURED AND KLOTZWAS SUSPENDED FROM ASSOCIATION WITH ANY BROKER, DEALER ORMUNICIPAL SECURITIES DEALER FOR 20 BUSINESS DAYS. RESPONDENTSNEITHER ADMITTED NOR DENIED THE ALLEGATIONS AGAINST THEM.THE COMMISSION'S ORDER FOR PROCEEDINGS ALLEGED VIOLATIONS OFRECORDKEEPING PROVISIONS AND OF CERTAIN ANTIFRAUD PROVISIONSOFTHE SECURITIES LAWS AND THE PRICING REGULATORY PROVISIONS OFTHE MSRB FOR CHARGING TWO CUSTOMERS EXCESSIVE PRICES TOSUCHCUSTOMERS. THE COMMISSION'S ORDER FOR PROCEEDING ALSOALLEGEDTHAT FEINSILVER FAILED TO REASONABLY SUPERVISE PERSONS UNDERHIS SUPERVISION WITH A VIEW TO PREVENTING VIOLATIONS OF MSRBRULES RELATING TO CUSTOMER ACCOUNT INFORMATION AND A REVIEWOFCUSTOMER ACCOUNTS. (REL. 34-19552) (SEE LR-9919)

Sanctions Ordered: Censure

Consent




SEC NEWS DIGEST, MARCH 8, 1983, ISSUE 83-45THE COMMISSION HAS AUTHORIZED AND ACCEPTED THE SETTLEMENTOFFERIN A PUBLIC ADMINISTRATIVE PROCEEDING AGAINST FIRST MIAMISECURITIES, INC., A NORTH MIAMI BEACH, FL MUNICIPAL SECURITIESFIRM, ITS PRESIDENT, JAMES A. KLOTZ, AND ITS CHAIRMAN, PAULFEINSILVER. FIRST MIAMI AND FEINSILVER WERE CENSURED AND KLOTZWAS SUSPENDED FROM ASSOCIATION WITH ANY BROKER, DEALER ORMUNICIPAL SECURITIES DEALER FOR 20 BUSINESS DAYS. RESPONDENTSNEITHER ADMITTED NOR DENIED THE ALLEGATIONS AGAINST THEM.THE COMMISSION'S ORDER FOR PROCEEDINGS ALLEGED VIOLATIONS OFRECORDKEEPING PROVISIONS AND OF CERTAIN ANTIFRAUD PROVISIONSOFTHE SECURITIES LAWS AND THE PRICING REGULATORY PROVISIONS OFTHE MSRB FOR CHARGING TWO CUSTOMERS EXCESSIVE PRICES TOSUCHCUSTOMERS. THE COMMISSION'S ORDER FOR PROCEEDING ALSOALLEGEDTHAT FEINSILVER FAILED TO REASONABLY SUPERVISE PERSONS UNDERHIS SUPERVISION WITH A VIEW TO PREVENTING VIOLATIONS OF MSRBRULES RELATING TO CUSTOMER ACCOUNT INFORMATION AND A REVIEWOFCUSTOMER ACCOUNTS. (REL. 34-19552) (SEE LR-9919)


Initiated By: SECURITIES EXCHANGE COMMISSION


Censure



Docket/Case Number: 3-6160



Allegations: THE COMMISSION ALLEGED VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933, SECTIONS 17(A), 15(B)(1) AND15(C)(1) OF THE 1934 ACT, AND RULES G-8, G-26 AND G-30 OF THE MSRB.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS JAMES A. KLOTZCONSENTED TO A 20 DAY SUSPENSION.

Sanctions Ordered: CensureSuspension

Settled

Disclosure 11 of 11

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Docket/Case Number: ATL-662



Allegations:



Resolution:


Sanction Details:

Regulator Statement COMPLAINT #ATL-662 FILED 1/28/82DISTRICT #76/25/82: CAF $2,500, J & SFC #8248 J & S PAID 7-6-82


Decision


Initiated By: NASD


Docket/Case Number: ATL-662



Allegations: THE NASD'S COMPLAINT ALLEGED VIOLATIONS OF RULE G-30 AND RULEG-8 (A)(XI) OF MUNICIPAL SECURITIES RULEMAKING BOARD.






Censure




Resolution:


Sanction Details: THE FINE OF $2,500.00 WAS PAID IN FULL.


Settled




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 2


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

02/12/2015

15-00304

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

MUNICIPAL BONDS

$2,500,000.00

AWARD AGAINST PARTY

08/19/2016

$218,600.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 2

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Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

04/27/2017

17-01038

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE


http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/awardsonlinehttps://www.finra.org/arbitration-mediation/arbitration-awards-online?search=15-00304https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=17-01038


Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

17-01038

GOVERNMENT SECURITIES; MUNICIPAL BONDS

Unspecified Damages

AWARD AGAINST PARTY

01/10/2020

$455,000.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.


http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-mediation/arbitration-awards-online?search=17-01038


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Report SummaryFirm ProfileFirm HistoryFirm OperationsDisclosure EventsDisclosure InformationRegulatory - FinalDisclosure #1Disclosure #2Disclosure #3Disclosure #4Disclosure #5Disclosure #6Disclosure #7Disclosure #8Disclosure #9Disclosure #10Disclosure #11

Arbitration Award - Award / JudgmentDisclosure #1Disclosure #2

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