raymond james & associates, inc. - finra · elwyn, tashtego spring 2319098 ... raymond james...

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

www.finra.org/brokercheck User Guidance

1©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.

https://adviserinfo.sec.gov/IAPD/IAPDSummaryRouter.aspx?IndividualID=-1&FirmID=705&Source=Report


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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








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



Position Start Date


JAMES, THOMAS ALAN

DIRECTOR/CHAIRMAN OF THE BOARD

5% but less than 10%

No

Individual

01/1972

Yes

257119



Position


Position Start Date

ARIYAN, GERALD HAIG

PRESIDENT, ALEX. BROWN DIVISION

Less than 5%

Individual

09/2016

2326282








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


BARKO, SHAWN JOSEPH

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

12/2017

Yes

2690394



Position



Position Start Date


CAMPAGNOLI, VINCENT JOHN

CHIEF INFORMATION OFFICER

Less than 5%

No

Individual

06/2016

No

1421076



ELWYN, TASHTEGO SPRING

2319098








Firm Profile

Position



Position Start Date


PRESIDENT - PRIVATE CLIENT GROUP/DIRECTOR

Less than 5%

No

Individual

02/2014

Yes

2319098


Position



Position Start Date


JULIEN, JEFFREY PAUL

DIRECTOR

Less than 5%

No

Individual

01/2004

Yes

1453432



Position


Position Start Date


OLLIA, MARSHALL FARROKH

PRINCIPAL FINANCIAL OFFICER / FINOP

Less than 5%

Individual

04/2018

Yes

3195972









Firm Profile



No

Yes

Position



Position Start Date


SANTELLI, JONATHAN

CHIEF LEGAL OFFICER / SECRETARY

Less than 5%

No

Individual

05/2016

No

6306997



Position



Position Start Date


SHOUKRY, PAUL MARONE

TREASURER

Less than 5%

No

Individual

04/2018

Yes

5804809



THURSTON, CHRISTOPHER S

Individual

3112696









Firm Profile

Position



Position Start Date


RIA CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

02/2018

No


Position



Position Start Date


TREMAINE, THOMAS ROBERT

EXECUTIVE VICE PRESIDENT, DIRECTOR, CHIEF OPERATIONS OFFICER

Less than 5%

No

Individual

05/2004

Yes

1524109



Position


Position Start Date


ZANK, DENNIS WILLIAM

CHIEF EXECUTIVE OFFICER/DIRECTOR

Less than 5%

Individual

05/2004

Yes

871971









Firm Profile



No

Yes






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, 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






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






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.






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.





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.






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.






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


174904

CARILLON TOWER ADVISERS, INC. is under common control with the firm.

WHOLLY-OWNED SUBSIDIARY OF THE PARENT OF APPLICANTDescription:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






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:



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:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

10/01/2013


121221

RAYMOND JAMES INSURANCE GROUP, INC. is under common control with the firm.

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

No

Yes

No




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.




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.




Country:

Foreign Entity:

Effective Date:

Business Address:


149018

RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC is under common control with the firm.

Business Address:

CRD #:






Firm Operations


Yes

No

No

12/18/2008




Country:

Foreign Entity:

Effective Date:

No

Yes

No

11/01/2008


EAGLE FUND SERVICES, INC. is under common control with the firm.




Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

07/13/2006


139749

CARILLON FUND DISTRIBUTORS, INC. is under common control with the firm.




Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:


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.





Firm Operations


No

Yes

No

05/28/1992





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.




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:



Country:

Foreign Entity:

Effective Date:

Business Address:

RAYMOND JAMES GLOBAL SECURITIES, LTD. is under common control with the firm.






Firm Operations


No

Yes

BRITISH VIRGIN ISLANDS

Yes

01/31/2001

ROMASCO PLACE WICKHAMS CAY 1P.O. BOX 3140, ROAD TOWNTORTOLA, BRITISH VIRGIN ISLANDS




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.




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.



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes



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:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

No

12/07/2007


EAGLE BOSTON INVESTMENT MANAGEMENT, INC. is under common control with the firm.




Country:

Foreign Entity:

Effective Date:

Business Address:

02/08/1984


110653

EAGLE ASSET MANAGEMENT INC is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

No




Country:

Foreign Entity:

Yes

Yes

No

09/12/1973


6694

RAYMOND JAMES FINANCIAL SERVICES, INC. is under common control with the firm.




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







Firm Operations


Effective Date:

Business Address:

Description: PARENT OF APPLICANT.

RAYMOND JAMES FINANCIAL, INC. is a Bank Holding Company and controls the firm.

02/01/2012







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






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






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):


Resolution: Decision & Order of Offer of Settlement 28©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.





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








Initiated By: NYSE ARCA, INC.


Censure


MONETARY FINE & UNDERTAKING





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:


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.








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

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Initiated By: NASDAQ ISE, LLC





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.









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


No


Acceptance, Waiver & Consent(AWC)


Initiated By: NASDAQ ISE, LLC






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.










Resolution:


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.



Disclosure 3 of 120

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Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION


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



Docket/Case Number: 65556-S

URL for Regulatory Action:

Principal Product Type: No Product


Allegations: N/A



Resolution:


No

Order






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.


No

Sanctions Ordered: Monetary/Fine $10,000.00Cease and Desist/Injunction


Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION





Docket/Case Number: 65556-S



Allegations: N/A



Resolution: Order







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.


Disclosure 4 of 120

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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.







Initiated By: FINRA







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:

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.


No




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.






https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2011030345701


Initiated By: FINRA





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.











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.



Disclosure 5 of 120

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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 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.











Other Product Type(s): OTC SECURITIES


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.


No

Sanctions Ordered: Monetary/Fine $5,000.00Disgorgement/Restitution



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.







Initiated By: FINRA






Other Product Type(s): OTC SECURITIES


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.



Disclosure 6 of 120

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Initiated By: FINRA


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.












Principal Product Type: Equity - OTC



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.


No




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.








Initiated By: FINRA







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:


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.



Disclosure 7 of 120

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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.








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.








N/A


Docket/Case Number: 3-17531




Resolution:


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.


Yes


Order






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.


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.










N/A





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:


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.


Order






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




CEASE AND DESIST ORDER


Docket/Case Number: 16-026-S



Allegations: VIOLATION OF 9 VERMONT SECURITIES ACT (VSA) 5412(D)(9)



Resolution:


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






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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Initiated By: FINRA







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.



Resolution:


No








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.


No



Initiated By: FINRA







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.









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.



Disclosure 10 of 120

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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.







Initiated By: FINRA




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:


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.


No

Sanctions Ordered: CensureMonetary/Fine $8,000,000.00



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.






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.






Initiated By: FINRA







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:


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.









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.


i


Initiated By: FINRA


Other





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.









Other


N/A


Resolution:


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.


No




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.







Initiated By: FINRA


Other


N/A





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:


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.









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.


i


Initiated By: INTERNATIONAL SECURITIES EXCHANGE








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.



Resolution:


Sanction Details: RAYMOND JAMES FINED $5000.


No

Sanctions Ordered: Monetary/Fine $5,000.00









Initiated By: INTERNATIONAL SECURITIES EXCHANGE








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:


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.




i


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.







Initiated By: FINRA


Other


N/A



Principal Product Type: Mutual Fund(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:


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.


No

Sanctions Ordered: CensureDisgorgement/Restitution



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.








Initiated By: FINRA


Other


N/A





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:


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.




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Cease and Desist




Principal Product Type: Debt - Municipal


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.



Resolution:


Yes

Order







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.


Yes



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."









Cease and Desist






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:


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.


Order






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.


i


Initiated By: FINRA







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).



Resolution:


No










Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. FINE PAID IN FULL ONDECEMBER 9, 2014.


Initiated By: FINRA







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).



Resolution:


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.




i


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.








Initiated By: FINRA









Resolution:



No










Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL ON SEPTEMBER 8, 2014.


Initiated By: FINRA










Resolution: Acceptance, Waiver & Consent(AWC)









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


i


Initiated By: FINRA




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.













Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $12,500.


No




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.







Initiated By: FINRA







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:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $12,500.




i


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.








Initiated By: FINRA







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:


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, 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.



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.







Initiated By: FINRA







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:


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.




i


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.








Initiated By: THE OFFICE OF THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION





Docket/Case Number: CAUSE NO. 13-0163 SC



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:

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.


Consent






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.


i


Initiated By: FINRA





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.












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.


No



Initiated By: FINRA


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.












Other Product Type(s): TRACE-ELIGIBLE SECURITIES


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, 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.




i


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.








Initiated By: FINRA





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:


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.


No










Initiated By: FINRA






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.











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.



i


Initiated By: FINRA







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.









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, 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.


No




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.







Initiated By: FINRA







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:


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.




i









Initiated By: STATE OF ALASKA




CEASE & DESIST


Docket/Case Number: ORDER NO: 11-000736-01-S


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.



Resolution:



Order







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.


i


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.







Initiated By: OHIO SECURITIES DIVISION




CEASE & DESIST


Docket/Case Number: ORDER NO. 12-024



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:


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.


Order






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.


i


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.







Initiated By: STATE OF IOWA INSURANCE DIVISION




CEASE & DESIST


Docket/Case Number: DOCKET NO. 72282



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).



Resolution:


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.


Order






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.


i


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.







Initiated By: FINRA


Other





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.








Other


N/A


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 $250,000. FINE PAID INFULL ON SEPTEMBER 21, 2012


No




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.







Initiated By: FINRA







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:


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.




i


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.








Initiated By: PENNSYLVANIA CONTACT: CAROLYN MENDELSON (412)-565-5083




RAYMOND JAMES & ASSOCIATES, INC. HAS COMPLETED A REPURCHASEOF AUCTION RATE SECURITIES FROM ELIGIBLE PA INVESTORS.


Docket/Case Number: 2009-10-21





Resolution:


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.


Yes


Settled


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.







Initiated By: PENNSYLVANIA SECURITIES COMMISSION




CEASE & DESIST


Docket/Case Number: NO. 2009-10-21



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:


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.


Order






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.


i


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).








Initiated By: ILLINOIS SECURITIES DEPARTMENT




CEASE AND DESIST


Docket/Case Number: NO. 0900447



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).



Resolution:


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.


Order






WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE ILLINOIS SECURITIESDEPARTMENT ON JULY 16, 2012, IN WHICH IT CONSENTED:



i


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.







Initiated By: STATE OF WEST VIRGINIA




CEASE & DESIST


Docket/Case Number: ORDER NO.: 81-705



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:


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.


Order






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.


i


Initiated By: U.S. VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE


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.










CEASE & DESIST

Docket/Case Number: ORDER NO. 04/2012




Resolution:


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.


Order






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.


i


Initiated By: THE STATE OF MICHIGAN, OFFICE OF FINANCIAL AND INSURANCEREGULATION




Docket/Case Number:



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.










CEASE & DESIST


Resolution:


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.


Order






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.


i


Initiated By: DISTRICT OF COLUMBIA


Other


ADMINISTRATIVE CONSENT ORDER


Docket/Case Number: SB-CO-08-12




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.



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.


No


Order






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.


Initiated By: THE DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIESAND BANKING




CEASE & DESIST


Docket/Case Number: ORDER NO. SB-CO-08-12



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.


Resolution: Order104©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.






Resolution:


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.


Order


i







Initiated By: ARKANSAS SECURITIES COMMISSIONER




CEASE & DESIST


Docket/Case Number: ORDER NO. S-09-024-11-0R15 CASE NO. S-09-024



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.



Resolution:



Order







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.


i


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.








Initiated By: WISCONSIN SECURITIES DIVISION




CEASE & DESIST


Docket/Case Number: FILE S-220238 (EX)



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.



Resolution:


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.


Order






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.


i


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).








Initiated By: NEBRASKA DEPARTMENT OF BANKING & FINANCE




CEASE & DESIST


Docket/Case Number: NONE



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).



Resolution:


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.


Order






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.


i


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)).








Initiated By: DELAWARE SECURITIES COMMISSIONER




CEASE & DESIST


Docket/Case Number: CASE NO. 11-11-3



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)).



Resolution:


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.


Order






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.


i


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.







Initiated By: COMMISSIONER OF SECURITIES STATE OF GEORGIA




CEASE & DESIST


Docket/Case Number: CASE NO. ENSC - 120081



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:


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.


Order






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.


i


Initiated By: COLORADO DIVISION OF SECURITIES


Docket/Case Number: ORDER NO. 12-6-21



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.










CEASE & DESIST



Resolution:


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.


Order






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.


i


Initiated By: MISSOURI


Other


CONSENT ORDER


Docket/Case Number: AP-11-23




Allegations: ACTIVITIES REGARDING THE SALE OF AUCTION RATE SECURITIES HAVEBEEN THE SUBJECT OF COORDINATED INVESTIGATIONS CONDUCTED BYA MUTLI-STATE TASK FORCE.



Resolution:


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.


Yes

Sanctions Ordered:

Consent

i117©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.






Initiated By: MISSOURI SECURITIES DIVISION




CEASE & DESIST


Docket/Case Number: CASE NO. AP-11-23



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.



Resolution:


Order







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.



i


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.







Initiated By: MISSISSIPPI SECRETARY OF STATE




CEASE & DESIST


Docket/Case Number: FILE NO. S-11-0240



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:


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.


Order






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.


i


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.







Initiated By: WASHINGTON


Cease and Desist


CIVIL MONETARY PENALTY


Docket/Case Number: S-11-0740-11-CO01




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:


Sanction Details: CIVIL MONETARY PENALTY OF $8363.42. FULL AMOUNT WAS PAID ON12/8/2011.

Regulator Statement BRIDGETT FISHER 3609028783


Yes


Consent


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.







Initiated By: STATE OF WASHINGTON, SECURITIES DIVISION




CEASE & DESIST


Docket/Case Number: ORDER NUMBER S-11-0740-11-CO01



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:


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.


Order






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.


i


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.







Initiated By: COMMONWEALTH OF VIRGINIA





Docket/Case Number: CASE NO. SEC-2011-00039



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:


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.


Order






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.


i


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.







Initiated By: MASSACHUSETTS SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: DOCKET NO. E-2011-0049



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:


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.


Order






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.


i


Initiated By: SECURITIES COMMISSIONER OF MARYLAND


Docket/Case Number: NO. 2011-0336


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.










CEASE AND DESIST




Resolution:


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.


Order






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.


i


Initiated By: UTAH


Cease and Desist


ADMINISTRATIVE FINE


Docket/Case Number: SD-11-0089




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.



Resolution:


Sanction Details: THE FINE OF $29328.05 WAS PAID WITHIN TEN (10) DAYS OF ENTRY OF THEORDER.


Yes


Stipulation and Consent






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).


Initiated By: UTAH DIVISION OF SECURITIES




CEASE AND DESIST


Docket/Case Number: SD-11-0089



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.








CEASE AND DESIST


Resolution:


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.




i







Initiated By: MAINE OFFICE OF SECURITIES


Cease and Desist


CIVIL MONETARY PENALTY






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.



Resolution:


No


Order







Sanction Details: CIVIL MONETARY PENALTY OF $4,586 PAID IN FULL ON 10/28/2011.


Initiated By: MAINE OFFICE OF SECURITIES




CEASE AND DESIST


Docket/Case Number: CASE NO. 11-7620



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.



Resolution: Order








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.



i


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).








Initiated By: STATE OF MINNESOTA, DEPARTMENT OF COMMERCE




CEASE AND DESIST


Docket/Case Number: FILE 21296



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).



Resolution:


Sanction Details: ON OCTOBER 27, 2011, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF$13,982.32 TO THE MINNESOTA DEPARTMENT OF COMMERCE.


Order






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


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).








Initiated By: KANSAS SECURITIES COMMISSIONER




CEASE AND DESIST


Docket/Case Number: DOCKET NO. 12 E 006 -- KSC NO. 2012-5915



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).



Resolution:


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:



Order






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


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).








Initiated By: STATE OF WYOMING, SECRETARY OF STATE, SECURITIES DIISION




CEASE AND DESIST


Docket/Case Number: ORDER NO. 11-06



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).



Resolution:


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:



Order






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


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).








Initiated By: STATE OF NEW MEXICO REGULATION AND LICENSING DEPT., SECURITIESDIVISION




CEASE AND DESIST


Docket/Case Number: MATTER NO. 11-11-996-015



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).



Resolution:


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:



Order






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


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).








Initiated By: IDAHO DEPARTMENT OF FINANCE




CEASE AND DESIST


Docket/Case Number: DOCKET NO. 2011-7-15



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).



Resolution:


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:



Order






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


Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SECURITIES.


Cease and Desist


CIVIL PENALTY; BUYBACK OF ELIGIBLE AUCTION RATE SECURITIES FROMELIGIBLE INVESTORS


Docket/Case Number: S-11-0060




Allegations: ENGAGING IN DISHONEST OR UNETHICAL PRACTICES IN CONNECTIONWITH THE PURCHASE OR SALE OF SECURITIES; FAILURE TO SUPERVISE



Resolution:


No

Consent






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.


No



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).








Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,DIVISION OF FINANCE AND CORPORATE SECURITIES




CEASE AND DESIST


Docket/Case Number: DFCS FILE NO. S-11-0060



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).



Resolution:


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:



Order






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


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).








Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT




CEASE AND DESIST


Docket/Case Number: N/A




Resolution:


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:



Order






WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMESFINALIZED A SETTLEMENT AGREEMENT WITH THE NORTH DAKOTASECURITIES DEPARTMENT ON SEPTEMBER 26, 2011, IN WHICH ITCONSENTED:



i


Initiated By: TENNESSEE DEPT. OF COMMERCE AND INSURANCE, SECURITIESDIVISION


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.










CEASE AND DESIST

Docket/Case Number: ORDER NO. 11-010 (SI#2011-002)




Resolution:


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.


Order






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.


i


Initiated By: MONTANA COMMISSIONER OF SECURITIES AND INSURANCE




CEASE AND DESIST


Docket/Case Number: SEC-2001-228



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.








CEASE AND DESIST


Resolution:


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.


Order







i


Initiated By: FINRA







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).



Resolution:



No










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.


Initiated By: FINRA



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).














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, 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.




i


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.








Initiated By: FINRA









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, 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.


No









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.


Initiated By: FINRA










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, 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.









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.


i


Initiated By: FINRA







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.



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 $15,000.


No



iReporting Source: 159©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.







Initiated By: FINRA







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.



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 $15,000.00.




i


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.









Initiated By: RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION




CEASE AND DESIST





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.



Resolution:


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.


Order






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.


i


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).








Initiated By: VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES ANDHEALTHCARE




CEASE AND DESIST


Docket/Case Number: DOCKET NO. 11-034-S



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).



Resolution:


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.


Order






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.


i


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).








Initiated By: NEW JERSEY BUREAU OF SECURITIES




CEASE AND DESIST





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).



Resolution:


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.


Order






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.


i


Initiated By: SOUTH DAKOTA DIVISION OF SECURITIES



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.










CEASE AND DESIST





Resolution:


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.


Order






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.


i


Initiated By: SECURITIES COMMISSIONER OF SOUTH CAROLINA




CEASE AND DESIST


Docket/Case Number: FILE NO. 10056



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.








CEASE AND DESIST


Resolution:


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.


Order







i


Initiated By: PUERTO RICO OFFICE OF THE COMMISSIONER OF FINANCIALINSTITUTIONS




CEASE AND DESIST


Docket/Case Number: C11 - ND - 008



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.



Resolution: Order







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.



i








Initiated By: ALABAMA SECURITIES COMMISSION




CEASE AND DESIST


Docket/Case Number: NO. C0-2011


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:


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.


Order






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.


i


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







Initiated By: STATE OF NEVADA, SECRETARY OF STATE, SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: MATTER NO. I11-142



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:


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.


Order





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.


i


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.







Initiated By: STATE OF INDIANA, SECRETARY OF STATE, SECURITIES DIVISION




CEASE AND DESIST


Docket/Case Number: 11-0210 CO



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:


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.


Order






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.


i


Initiated By: TEXAS





Docket/Case Number: ORDER NO. IC11-FIN-08




Allegations: INEQUITABLE PRACTICES AND FAILURE TO SUPERVISE AGENTS INCONNECTION WITH THE SALE OF AUCTION RATE SECURITIES PRIOR TOFEBRUARY 13, 2008.



Resolution: Consent







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.


No



Initiated By: TEXAS STATE SECURITIES BOARD


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.








Cease and Desist


FINE




Resolution:


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.


Order






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.


i


Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFFICE")




CEASE & DESIST


Docket/Case Number: 0404-S-10/08



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.



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.


No


Order






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.


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.







Initiated By: STATE OF FLORIDA - OFFICE OF FINANCIAL REGULATION


Cease and Desist


FINE; CENSURE; INVESTIGATIVE COSTS; REIMBURSEMENT OF NASAAASSISTANCE.


Docket/Case Number: 0404-S-10/08 AND 0404A-S-10/08



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:

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






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.


i


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.









Cease and Desist






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:

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]


Yes

Sanctions Ordered: CensureCease and Desist/Injunction

Order






Other Sanctions Ordered: UNDERTAKING:


A. KEY DEFINITIONS







1. OFFER NOTICES.







UNDERTAKING:


A. KEY DEFINITIONS







1. OFFER NOTICES.


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.






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.























[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.


























Cease and Desist






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.



Resolution:


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.


Order






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.


i


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.







Initiated By: FINRA







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:


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.


No











Initiated By: FINRA



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.














Resolution:






i


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.








Initiated By: FINRA







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:


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.


No









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.


Initiated By: FINRA



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.













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, 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.




i







Initiated By: FINRA






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..



Resolution:


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.


No










Initiated By: FINRA






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.



Resolution:


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.




i









Initiated By: FINRA






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:


No










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.



Initiated By: FINRA






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:


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.




i


Initiated By: FINRA







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.



Resolution:


No









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.



Initiated By: FINRA







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.



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.




i


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.







Initiated By: INDIANA SECURITIES DIVISION


Other


$60000 FINE & $27500 COSTS OF INVESTIGATION


Docket/Case Number: CAUSE NO. 05-0082 CA



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:

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.


Consent


i


Initiated By: NASD



Docket/Case Number: C07050037



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.






https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=c07050037





Resolution:


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.


No




Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)







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.









Resolution:


Sanction Details: SANCTIONS: CENSURE AND FINE OF $90,000.00.




i


Initiated By: NASD






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.



Resolution:


No








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.



Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)







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).



Resolution:


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.








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.


i


Initiated By: NASD




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.













Resolution:


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.


No




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.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.







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:


Sanction Details: SANCTIONS: CENSURE AND FINE OF $37,500.00




i


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.







Initiated By: NASD








Resolution:


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.


No



iReporting Source:








Initiated By: NATIONAL ASSOCIATION OF SRECURITIES DEALERS, INC.







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.



Resolution:


Sanction Details: SANCTIONS: FINE OF $10,000.00 - RESTITUTION: $3,924.00 PLUSINTEREST. RESTITUTION TO BE ALLOCATED BETWEEN RJA & ANGELOMASUT, JR.




i


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.








Initiated By: NASD




Docket/Case Number: CE3050007


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:


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.


No







https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=ce3050007


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.






Docket/Case Number: CE3050007



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.



Resolution:








https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=ce3050007



Sanction Details: SANCTIONS: $750,000 - RJA RESPONSIBLE FOR $224,100. RESTITUTION:$138,000 - RJA RESPONSIBLE FOR $27,025.42 + INTEREST OF $1,492.26


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Initiated By: HAWAII





Docket/Case Number: SEU-2011-13




Allegations: FAILURE TO SUPERVISE MARKETING OF ARS AS LIQUID.



Resolution:


Sanction Details: PART OF MULTISTATE SETTLEMENT, PAID IN FULL UPON EXECUTION OFCONSENT ORDER ON SEPT 16, 2014


No




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.







Initiated By: STATE OF HAWAII




CEASE & DESIST


Docket/Case Number: SEU-2011-13



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:


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.








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.


i


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS



Docket/Case Number: CMS020021



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.










Resolution:


Sanction Details: N/A











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.



Resolution:









Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, THE FIRMHERRBY ACCEPTS AND CONSENTS TO THE IMPOSITION OF A CENSUREAND A $10,000 FINE.



i


Initiated By: NYSE DIVISION OF ENFORCEMENT


Docket/Case Number: HPD#01-207



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.











Resolution:


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


Decision


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.














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:


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


Decision







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Docket/Case Number: HPD# 01-118



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.



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.


Decision






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




Docket/Case Number: HPD# 01-118


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.












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


Decision


i


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.














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:


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.




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.









Disgorgement






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:


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.




i


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.














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:

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



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.









Disgorgement


CENSURE



Principal Product Type: Debt - Government


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:


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.




i


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.







Initiated By: THE NATIONAL ASSOCIATION OF SECURITIES DEALERS







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:


Sanction Details: CENSURED AND FINED $7500.00




Initiated By: THE NATIONAL ASSOCIATION OF SECURITIES DEALERS


Censure





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.








Censure



Resolution:


Sanction Details: NONE




i


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*







Initiated By: NYSE OF ENFORCEMENT.







*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:


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.


Decision






*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.


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*









Censure






*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:


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.


Decision






*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.


i


Initiated By: DELAWARE SECURITIES DIVISION


Censure






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.








Resolution:


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.


Decision


i


Initiated By: STATE OF NORTH DAKOTA


Other



Docket/Case Number: UNKNOWN



Allegations: ALLEGED THAT FIRM OFFERED INVESTMENTS IN ROYAL CROWNCORPORATION BONDS TO RESIDENTS OF NORTH DAKOTA WHILEINVESTMENTS WERE NOT REGISTERED OR EXEMPT UNDER ND LAW.



Resolution:


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).


Decision






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).


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Initiated By: PHILADELPHIA STOCK EXCHANGE


Other






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.



Resolution:


Sanction Details: THE COMMITTEE DETERMINED TO ACCEPT RESPONDENT'S OFFER OFSETTLEMENT AND DIRECTS THE IMPOSITION OF A FINE OF $1,500.00.


Decision


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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.







Initiated By: COMMONWEALTH OF VIRGINIA, EX REL.


Other


MONETARY PENALTY(IES)/FINE(S)


Docket/Case Number: SEC940057



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:


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.


Decision


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Initiated By: CHICAGO BOARD OF OPTION EXCHANGE





Allegations: THE ALLEGATIONS INVOLVED THE CONDUCTING OF BUSINESS WITHCUSTOMERS WITHOUT STRICT ADHERENCE TO PROPER PROCEDURES ASSPELLED OUT IN THE RULES OF THE EXCHANGE.








Other


CIVIL AND ADMINISTRATIVE PENALTY (IES)/FINE(S)



Resolution:


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.


Decision


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Initiated By: GEORGIA SECURITY COMMISSION


Prohibition


CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S), OTHER FINANCIAL.





Allegations: ALLEGED SERVICING OF CLIENTS ACCOUNTS BY UNREGISTEREDAGENTS.



Resolution:


Decision






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.



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Initiated By: STATE OF INDIANA


Cease and Desist




Docket/Case Number: 85-0082CA



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.



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.


Decision


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Censure


$7,000.00 FINE





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)



Resolution:


Sanction Details: $7,000.00 FINE; CENSURE

Regulator Statement 02-08-00, $7,000 PAID ON 8/24/99, INVOICE #99-MS-701











Censure






Allegations: FAILED TO EXECUTE ORDERS, AND FAILURE TO SUPERVISE.



Resolution:


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).




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Docket/Case Number:

Principal Product Type:

Allegations:












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




Reprimand





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.



Resolution:

Other Sanctions Ordered: LETTER OF REPRIMAND

Sanctions Ordered:







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.


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Initiated By: SECURITIES AND EXCHANGE COMMISSION




Docket/Case Number:



Allegations: TRADED NASDAQ STOCKS FOR ITS OWN ACCOUNTS AND FOR THEACCOUNTS OF INSTITUTIONAL AND RETAIL INVESTORS.



Resolution:


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







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)


Initiated By: SECURITIES AND EXCHANGE COMMISSION



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.








Cease and Desist






Resolution:


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


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Docket/Case Number: CMS980069 AWC



Allegations:









Resolution:


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 ******




Allegations: ALLEGED FAILURE TO EXECUTE ORDERS AND FAILED TO SUPERVISE.









Censure






Allegations: ALLEGED FAILURE TO EXECUTE ORDERS AND FAILED TO SUPERVISE.


Resolution:


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).




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Allegations: VIOLATIONS OF MARKETPLACE RULE 4632(A); 6620(A); 4642(A);6130(B);AND NASD CONDUCT RULE 2110 AND IM 2110-2;3010









Resolution:


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.











Censure



Docket/Case Number: CMS970065-AWC



Allegations: OTC TRADE REPORTING VIOLATIONS AND FAILURE TO SUPERVISE.



Resolution:


Sanction Details: NOTICE OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED. RJAWAS CENSURED AND FINED $17,500.00.




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Docket/Case Number: CAF970006



Allegations:










Resolution:


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)






Censure



Docket/Case Number: CAF970006



Allegations: VIOLATIONS OF MSRB RULES G-36 AND G-8(A)(XV)



Resolution: Consent








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).



i


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.







Initiated By: NYSE DIVISION OF ENFORCEMENT NYSE DIVISIONOF ENFOR*See FAQ #1*







**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:


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.


Consent






**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.


Initiated By: NEW YORK STOCK EXCHANGE


Censure






Allegations: BOOKS AND RECORDS VIOLATION(S); FAILURE TO MEET FINANCIALSTANDARDS; FAILURE TO SUPERVISE; FAILURE TO FILE FINANCIALREPORTS.









Resolution:


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.


Consent


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Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECT*See FAQ #1*



Docket/Case Number: 2083-S-9/94




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.










Resolution:


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.


Decision


Initiated By: STATE OF FLORIDA


Docket/Case Number: 2083-S-9/94 & 2084-S-9/94



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.








Cease and Desist



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


Decision


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Docket/Case Number: N-V-309



Allegations:



Resolution:


Sanction Details:

Sanctions Ordered: Monetary/Fine $25.00

Decision






Sanction Details:

Regulator Statement NASDAQ COMPLAINT N-V-309 FILED 6-12-73 10-1-73 FINED $25.0011-15-73 FINAL









Other Product Type(s): UNKNOW - CRD DATA CONVERSION

Allegations: FAILED TO REPORT ITS NASDAQ VOLUME.



Resolution:


Sanction Details: RJA WAS FINED $25.00. FINE PAID: 11/15/1973.


Decision


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Docket/Case Number: DEC. 78-84



Allegations:











Resolution:


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)


Consent




Censure



Docket/Case Number: DEC. 78-84


Other Product Type(s): UNKNOWN - CRD DATE CONVERSION

Allegations: ALLEGED CONDUCT INCONSISTENT WITH JUST AND EQUITABLEPRINCIPALS OF TRADE.



Resolution: Consent








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.



i






Docket/Case Number: AWC-47



Allegations:



Resolution:


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





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.




Censure



Docket/Case Number: AWC-47



Allegations: MAINTAINED INACCURATE NASDAQ VOLUME REPORTS.



Resolution:


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.


Consent


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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.







Initiated By: MASSACHUSETTS SECURITIES DIVISION




Docket/Case Number: 92-007-E




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:


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.


Consent






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


Initiated By: COMMONWEALTH OF MASSACHUSETTS


Disgorgement



Docket/Case Number: 92-007-E



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.



Resolution:


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.


Consent





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.


i









Allegations:



Resolution:


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.


Consent






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.




Censure






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").



Resolution:


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.


Consent


i



Allegations:















Resolution:


Sanction Details:

Regulator Statement NASDAQ COMPLAINT N-V-89 FILED 03/15/7207/10/72 FINED $2507/20/72 PAID FINE08/24/72 FINAL


Decision












Resolution: Decision264©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.






Resolution:


Sanction Details: RAYMOND JAMES & ASSOCIATES, INC. ON 07/10/1971 WAS FINED $25.00.FINE PAID: 07/20/1972.


Decision


i






Docket/Case Number: CMS930022 A.W.C.



Allegations:



Resolution:


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**


Consent






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**




Censure


MONETARY PENALTY(IES/FINE(S)


Docket/Case Number: CMS930022 A.W.C.



Allegations: THE MARKET SURVEILLANCE COMMITTEE ALLEGES TRADE REPORTINGVIOLATIONS AND PRICE AND VOLUME VIOLATIONS DURING THE PERIODOF MAY 1, 1992 THROUGH MAY 22, 1992.



Resolution:


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.


Consent


i


Allegations: FAILURE TO DESIGNATED MANAGER, BOOKS ANDRECORDS VIOLATIONS, UNREGISTERED BRANCH OFFICE MANAGER,FAILURETO SUPERVISE.







Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECT*See FAQ #1*




Docket/Case Number: 1547-S-791




Allegations: FAILURE TO DESIGNATED MANAGER, BOOKS ANDRECORDS VIOLATIONS, UNREGISTERED BRANCH OFFICE MANAGER,FAILURETO SUPERVISE.


Resolution:


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


Consent


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.








Censure


MONETARY FINE


Docket/Case Number: 91-187-DOS




Resolution:


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.


Decision


i






Docket/Case Number: MS-902 AWC



Allegations:








Resolution:


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***


Consent







Docket/Case Number: MS-902-AWC






Resolution:


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.


Consent






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.


i






Docket/Case Number: 87-0121(A)


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.



Resolution: Settled







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.





Censure




Docket/Case Number: 87-0121(2) & (C)


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.



Resolution:


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.


Consent


i















Allegations:



Resolution:


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


Consent


Allegations: ALLEGING VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRJA FAILED TO REPORT ITS NASDAQ VOLUME.









Other







Allegations: ALLEGING VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRJA FAILED TO REPORT ITS NASDAQ VOLUME.


Resolution:


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.


Consent


i









Allegations:








Resolution:


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


Consent










Allegations: FAILED TO REPORT ITS NASDQ VOLUME.



Resolution: Consent








Sanction Details: VIOLATIONS OF PART VI, SECTION 4(A) OF THE ASSOCIATION'S RULES OFFAIR PRACTICE. FINED RJA $500.00. PAID: 12/23/1987.



i






Docket/Case Number: MS-437



Allegations:



Resolution:


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.


Consent






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.


Initiated By: NATIONAL ASOCIATION OF SECURITIES DEALERS, INC.


Censure




Docket/Case Number: MS-437



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.



Resolution: Consent








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.



i









Allegations:



Resolution:


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


Consent






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










Allegations: BY MARKET SURVEILLANCE COMMITTEE - FAILED TO REPORT ITS NASDAQVOLUME.



Resolution:


Sanction Details: RJA CONSENTED TO A FINE OF $250.00.


Consent


i





Docket/Case Number: ATL-707-SC



Allegations:










Resolution:


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.


Decision




Censure



Docket/Case Number: ATL-707-SC



Allegations: ALLEGES VIOLATION OF SECTION 1, ARTICLE III OF THE ASSOCIATION'SRULES OF FAIR PRACTICE WITH RESPECT TO FREE-RIDING ANDWITHHOLDING REGARDING "HOT ISSUE".



Resolution: Decision








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.



i






Docket/Case Number: ATL-329



Allegations:



Resolution:


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


Decision






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




Censure


OTHER FINANCIAL


Docket/Case Number: ATL-329



Allegations: SALES MATERIAL NOT CONFORMING TO SEC STATEMENT OF POLICY.



Resolution:

Other Sanctions Ordered: OTHER FINANCIAL: $16.00

Sanction Details: RJA WAS CENSURED AND FINED $250.00 PLUS COSTS OF $16.00.


Decision






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


Initiated By: NYSE AMERICAN LLC






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









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:


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






Initiated By: NYSE AMERICAN LLC







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.


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:






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)






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


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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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



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


$336,703.21 286©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.




www.finra.org/awardsonline

https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=00-02925




Disposition:

Disposition Date:


$336,703.21

AWARD AGAINST PARTY

04/08/2002

$47,300.00


Disclosure 3 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/06/2001

01-01043

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE


$500,000.00

AWARD AGAINST PARTY

03/21/2002

$185,000.00


Disclosure 4 of 73

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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








Case Number:



Disposition:

Disposition Date:


01-01632

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$50,000.00

AWARD AGAINST PARTY

02/11/2002

$880.00


Disclosure 5 of 73

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/24/2001

01-05256

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$13,000,000.00

AWARD AGAINST PARTY

12/08/2004

$432,014.77


Disclosure 6 of 73

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Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


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


Disclosure 7 of 73

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/03/2002

02-02874

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE


$40,592.86

AWARD AGAINST PARTY

05/27/2003

$30,000.00


Disclosure 8 of 73

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 9 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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









Disclosure 10 of 73

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/22/2002

02-04717

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE


Unspecified Damages

AWARD AGAINST PARTY

04/29/2004

$45,300.01


Disclosure 11 of 73

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/25/2002

02-04989

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$400,000.00

AWARD AGAINST PARTY

02/19/2004

$395,965.00









Disclosure 12 of 73

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/14/2002

02-06610

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE


$266,286.75

AWARD AGAINST PARTY

12/18/2003

$198,285.74


Disclosure 13 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

04/15/2003

02-07764

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE


$1,000,000.00

AWARD AGAINST PARTY

10/13/2004 292©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.







Disposition Date:


10/13/2004

$290,000.00


Disclosure 14 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/04/2003

03-03225

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$10,853.00

AWARD AGAINST PARTY

01/02/2004

$11,277.79


Disclosure 15 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



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









Disposition:

Disposition Date:


AWARD AGAINST PARTY

09/30/2005


Disclosure 16 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


$650,000.00

AWARD AGAINST PARTY

06/19/2007

$39,375.00


Disclosure 17 of 73

i



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








Case Number:



Disposition:

Disposition Date:


08-00750


$13,458.13

AWARD AGAINST PARTY

11/12/2008

$13,670.63


Disclosure 18 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 19 of 73

i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


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


Disclosure 20 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 21 of 73

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 22 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


$12,000,000.00

AWARD AGAINST PARTY

07/19/2010

$0.00297©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.







Sum of All Relief Awarded: $0.00


Disclosure 23 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

09/17/2009

09-04932



$5,400,000.00

AWARD AGAINST PARTY

11/10/2010

$0.00


Disclosure 24 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


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










Disposition:

Disposition Date:


$518,203.70

AWARD AGAINST PARTY

05/24/2012

$518,203.70


Disclosure 25 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 26 of 73

i



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







Case Initiated:

Case Number:



Disposition:

Disposition Date:


12/04/2012

12-03949

COLLATERALIZED MORTGAGE OBLIGATIONS

$13,000,000.00

AWARD AGAINST PARTY

06/09/2015

$10,000.00


Disclosure 27 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 28 of 73

i



Arbitration Forum:

Allegations:

FINRA

ACCOUNT RELATED-OTHER








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

05/02/2013

13-01233

AWARD AGAINST PARTY

11/08/2013


Disclosure 29 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

07/11/2014

14-02056

ACCOUNT ACTIVITY-CHURNING

$2,006,596.00

AWARD AGAINST PARTY

02/24/2017

$761,770.97


Disclosure 30 of 73

i



Arbitration Forum:

Allegations:

FINRA

ACCOUNT RELATED-BREACH OF CONTRACT








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

08/15/2014

14-02440

COMMON STOCK

$36,138.00

AWARD AGAINST PARTY

04/30/2015

$12,146.00


Disclosure 31 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 32 of 73

i



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








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


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


Disclosure 33 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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









Disclosure 34 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/05/1988

88-01940

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$72,000.00

AWARD AGAINST PARTY

05/23/1991

$43,896.38


Disclosure 35 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1988

88-03619

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$21,200.00

AWARD AGAINST PARTY

01/24/1990

$7,000.00









Disclosure 36 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/31/1989

88-03886

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$935,460.00

AWARD AGAINST PARTY

04/24/1991

$22,914.23


Disclosure 37 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

01/01/1989

89-00427


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.







Disposition Date:


06/12/1990

$3,400.00


Disclosure 38 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1989

89-00800



$3,750.00

AWARD AGAINST PARTY

06/12/1990

$7,600.00


Disclosure 39 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



NASD

01/01/1989

89-00801



$16,550.00 306©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.








Disposition:

Disposition Date:


$16,550.00

AWARD AGAINST PARTY

06/12/1990

$19,100.00


Disclosure 40 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1989

89-00802



$4,000.00

AWARD AGAINST PARTY

06/12/1990

$7,800.00


Disclosure 41 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

08/27/1990

90-02329

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-COMPENSATION; EMPLOYMENT-OTHER








Case Number:



Disposition:

Disposition Date:


90-02329


$432,000.00

AWARD AGAINST PARTY

07/11/1991

$77,500.00


Disclosure 42 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 43 of 73

i



Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; UNKNOWN TYPE OF CONTROVERSIES








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

12/07/1990

90-03355

LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES

$7,196.00

AWARD AGAINST PARTY

10/31/1991

$7,075.25


Disclosure 44 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 45 of 73

i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 46 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 47 of 73

i








Disclosure 47 of 73



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 48 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/10/1993

93-02886

ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$3,455.20

AWARD AGAINST PARTY

05/26/1994

$3,455.20









Disclosure 49 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/27/1993

93-04855

ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$500,000.01

AWARD AGAINST PARTY

10/17/1996

$115,000.00


Disclosure 50 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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









Disclosure 51 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 52 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



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


$50,000.00

AWARD AGAINST PARTY313©2018 FINRA. All rights reserved. Report about RAYMOND JAMES & ASSOCIATES, INC.







Disposition:

Disposition Date:


AWARD AGAINST PARTY

08/08/1995

$67,500.00


Disclosure 53 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 54 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


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.









Disposition:

Disposition Date:



$25,000.00

AWARD AGAINST PARTY

06/14/1996

$6,615.00


Disclosure 55 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


Disclosure 56 of 73

i



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







Case Initiated:

Case Number:



Disposition:

Disposition Date:


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


Disclosure 57 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/25/1995

95-01847

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$251,953.79

AWARD AGAINST PARTY

12/15/1997

$10,750.00


Disclosure 58 of 73

i



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.







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

07/20/1995

95-03212

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE


$15,339.15

AWARD AGAINST PARTY

08/02/1996

$17,000.00


Disclosure 59 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/03/1995

95-03735



$579,000.00

AWARD AGAINST PARTY

05/21/1997

$125,000.00


Disclosure 60 of 73

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/19/1995

95-04412

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; DO NOT USE-OTHER-OTHER ; OTHER-CLEARING DISPUTES; TRADING DISPUTES-OTHER


$75,335.50

AWARD AGAINST PARTY

01/10/1997

$75,335.50


Disclosure 61 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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









Disclosure 62 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/03/1996

96-01571

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT


$14,400.00

AWARD AGAINST PARTY

06/12/1997

$13,123.00


Disclosure 63 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



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


$306,157.18

AWARD AGAINST PARTY

05/28/1999








Sum of All Relief Awarded: $58,600.00


Disclosure 64 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/30/1996

96-02817

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE


$1,000,000.00

AWARD AGAINST PARTY

05/30/1997

$0.00


Disclosure 65 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



NASD

08/28/1996

96-03229

ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$1,000,000.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

03/19/1998

$1,000.00


Disclosure 66 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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


$28,560.00

AWARD AGAINST PARTY

10/08/1997

$3,200.00


Disclosure 67 of 73

i



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








Case Number:



Disposition:

Disposition Date:


97-00052


$17,000.00

AWARD AGAINST PARTY

02/24/1998

$12,500.00


Disclosure 68 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/07/1997

97-01823

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$7,000.00

AWARD AGAINST PARTY

12/10/1997

$75.00


Disclosure 69 of 73

i



Arbitration Forum:

Allegations:

NASD









Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

06/19/1998

98-02107


$58,052.30

AWARD AGAINST PARTY

10/20/1999

$40,000.00


Disclosure 70 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/17/1998

98-04207



$82,430.00

AWARD AGAINST PARTY

03/24/2000

$78,356.03


Disclosure 71 of 73

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/03/1999

99-01630

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$5,000,000.00

AWARD AGAINST PARTY

03/21/2000

$397,508.00


Disclosure 72 of 73

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/31/1999

99-05560

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$25,059.00

AWARD AGAINST PARTY

04/18/2000

$1,584.00


Disclosure 73 of 73

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


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








End of Report

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