wintrust investments llc - finra · wintrust investments llc sec# 875 8-484 main office location...

BrokerCheck Report

WINTRUST INVESTMENTS LLC

Section Title

Report Summary

Firm History

CRD# 875

1

11

Firm Profile 2 - 10

Page(s)

Firm Operations 12 - 19

Disclosure Events 20

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CRD# 875

SEC# 8-484

Main Office Location

231 SOUTH LASALLE STREET13TH FLOORCHICAGO, IL 60604Regulated by FINRA Chicago Office

Mailing Address

P.O. BOX 750CHICAGO, IL 60690-0750

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

312-431-6569

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 5

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in Delaware on 01/31/1996.

Its fiscal year ends in December.

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 14 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

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

This firm is registered with:

• the SEC• 2 Self-Regulatory Organizations• 52 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about WINTRUST INVESTMENTS LLC

https://adviserinfo.sec.gov/firm/summary/875


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This firm is classified as a limited liability company.

This firm was formed in Delaware on 01/31/1996.

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 December.


SEC#

875

8-484

Main Office Location

Mailing Address

Business Telephone Number

Doing business as WINTRUST INVESTMENTS LLC

312-431-6569

Regulated by FINRA Chicago Office

231 SOUTH LASALLE STREET13TH FLOORCHICAGO, IL 60604

P.O. BOX 750CHICAGO, IL 60690-0750

Other Names of this Firm

Name Where is it used

FCB ADVISORS AK, AR, AZ, CA, CO,DC, FL, GA, HI, IL,KS, KY, LA, MD, MI,MN, MO, MT, NC,NE, NJ, NV, OH, OK,PA, RI, SC, SD, TN,TX, VA, WA, WI

GRUNDY INVESTMENTS CA, GA, IL, IN, MO,NC, PA, RI, TX, VA






INVESTMENT SERVICES - A DIVISION OF MORTON COMMUNITYBANK

AL, AZ, CA, CO, FL,ID, IL, IN, MI, MN,MS, NC, NE, NV, OH,OK, PA, TN, TX, WA,WY

WAYNE HUMMER INSURANCE AGENCY, LLC CA

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

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

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





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?

WINTRUST BANK

SOLE DIRECT OWNER

75% or more

No

Domestic Entity

10/2002

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


CARLISLE, PAUL CLAYTON

DIRECTOR

Less than 5%

No

Individual

01/2014

Yes

6314743



Position


Position Start Date

CORBETT, JAMES EDWARD

CHIEF OPERATIONS OFFICER

Less than 5%

Individual

06/2018

2371982








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


GETZ, BERT ATWATER JR

DIRECTOR

Less than 5%

No

Individual

01/2005

Yes

4588181



Position



Position Start Date


GLABE, MARLA FRIEDMAN

DIRECTOR

Less than 5%

No

Individual

09/2009

Yes

2339176



HEITMANN, SCOTT KEITH

2351200








Firm Profile

Position



Position Start Date


DIRECTOR

Less than 5%

No

Individual

07/2008

Yes

2351200


Position



Position Start Date


HUGHES, TERRANCE GREGORY

DIRECTOR OF SALES

Less than 5%

No

Individual

01/2013

Yes

2823480



Position


Position Start Date


KAMRADT, MICHAEL PAUL

DIRECTOR

Less than 5%

Individual

01/2019

Yes

1562014









Firm Profile



No

Yes

Position



Position Start Date


KIERNAN, THOMAS JOSEPH

MUNICIPAL PRINCIPAL

Less than 5%

No

Individual

03/1998

No

714859



Position



Position Start Date


MCKINNEY, SUZET MEYLIEU

DIRECTOR

Less than 5%

No

Individual

01/2019

Yes

7069598



ROLDAN, CELENA

Individual

7069597









Firm Profile

Position



Position Start Date


DIRECTOR

Less than 5%

No

Individual

01/2019

Yes


Position



Position Start Date


SILVER, ELLIOTT JOSEPH

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

03/2005

Yes

1594446



Position


Position Start Date


SMYTH, MICHAEL J

CHIEF FINANCIAL OFFICER

Less than 5%

Individual

03/2019

Yes

2802717









Firm Profile



No

Yes

Position



Position Start Date


SOMMERFIELD, JAMES ALFRED JR

SR. COMPLIANCE OFFICER, INSURANCE PRINCIPAL

Less than 5%

No

Individual

03/2005

No

2841304



Position



Position Start Date


ZIDAR, THOMAS PATRICK

CHAIRMAN & CEO

Less than 5%

No

Individual

09/2006

Yes

2128329








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

Indirect Owners

Firm Profile

WINTRUST FINANCIAL CORPORATION

SOLE OWNER

WINTRUST BANK

75% or more

Yes

Domestic Entity

09/1994

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









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, 2 SROs and 52 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 05/02/1954

Self-Regulatory Organization Status Date Effective

FINRA Approved 10/16/1936

NYSE Chicago, Inc. Approved 12/11/1933






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 11/12/1996

Alaska Approved 06/08/1982

Arizona Approved 03/31/1982

Arkansas Approved 04/01/1996

California Approved 04/04/1996

Colorado Approved 02/01/1983

Connecticut Approved 05/28/1982

Delaware Approved 04/15/1982

District of Columbia Approved 06/21/1986

Florida Approved 04/27/1983

Georgia Approved 04/08/1982

Hawaii Approved 04/01/1996

Idaho Approved 05/04/1982

Illinois Approved 07/01/1952

Indiana Approved 04/16/1982

Iowa Approved 07/14/1983

Kansas Approved 04/01/1982

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 02/09/1984

Maryland Approved 05/25/1982

Massachusetts Approved 04/13/1982

Michigan Approved 02/28/1996

Minnesota Approved 07/15/1982

Mississippi Approved 05/25/1982

Missouri Approved 07/15/1983

Montana Approved 04/20/1983

Nebraska Approved 04/01/1996

Nevada Approved 07/14/1983

New Hampshire Approved 09/30/1983

New Jersey Approved 05/25/1982

New Mexico Approved 06/16/1982

New York Approved 04/01/1996

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 04/27/1982

Ohio Approved 07/16/1982

Oklahoma Approved 07/27/1982

Oregon Approved 05/24/1982

Pennsylvania Approved 04/12/1982

Rhode Island Approved 02/01/1983

South Carolina Approved 04/08/1982

South Dakota Approved 07/15/1982

Tennessee Approved 04/19/1982

Texas Approved 05/20/1996

Utah Approved 04/21/1983

Vermont Approved 02/13/1984

Virgin Islands Approved 01/28/2008

Virginia Approved 03/25/1982

Washington Approved 04/20/1983

West Virginia Approved 05/24/1982

Wisconsin Approved 05/01/1969

Wyoming Approved 04/30/1982






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

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

Non-Securities Business Description: LIFE INSURANCEFIXED ANNUITIES

This firm currently conducts 14 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

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 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

Put and call broker or dealer or option writer

Investment advisory services

Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union

Other - SERVICE FEESMARGIN DEBITS/LOANSINSURED BANK DEPOSITS PROGRAMBROKERED CDSVARIABLE ANNUITIESINDEXED ANNUITIES






Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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

Name: WELLS FARGO CLEARING SERVICES, LLC

Business Address: 1 NORTH JEFFERSON STREETST. LOUIS, MO 63103

CRD #: 19616

Effective Date: 07/21/2004

Description: WAYNE HUMMER HAS ENTERED INTO AN AGREEMENT WITH WELLSFARGO CLEARING SERVICES, LLC (FORMERLY FIRST CLEARING, LLC)TO PROVIDE CLEARING SERVICES. WAYNE HUMMER DOES NOTMAINTAIN CUSTODY OF CUSTOMER FUNDS OR SECURITIES. ALLACCOUNTS ARE CARRIED AT WELLS FARGO CLEARING SERVICES, LLC.ON NOVEMBER 14TH, 2016, FIRST CLEARING, LLC CHANGED ITS NAMETO WELLS FARGO CLEARING SERVICES.






Firm Operations

Industry Arrangements

This firm does 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 have customer accounts, funds, or securities maintained by a third party.



CRD #: 19616





CRD #: 19616





CRD #: 19616


Description: WAYNE HUMMER HAS ENTERED INTO AN AGREEMENT WITH WELLSFARGO CLEARING SERVICES, LLC (FORMERLY FIRST CLEARING, LLC)TO PROVIDE CLEARING SERVICES. WAYNE HUMMER DOES NOTMAINTAIN CUSTODY OF CUSTOMER FUNDS OR SECURITIES. ALLACCOUNTS ARE CARRIED AT WELLS FARGO CLEARING SERVICES,LLC.ON NOVEMBER 14TH, 2016, FIRST CLEARING, LLC CHANGED ITSNAME TO WELLS FARGO CLEARING SERVICES.






Firm Operations

Industry Arrangements (continued)

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

Description: WAYNE HUMMER HAS ENTERED INTO AN AGREEMENT WITH WELLSFARGO CLEARING SERVICES, LLC (FORMERLY FIRST CLEARING, LLC)TO PROVIDE CLEARING SERVICES. WAYNE HUMMER DOES NOTMAINTAIN CUSTODY OF CUSTOMER FUNDS OR SECURITIES. ALLACCOUNTS ARE CARRIED AT WELLS FARGO CLEARING SERVICES,LLC.ON NOVEMBER 14TH, 2016, FIRST CLEARING, LLC CHANGED ITSNAME TO WELLS FARGO CLEARING SERVICES.






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

No

10/01/2002

231 S. LASALLE STREET13TH FLOORCHICAGO, IL 60604

THE CHICAGO TRUST COMPANY is under common control with the firm.

WINTRUST FINANCIAL CORPORATION CONTROLS 100% OF WINTRUSTBANK, WHICH CONTROLS 100% OF WAYNE HUMMER INVESTMENTS.WINTRUST, AN INDIRECT OWNER OF WAYNE HUMMER INVESTMENTS,OWNS 100% OF THE CHICAGO TRUST COMPANY (FORMERLY WAYNEHUMMER TRUST COMPANY).

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

No

02/20/2002

231 S. LASALLE STREET4TH FLOORCHICAGO, IL 60604

110757

GREAT LAKES ADVISORS, LLC is under common control with the firm.


Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

Yes

GREAT LAKES ADVISORS, LLC (FORMERLY WINTRUST CAPITALMANAGEMENT & WAYNE HUMMER ASSET MANAGEMENT COMPANY) IS ADELAWARE LLC AND INVESTMENT ADVISOR REGISTERED WITH THESECURITIES AND EXCHANGE COMMISSION, AND IS AN AFFILIATE OFWAYNE HUMMER INVESTMENTS LLC. IT IS WHOLLY OWNED BY WINTRUSTFINANCIAL CORPORATION.

Description:


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: WINTRUST BANK (FORMERLY NORTH SHORE COMMUNITY BANK ANDTRUST) IS THE SOLE DIRECT OWNER OF WAYNE HUMMER INVESTMENTSLLC.

WINTRUST BANK is a State Member Bank of the Federal Reserve System and controls the firm.

10/01/2002

1145 WILMETTE AVENUEWILMETTE, IL 60091

Effective Date:

Business Address:

Description: WINTRUST FINANCIAL CORPORATION IS SOLE OWNER OF WINTRUSTBANK AND THEREFORE AN INDIRECT OWNER OF WAYNE HUMMERINVESTMENTS LLC.

WINTRUST FINANCIAL CORPORATION is a Bank Holding Company and controls the firm.

02/20/2002

9700 WEST HIGGINS ROADROSEMONT, IL 60018






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 5 0






Disclosure Event Details

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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.

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§ 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 5

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, INTRANSACTIONS INVOLVING MUNICIPAL SECURITIES, IT FAILED TOEXERCISE REASONABLE DILIGENCE IN ASCERTAINING THE BEST MARKETAND SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO THECUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FINDINGS STATED THAT IN THESE INSTANCES,THE FIRM, ACTING IN A PRINCIPAL CAPACITY, RELIED EXCLUSIVELY ON AVENDOR'S PROPRIETARY YIELD CURVE TO DETERMINE THETRANSACTION PRICE. IN SO DOING, THE FIRM FAILED TO CONSIDER ALLOF THE MSRB RULE G-18(A) FACTORS AND IGNOREDCONTEMPORANEOUS INTER-DEALER TRANSACTIONS IN THATPARTICULAR SECURITY. THE FINDINGS ALSO STATED THAT THE FIRMCHARGED UNFAIR AND UNREASONABLE MARK-UPS FOR THESETRANSACTIONS. IN MOST OF THE INSTANCES, THE FIRM CHARGED AMARK-UP IN EXCESS OF FIVE PERCENT. THE FIRM PROVIDED EVIDENCETHAT IT HAS MADE FULL RESTITUTION IN THE AMOUNT OF $18,925 TO ITSCUSTOMERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM DID NOTHAVE A REASONABLE SUPERVISORY SYSTEM, INCLUDING WSPS, TOACHIEVE COMPLIANCE WITH ITS BEST EXECUTION OBLIGATIONS.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 01/03/2020

Docket/Case Number: 2017053470801

Principal Product Type: Debt - Municipal

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, INTRANSACTIONS INVOLVING MUNICIPAL SECURITIES, IT FAILED TOEXERCISE REASONABLE DILIGENCE IN ASCERTAINING THE BEST MARKETAND SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO THECUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FINDINGS STATED THAT IN THESE INSTANCES,THE FIRM, ACTING IN A PRINCIPAL CAPACITY, RELIED EXCLUSIVELY ON AVENDOR'S PROPRIETARY YIELD CURVE TO DETERMINE THETRANSACTION PRICE. IN SO DOING, THE FIRM FAILED TO CONSIDER ALLOF THE MSRB RULE G-18(A) FACTORS AND IGNOREDCONTEMPORANEOUS INTER-DEALER TRANSACTIONS IN THATPARTICULAR SECURITY. THE FINDINGS ALSO STATED THAT THE FIRMCHARGED UNFAIR AND UNREASONABLE MARK-UPS FOR THESETRANSACTIONS. IN MOST OF THE INSTANCES, THE FIRM CHARGED AMARK-UP IN EXCESS OF FIVE PERCENT. THE FIRM PROVIDED EVIDENCETHAT IT HAS MADE FULL RESTITUTION IN THE AMOUNT OF $18,925 TO ITSCUSTOMERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM DID NOTHAVE A REASONABLE SUPERVISORY SYSTEM, INCLUDING WSPS, TOACHIEVE COMPLIANCE WITH ITS BEST EXECUTION OBLIGATIONS.

Resolution Date: 01/03/2020

Resolution:

Other Sanctions Ordered: UNDERTAKING

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

No

Sanctions Ordered: CensureMonetary/Fine $35,000.00

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2017053470801


Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $35,000 AND REQUIRED TO REVISE ITSWSPS. FINE PAID IN FULL ON 1/23/2020.

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)


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


CENSURE





Allegations: ALLEGATIONS THAT THE FIRM FAILED TO EXERCISE REASONABLE DUEDILIGENCE TO ASCERTAIN BEST EXECUTION UNDER PREVAILING MARKETCONDITIONS AND FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEMTO ACHIEVE COMPLIANCE WITH BEST EXECUTION OBLIGATIONS.



Resolution:

Other Sanctions Ordered: UPDATE FIRM POLICIES AND PROCEDURES

Sanction Details: FIRM ENTERED INTO AWC AND PAID FINE AMOUNT. RESTITUTION WASPAID TO CLIENTS PRIOR TO AWC.

Firm Statement WITHOUT ADMITTING OR DENYING GUILT, FIRM ENTERED INTO AWC WITHFINRA. RESTITUTION WAS PROVIDED TO CLIENTS AFFECTED. CASE ISFINAL



Disclosure 2 of 5

i


Allegations: MSRB RULES G-17, G-30(A) - WAYNE HUMMER INVESTMENTS L.L.C., INPAIRS OF TRANSACTIONS, SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANYMARKUP)THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION 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 THETRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTION.








Initiated By: FINRA







Allegations: MSRB RULES G-17, G-30(A) - WAYNE HUMMER INVESTMENTS L.L.C., INPAIRS OF TRANSACTIONS, SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANYMARKUP)THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION 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 THETRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTION.


Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 FOR VIOLATION OFMSRB RULES AND ORDERED TO PAY $2,014.89, PLUS INTEREST, INRESTITUTION TO CUSTOMERS. A REGISTERED PRINCIPAL OF 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

Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution







www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 FOR VIOLATION OFMSRB RULES AND ORDERED TO PAY $2,014.89, PLUS INTEREST, INRESTITUTION TO CUSTOMERS. A REGISTERED PRINCIPAL OF 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.


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)




CENSURE AND RESTITUTION





Allegations: ALLEGATIONS STATE THAT FOR 5 TRANSACTIONS DURING Q4 2008,HUMMER SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TOCUSTOMERS AT AN AGGREGATE PRICE THAT WAS NOT FAIR ANDREASONABLE; VIOLATIONS OF MSRB RULE G-17 AND G-30(A).



Resolution:


Sanction Details: FIRM ENTERED INTO AWC, PROVIDED RESTITUTION TO AFFECTEDCLIENTS, AND PAID FINE AMOUNT.

Firm Statement WITHOUT ADMITTING OR DENYING GUILT, FIRM ENTERED INTO AWC WITHFINRA. RESTITUTION WAS PROVIDED TO CLIENTS AFFECTED. CASE ISFINAL.

Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution


Disclosure 3 of 5

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Disclosure 3 of 5


Initiated By: NASD




Docket/Case Number: CMS040042

Principal Product Type: No Product


Allegations: NASD CONDUCT RULE 2110, 3010 AND 3360 - RESPONDENT MEMBERFAILED TO REPORT ITS SHORT INTEREST POSITIONS TO NASD FORNASDAQ NATIONAL MARKET SECURITIES FROM APRIL 2000 THROUGHOCTOBER 2002; FAILED TO REPORT SHORT INTEREST FOR 15 DIFFERENTSECURITIES TOTALING 25,740 SHARES DURING THE REVIEW PERIOD.RESPONDENT MEMBER'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONSCONCERNING THE TIMELY REPORTING OF SHORT INTEREST POSITIONS.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WAYNE HUMMERINVESTMENTS, LLC CONSENTED TO THE FINDING OF THE ALLEGATIONSAND TO THE FOLLOWING SANCTIONS: CENSURE AND $15,000.00 FINE($10,000 FOR THE SHORT INTEREST REPORTING VIOLATIONS AND $5,000FOR THE SUPERVISION VIOLATION)


No









Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.





Docket/Case Number: CMS040042AWC

Principal Product Type: Equity Listed (Common & Preferred Stock)


Allegations: WAYN FAILED TO REPORT ITS SHORT INTEREST POSITION TO NASD FORNASDAQ NMS SECURITIES FROM APRIL 2000 THROUGH OCTOBER 2002.WAYN FAILED TO REPORT SHORT INTEREST FOR 15 DIFFERENTSECURITIES DURING THE PERIOD.SUPERVISORY SYSTEM WAS DEFICIENT REGARDING SHORT REPORTING.



Resolution:


Sanction Details: $15000 PAYMENT WAS MADE.



Disclosure 4 of 5

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Reporting Source: Firm

Initiated By: STATE OF MINNESOTA, DEPARTMENT OF COMMERCE, SECURITIESDIVISION


Allegations: BY MAILING "STOCK MARKET LETTERS" TO PERSONS IN STATE, FIRMTRANSACTED OR OFFERED TO TRANSACT BUSINESS IN THE STATE ANDWAS NOT LICENSED AS EITHER A BROKER-DEALER OR INVESTMENTADVISOR.








Cease and Desist



Docket/Case Number: SEC-78-021-GB

Principal Product Type: Equity Listed (Common & Preferred Stock)



Resolution:


Sanction Details: CEASE AND DESIST ORDER FROM MAILING STOCK MARKET LETTERS TOPERSONS IN STATE AND FROM TRANSACTING BUSINESS IN STATE ASEITHER A BROKER-DEALER OR INVESTMENT ADVISOR UNTIL FIRM WASREGISTERED APPROPRIATELY.

Sanctions Ordered: Cease and Desist/Injunction

Order

Disclosure 5 of 5

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C8A970043

Principal Product Type:


Allegations:



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details:

Regulator Statement ON JULY 7, 1997, DISTRICT NO. 8 NOTIFIED RESPONDENT WAYNEHUMMER INVESTMENTS, L.L.C. THAT THE LETTER OF ACCEPTANCE,WAIVER AND CONSENT NO. C8A970043 WAS ACCEPTED; THEREFORE, THEFIRM WAS FINED $500 - (MSRB RULES G-8 AND G-37 - RESPONDENTMEMBER FAILED TO REFLECT POLITICAL CONTRIBUTIONS ON ITS LIST OFPOLITICAL CONTRIBUTIONS MADE BY MUNICIPAL FINANCEPROFESSIONALSAND EXECUTIVE OFFICERS OF THE FIRM; AND, FILED WITH THE MSRB ALATE FORM G-37 LISTING A POLITICAL CONTRIBUTION).

**$500.00 PAID ON 8/11/97, INVOICE # 97-8A-622**

Sanctions Ordered: Monetary/Fine $500.00


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Other


LETTER OF ACCEPTANCE WAIVER AND CONSENT


Docket/Case Number: C8A970043

Principal Product Type: No Product


Allegations: VIOLATION OF MSRB RULES G-8 AND G-37.



Resolution:


Sanction Details: FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ANDPAID A FINE OF $500.00.

Sanctions Ordered: Monetary/Fine $500.00







End of Report

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