CLIENT ALLEGES THAT REGISTERED REPRESENTATIVE PURCHASED AN UNSUITABLE INVESTMENT WITH NO DISCUSSION OF THE RISK ASSOCIATED WITH THE INVESTMENT. ACTIVITY PERIOD: 3-3-11 THROUGH 5-23-12.

VERMONT

REVIEW OF DRP HISTORY INDICATES NEED FOR IMPOSITION OF REGISTRATION CONDITIONS PRIOR TO APPROVAL OF REGISTRATION

Order

IMPOSITION OF "ORDER IMPOSING UNDERTAKINGS IN CONNECTION WITH REGISTRATION UNDER THE VERMONT SECURITIES ACT AND CONSENT TO SAME"

ORDER SHALL REMAIN IN FULL FORCE AND EFFECT FOR A PERIOD OF NOT LESS THAN TWO (2) YEARS FROM ITS EFFECTIVE DATE. AFTER THE TWO YEAR PERIOD, PETITION MAY BE MADE TO THE VERMONT SECURITIES DIVISION TO HAVE THE CONDITIONS REMOVED OR MODIFIED. RELEASE FROM THE TERMS OF THE ORDER SHALL BE MADE OR DENIED AT THE DIVISION'S DISCRETION.

UPON RECEIPT OF A WRITTEN REQUEST FROM RYAN, BECK & COMPANY, MR. DANIELI AND RYAN, BECK & CO. ARE RELEASED FROM THE TERMS OF THE ORDER, EFFECTIVE 4/5/06.

CLAIMANT, THROUGH HER COUNSEL, ALLEGED THAT HER BROKER - NOT MR. DANIELI, EXECUTED UNAUTHORIZED TRADES AND ENGAGED IN MARGIN TRADING CONTRARY TO HER INSTRUCTIONS. CLAIMANT INCLUDED MR. DANIELI IN THIS MATTER, ALLEGING THAT HE HAD SUPERVISORY RESPONSIBILITY TO VERIFY MARGIN AUTHORIZATION. DID NOT PROPERLY SUPERVISE HER ACCOUNTS AND VERIFY MARGIN AUTHORIZATION. AS A RESULT, MARGIN, TRAING OCCURRED IN CONTRAVENTION OF CLAIMANT'S INSTRUCTIONS.

$102,960.99

$35,000.00

WHEN CLAIMANT'S ACCOUNT WAS OPENED, PROPER MARGIN ACCOUNT DOCUMENTATION WAS SUBMITTED AT THAT TIME. MR. DANIELI DID NOT HAVE ANY INVOLVEMENT WITH THE CLAIMANT, OR SUPERVISION OF HER ACCOUNT. NOTWITHSTANDING THESE CIRCUMSTANCES, GRUNTAL SETTLED THIS MATTER WITHOUT ADMITTING OR CONCEDING LIABILITY IN ORDER RO AVOID THE EXPENSE AND UNCERTAINTIES OF PROTRACTED LITIGATION. MR. DANIELI DID NOT CONTRIBUTE TO THE SETTLEMENT.

CLAIMANT ALLEGED THAT MR. DANIELI MADE AN UNAUTHORIZED PURCHASE IN HIS ACCOUNT AND CHURNED HIS ACCOUNT. CLAIMANT ALSO ALLEGED UNSUITABLE TRADING ACTIVITY.

$700,862.00

$115,000.00

WITHOUT ADMITTING OR CONCEDING LIABILITY, AND IN THE INTERESTS OF AVOIDING THE EXPENSE AND UNCERTAINTIES OF PROTRACTED LITIGATION, GRUNTAL SETTLED THIS MATTER. MR. DANIELI CONTRIBUTED $10,000 TO THE OVERALL SETTLEMENT.

NYSE DIVISION OF ENFORCEMENT AND PENDING

CHARGES ISSUED: CHARGES- DANIELI ENGAGED IN CONSDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLE OF TRADE BY DUCT INCONSISTENT 1) OPENING CUSTOMER ACCOUNTS AT HIS MEMBER ORGANIZATION EMPLOYER IN THE NAMES OF ONE OR MORE INDIVIDUALS WITHOUT ANY AUTHORIZATION FROM SUCH INDIVIDUALS TO DO SO; AND 2) EFFECTING ONE OR MORE UNAUTHORIZED TRADES IN ONE OR MORE CUSTOMER ACCOUNTS OF HIS MEMBER ORGANIZATION EMPLOYER.

Consent

Censure

Suspension

AUGUST 23, 1994--STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING.--CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYI NG GUILT, DANIELI CONSENTED TO FINDINGS THAT HE ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE BY: (a) OPENING A CUSTOMER ACCOUNT AT HIS MEMBER ORGANIZATION IN THE NAMES OF TWO INDIVIDUALS WITHOUT ANY AUTHORIZATION FROM EITHER INDIVIDUAL TO DO SO; AND (b) EFFECTING ONE UNAUTHORIZED TRADE IN EACH OF TWO CUSTOMER ACCONTS OF HIS MEMBER ORGANIZATION EMPLOYER.--CONSENTED TO THE IMPOSITION BY THE EXCHANGE OF A PENALTY OF A CENSURE AND A ONE MONTH SUSPENSION FROM MEMBERSHIP, APPROVED PERSON STATUS AND EMPLOYMENT OR ASSOCIATION IN ANY CAPACITY WITH ANY MEMBER OR MEMBER ORGANIZATION.