NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES

ON OR ABOUT JUNE 2008, MR. BEADLE VIOLATED NASD RULE 2110 BY USING AN ANSWER KEY TO COMPLETE A STATE INSURANCE CONTINUING AGENT EXAM, FOR WHICH CONDUCT HE ENTERED INTO A "FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE WAIVER AND CONSENT" IN JUNE 2011 WITH FINRA, WHICH INCLUDED A ONE-MONTH SUSPENSION WITH FINRA AND A $5,000.00 FINE. AS A RESULT OF THE VIOLATION, THE NYS DEPARTMENT OF FINANCIAL SERVICES PROPOSED A SETTLEMENT WITH ATTENDANT CIVIL PENALTY.

Settled

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

$1,500.00

NORTH CAROLINA DEPARTMENT OF INSURANCE

ON OR ABOUT JUNE 2008, MR. BEADLE VIOLATED NASD RULE 2110 BY USING AN ANSWER KEY TO COMPLETE A STATE INSURANCE CONTINUING AGENT EXAM, FOR WHICH CONDUCT HE ENTERED INTO A "FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE WAIVER AND CONSENT" IN JUNE 2011 WITH FINRA, WHICH INCLUDED A ONE-MONTH SUSPENSION WITH FINRA AND A $5,000.00 FINE. AS A RESULT OF THE VIOLATION, AND PURSUANT TO N.C.G.S. 58-2-70(G), MR. BEADLE'S NORTH CAROLINA INSURANCE LICENSE WAS SUBJECT TO POSSIBLE REVOCATION.

Settled

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

$500.00

MR. BEADLE AND THE NORTH CAROLINA DEPARTMENT OF INSURANCE ENTERED INTO A VOLUNTARY SETTLEMENT AGREEMENT WHERE MR. BEADLE AGREED TO SETTLE, COMPROMISE, AND RESOLVE THE MATTERS AND THE DEPARTMENT AGREED NOT TO PURSUE ADDITIONAL PENALTIES, SANCTIONS, REMEDIES, OR RESTITUTION BASED ON THESE MATTERS AGAINST MR. BEADLE.

FINRA

NASD RULE 2110: BEADLE USED AN ANSWER KEY TO COMPLETE A STATE INSURANCE CONTINUING EDUCATION (CE) EXAM. CERTAIN STATES BEGAN REQUIRING FINANCIAL ADVISORS TO COMPLETE A LONG-TERM CARE (LTC) CE COURSE AND EXAM BEFORE SELLING LTC INSURANCE PRODUCTS TO CUSTOMERS WHO RESIDE IN THOSE STATES. BEADLE WAS ADVISED THAT HE WOULD BE REQUIRED TO COMPLETE THE LTC CE EXAM FOR A PARTICULAR STATE BEFORE HE WAS ABLE TO COMPLETE THE SALE OF A POLICY TO A COLLEAGUE'S BROTHER. BEADLE RECEIVED AN EMAIL FROM A WHOLESALER AT DIFFERENT MEMBER FIRM THAN WHICH HE WAS ASSOCIATED WITH AND ATTACHED TO THE EMAIL WAS A COPY OF THE STATE'S LTC CE EXAM QUESTIONS AND ANSWERED FILLED IN BY HAND. BEADLE USED THE ANSWER KEY TO COMPLETE THE STATE'S LTC CE EXAM.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

ALL CAPACITIES

ONE MONTH

7/5/2011

8/4/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, BEADLE CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR ONE MONTH. THE SUSPENSION IS IN EFFECT FROM JULY 5, 2011 THROUGH AUGUST 4, 2011.

WITHOUT ADMITTING OR DENYING THE FINDINGS, BEADLE CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR ONE MONTH. THE SUSPENSION IS IN EFFECT FROM JULY 5, 2011 THROUGH AUGUST 4, 2011.

CHURNING, UNAUTHORIZED TRADING, UNSUITABILITY, BREACH OF CONTRACT, BREACH OF FIDUCIARY DUTY, NEGLIGENCE, FRAUD, VIOLATION OF NASD AND NYSE RULES. VIOLATION OF FEDERAL AND PA SECURITIES LAWS. Y. TIME PERIOD: 04/00 TO 5/02

$500,000.00

$225,000.00

RICHARD APICELLA IS HANDLING THIS MATTER.