CLIENT ALLEGES MISREPRESENTATION AND FAILURE TO PROPERLY DELIVER A PROSPECTUS WITH RESPECT TO THE PURCHASE OF TWO MUTUAL FUND POSITIONS. CLIENT FURTHER ALLEGES THAT THE REPRESENTATIVE FAILED TO DISCLOSE THAT SAID MUTUAL FUND INVESTMENTS WERE NOT MUNICIPAL SECURITIES.

$35,000.00

ALTHOUGH THE CUSTOMER INITIALLY CONSENTED TO THE MUTUAL FUND PURCHASE ON JULY 19, 2013, UPON FURTHER CONVERSATION WITH BRANCH MANAGEMENT, IT BECAME CLEAR THAT THE CUSTOMER MISUNDERSTOOD THE UNDERLYING HOLDINGS IN THE FUND. AS SUCH THE FIRM DETERMINED IT APPROPRIATE TO CANCEL THE PURCHASE OF THAT FUND. THE DOLLAR AMOUNT OF THE SETTLEMENT REFLECTS THE TOTAL VALUE OF THE TRADE THAT WAS CANCELLED. THE CANCELLATION WAS DONE WITH NO LOSS TO THE CUSTOMER OR FIRM. THE CUSTOMER INDICATED VERBALLY TO BRANCH MANAGEMENT HIS SATISFACTION WITH THE ACTIONS TAKEN BY THE FIRM WITH RESPECT TO THE CLAIMS RAISED IN HIS INITIAL COMPLAINT LETTER. THE CLIENT ALSO INDICATED HIS SATISFACTION WITH HIS ADVISOR BRAD GLASMAN AND APOLOGIZED FOR SENDING THE LETTER.

REP FAILED TO VERIFITY THE TERMS OF AN ORDER, RESULTING IN AN UNAUTHORIZED TRADE, AND THE LIQUIDATION OF A POSITIONTHAT THE CLIENT WISHED TO HOLD.

$10,000.00

REP AND CLIENT HAD DISCUSSED THE LIQUIDATION OF 1 OF 2 SEQUOIA MUNICIPAL BOND POSITIONS HELD IN THE CLIENTS ACCOUNT. THE WRONG POSITION WAS LIQUIDATED AS A RESULT OF A MISCOMMUNICATION BETWEEN THE REP AND CLIENT. ISSUE WAS INITIALLY REPORTED AS A COMPLAINT BECAUSE THE CLIENT SENT IN A WRITTEN GRIEVANCE THAT APPEARED TO ALLEGE UNAUTHORIZED TRADING. SUBSEQUENT TO THE TRADE CORRECTION AND THE U-4 REPORTING, THE CLIENT SENT IN ANOTHER COMMUNICATION STATINGTHAT HE DID NOT INTEND FOR HIS INITIAL CORRESPONDENCE TO BE A COMPLAINT, HOWEVER, A TRADE CANCELLATION HAD ALREADY BEEN PROCESSED TO RECTIFY THE GRIEVANCE PRESENTED IN THE CLIENT'S ORIGINAL LETTER AT NO COST TO THE REP OR CLIENT. THE FIRM BELIEVE THIS TO BE SIMPLY A TRADE ERROR AS OPPOSED TO AN UNAUTHORIZED TRADE. MATTER CLOSED.

FROM 2005 THROUGH JULY 2008, ALLEGE REP TRADED IN RISKY CLOSED END FUNDS OF NONRATED CALIFORNIA MUNICPAL BONDS, CONSTITUTING A BREACH OF ORAL AND WRITTEN CONTRACTS, FRAUD DECEIT AND OMISSION OF MATERIAL FACT, BREACH OF FIDUCIARY DUTY, NEGLIGENCE, BREACH OF CONTRACT TO SUPERVISE BROKERS, VIOLATION OF THE CONSUMERS LEGAL REMEDIES ACT, VIOLATION OF THE UNFAIR COMPETITION ACT, AND FINANCIAL ELDER ABUSE

$231,500.00

$20,000.00

MATTER SETTLED BY THE FIRM ON 12-30-2010.

NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

**05/16/2003** CHARGES ISSUED BY NYSE DIVISION OF ENFORCEMENT AND PENDING., CHARGES: CHARGE I BRADLEY TODD GLASMAN, BY REASON OF THE FACTS SET FORTH IN THE STATEMENT OF FACTS AND EXPLANATION, ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT HE EFFECTED UNSUITABLE TRANSACTIONS IN THE ACCOUNTS OF ONE OR MORE CUSTOMERS OF HIS MEMBER ORGANIZATION EMPLOYER IN VIEW OF THEIR AGE, INVESTMENT OBJECTIVES AND/OR FINANCIAL CIRCUMSTANCES, AND HE IS, THEREFORE, SUBJECT TO DISCIPLINE PURSUANT TO EXCHANGE RULE 476(A). CHARGE II BRADLEY TODD GLASMAN, BY REASON OF THE FACTS SET FORTH IN THE STATEMENT OF FACTS AND EXPLANATION, ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT HE SOLICITED AND EFFECTED THE SWITCHING OF SIMILAR HIGH YIELD DEBT SECURITIES IN THE ACCOUNTS OF ONE OR MORE CUSTOMERS OF HIS MEMBER ORGANIZATION EMPLOYER THAT THEN PROVIDED NO BENEFIT TO THOSE CUSTOMERS, AND HE IS, THEREFORE, SUBJECT TO DISCIPLINE PURSUANT TO EXCHANGE RULE 476(A). CHARGE III BRADLEY TODD GLASMAN, BY REASON OF THE FACTS SET FORTH IN THE STATEMENT OF FACTS AND EXPLANATION, ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT HE MADE MISSTATEMENTS TO ONE OR MORE CUSTOMERS OF HIS MEMBER ORGANIZATION EMPLOYER IN CONNECTION WITH THE SOLICITATION OF PURCHASES IN THEIR ACCOUNTS, AND HE IS, THEREFORE, SUBJECT TO DISCIPLINE PURSUANT TO EXCHANGE RULE 476(A). **10/13/2003** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: A. A FINDING BY THE HEARING PANEL THAT HE ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT HE: 1.EFFECTED UNSUITABLE TRANSACTIONS IN THE ACCOUNTS OF ONE OR MORE CUSTOMERS OF HIS MEMBER ORGANIZATION EMPLOYER IN VIEW OF THEIR AGE, INVESTMENT OBJECTIVES AND/OR FINANCIAL CIRCUMSTANCES; **CONTINUED IN #14**

Decision

Monetary/Fine

$20,000.00

Censure

Bar

**11/25/2003** DECISION 03-216 ISSUED BY NYSE HEARING PANEL DECISION: EFFECTED UNSUITABLE CUSTOMER TRANSACTIONS; EFFECTED SWITCHING OF SIMILAR SECURITIES IN CUSTOMER ACCOUNTS WITHOUT BENEFIT TO THE CUSTOMERS; MADE MISSTATEMENT TO CUSTOMERS - CONSENT TO CENSURE, TWO MONTH BAR AND $20,000 FINE.

CLIENT ALLEGES UNAUTHORIZED AND UNSUITABLE TRADING. MR. GLASMAN DENIES ALL ALLEGATIONS. THE CUSTOMER AUTHORIZED ALL PURCHASES AND SELLS AND WAITED UNTIL FIVE YEARS AFTER ANY TRANSACTIONS TO MAKE A COMPLAINT.

$250,000.00

$140,000.00

CUSTOMER ALLEGES THAT THE REGISTERED REPRESENTATIVE RECOMMENDED UNSUITABLE INVESTMENTS. DAMAGES ARE UNSPECIFIED BUT BELIEVED TO BE IN EXCESS OF $5,000.

$130,000.00

FIRST UNION SECURITIES SETTLED WITH THE CUSTOMER FOR BUSINESS REASONS AND WITHOUT ADMITTING LIABILITY.

CLAIMANT COMPLAINS THAT THE FA MADE RECOMMENDATIONS OF HIGH YIELD BONDS AND OTHER INVESTMENTS THAT WERE UNSUITABLE FOR HER INVESTMENT DIRECTIVES.

$130,000.00

$70,000.00

MATTER SETTLED FOR BUSINESS REASONS ONLY.

CLIENT COMPLAINS THAT FINANCIAL ADVISOR RECOMMENDED CERTAIN PURCHASE OF HIGH YIELD BONDS IN HER ACCOUNT THAT ARE ALLEGEDLY UNSUITABLE FOR HER INVESTMENT OBJECTIVES.

$40,000.00

$21,000.00

FOR BUSINESS REASONS AND WITHOUT ADMITTING ANY LIABILTIY ON PART OF THE FIRM, THIS MATTER WAS SETTLED IN THE AMOUNT OF $21,000. MR. GLASSMAN WAS DISMISSED FROM THE MATTER.

CLIENTS ALLEGE THAT FINANCIAL ADVISOR RECOMMENDED TRANSACTIONS THAT WERE UNSUITABLE FOR THEIR INVESTMENT OBJECTIVES. THE FINANCIAL ADVISOR DISAGREES WITH THE CLAIMS MADE BY [CUSTOMERS].

$80,000.00

$20,000.00

CUSTOMER ALLEGES THAT FINANCIAL ADVISOR RECOMMENDED UNSTABLE HIGH YIELD BONDS AND MISREPRESENTATIONS REGARDING SAME.

$100,000.00

$25,000.00

CASE SETTLED

CLAIMANT ALLEGES "CHURNING" AND UNSUITABLE TRADING BY THE FA FROM OCTOBER 1996 THROUGH DECEMBER 1996.

$8,000.00

$6,250.00

FOR BUSINESS PURPOSES AND WITHOUT ADMITTING ANY LIABILITY ON PART OF THE FIRM, THIS MATTER WAS SETTLED IN THE AMOUNT OF $6,250.

CLAIMANT ALLEGES UNSUITABILITY, CHURNING AND UNAUTHORIZED TRADING.

$170,000.00

$100,000.00

CLAIM SETTLED FOR $100,000.00.

THE CLIENT'S SON HAS COMPLAINED THAT [CUSTOMERS] WERE SOLD UNSUITABLE CORPORATE BONDS. ON THEIR BEHALF, HE DEMANDS FULL RESTITUTION FOR THEIR LOSSES.

$25,500.00

$47,500.00

MATTER SETTLED FOR A TOTAL OF $47,500. THE CLIENTS WERE MAILED THEIR CHECKS ON 03/16/2000.

CUSTOMER ALLEGES THAT HER PURCHASE OF IRIDIUM BONDS WAS UNSUITABLE FOR HER INVESTMENT OBJECTIVES.

$23,754.50

CLIENT ALLEGED UNSUITABLE AND EXCESSIVE TRADING AND DID NOT SPECIFY DAMAGES. AFTER A DETAILED REVIEW OF THE ACCOUNTS, THE FIRM HAS DETERMINED THAT THE ACCOUNTS HAVE TOTAL LOSSES OF $6000.00.

$6,000.00

$20,000.00

THE FIRM DETERMINED TO SETTLE THIS MATTER FOR BUSINESS REASONS AND PAID THE CLIENT $20,000.00. THIS IS A PRODUCT RELATED COMPLAINT. AFTER THE RECOMMENDATION FROM EVEREN'S HIGH YIELD BOND DESK AND REVIEW OF A FAVORABLE SOLOMON BROTHER'S RESEARCH REPORT PROVIDED BY THAT DESK, I RECOMMENDED ON 10/17/97, CONSISTENT WITH [CUSTOMER]'S OVERALL STRATEGY, THE PURCHASE OF 19,000 APS HOLDING BONDS AT PAR. SUBSEQUENTLY ON 2/2/98, APS FILED FOR A VOLUNTARY PETITION UNDER CHAPTER 11 OF THE US BANKRUPTCY CODE. AS A RESULT THE VALUE OF THAT POSITION IN HER PORTFOLIO SIGNIFICANTLY DECLINED.

CLAIMANT ALLEGES HE WAS UNSOPHISTICATED AND RELIED UPON HIS FA (WHO IS ALSO HIS NEPHEW-IN-LAW) WHO EFFECTED UNAUTHORIZED TRADES THAT CONSTITUTED CHURNING IN UNSUITABLE SECURITIES.

$157,225.00

$110,000.00

FUSI SUBMITTED IT'S STATEMENT OF ANSWER ON 1/25/2000 STATING THAT THE CLAIMANT WAS A KNOWLEDGEABLE INVESTOR WHO WAS AWARE OF AND DISCUSSED THE MERITS OF EACH INVESTMENT BEFORE IT WAS MADE. CLAIMANTS' AWARENESS IS EVIDENCED BY A LETTER HE WROTE 2 YEARS BEFORE THE COMPLAINT ACKNOWLEDGING THE LOSSES AND MAKING INVESTMENT SUGGESTIONS. CASE WAS SETTLED.

ALLEGATIONS ARE FAILURE TO EXECUTE A STOP LOSS ORDER FOLLOWING A SHORT SALE AGAINST THE BOX ON MERCK COMMON STOCK. DAMAGES ARE UNSPECIFIED.

$37,500.00

$37,500.00

PRUDENTIAL SETTLED THE CLIAMS WITH THE CLIENT FOR $37,500.00 THERE WAS NEVER A STOP LOSS ORDER GIVEN. MANAGER OF OFFICE, ROBERT FEINMAN, FROZE ACCT. WHEN CLIENT ALTERED MARGIN AGREEMENT BECAUSE OF ARBITRATION CLAUSE. NEW ACCT. FORM WAS ACCEPTED BY PRIN. WITH ARBITRATION CLAUSE CROSSED OFF. I SHOULD NOT BE NAMED IN THIS CASE BECAUSE ACCT. WAS TAKEN AWAY FROM ME BY FEINMAN.

PRUDENTIAL SECURITIES INCORPORATED

Discharged

UNAUTHORIZED TRADING. VIOLATION OF COMPANY POLICY, WHICH WERE DENIED AND CONTESTED BY LEGAL ACTION.

PRUDENTIAL CLAIMED I VIOLATED COMPANY POLICY CONCERNING THE SALE AND PURCHASE OF A BOND. THESE ALLEGATIONS WERE FALSE. I CONTESTED THE TERMINATION THROUGH LEGAL ACTION.

CUSTOMER ALLEGED THAT TRADES WERE NOT DISCUSSED WITH HIM BEFORE HAND. ALLEGED DAMAGES OF $26,025.00

$26,025.00

$19,000.00

PRUDENTIAL SECURITIES SETTLED THIS AMTTER FOR $19,000.00 Not Provided

CUSTOMER ALLEGED UNSUITABLE INVESTMENTS, MISREPRESENTATIONS, UNAUTHORIZED AND EXCESSIVE TRADING IN SECURITIES, INCLUDING F & M CORPORATE BONDS, WITH DAMAGES SOUGHT OF $100,000.00

$100,000.00

$75,000.00

PRUDENTIAL SETTLED THIS MATTER FOR $75,000.00. THERE WAS NEVER UNAUTHORIZED TRADING OR EXCESSIVE TRADING IN [CUSTOMER] ACCOUNT. ALL OF THE INVESTMENTS WERE SUITABLE AND HER ACCOUNT WAS DIVERSIFIED. IN REGARD TO THE F AND M BONDS, THE COMPANY WENT BANKRUPT. PRUDENTIALS TRADING DEPT MISREPRESENTED THE BONDS TO ME. AS THE BONDS DROPPED IN PRICE PRUDENTIAL'S TRADING DEPT ASSURED ME THEY WERE IN GOOD SHAPE.