NM SECURITIES DIVISION

RESPONDENT VOLLRATH EXECUTED TRADES FOR THE ACCOUNT OF A NEW MEXICO RESIDENT FOR SEVERAL MONTHS PRIOR TO LICENSURE IN NM, VIOLATION OF SEC. 58-13B-3 OF THE NM SECURITIES ACT OF 1986. FAILURE TO ADVISE A NM RESIDENT HE WAS NOT LICENSED, VIOLATION OF SEC. 58-13B-30 OF THE ACT.

Consent

Cease and Desist/Injunction

CONSENT AGREEMENT SIGNED WHEREBY C&D IS WITHDRAWN, VOLLRATH SHALL CEASE AND DESIST SOLICITING, OFFERING AND SELLING SECURITIES OF ANY KIND IN NM, HE IS ASSESSED A CIVIL PENALTY OF $5000, HE WILL WITHDRAW HIS NM LICENSE AND WILL NOT APPLY FOR LICENSURE IN NM FOR A PERIOD OF THREE YEARS FROM THE DATE OF SUCH WITHDRAWAL.

I WAS UNAWARE OF MY LACK OF REGISTRATION DURING PERIOR OF MY DEALINGS WITH MAHLER WHO HAD BEEN A FAMILY FRIEND IN ILLINOIS DURING THE TIME I DEALT WITH HIM AS A CLIENT, HE MOVED FROM ILLINOIS TO NEW MEXICO. AS SOON AS I DISCOVERED THE REGISTRATION PROBLEM I BECAME REGISTERED IN NEW MEXICO.

PRUDENTIAL SECURITIES INCORPORATED

Permitted to Resign

Not Provided PRUDENTIAL TERMINATED EMPLOYMENT AFTER I INFORMED THE FIRM I HAD REIMBURSED MY FORMER FRIEND AND CUSTOMER, LARRY MAHLER FOR CERTAIN FOR CERTAIN BACK-END LOAD FEES ON PRUDENTIAL PROPRIETARY MUTUAL FUNDS AFTER MAHLER COMPLAINED. FIRM TERMINATED EMPLOYMENT BECAUSE THIS IS ALLEGEDLY A VIOLATION OF COMPANY POLICY.

Not Provided THE BACK-END LOAD FEE WAS REIMBURSED TO A FRIEND WHO HAD COMPLAINED AND WAS MOVING HIS ACCOUNT.

CLIENT ALLEGED I EXECUTED IMPROPER TRADED FOR HIM SINCE I WAS NOT REGISTERED IN NEW MEXICO FROM 1987-1987 (I SUBSEQUENTLY BECAME REGISTERED).

$10,000.00

PRUDENTIAL, MY BROKER-DEALER AT THE TIME HAS INFORMED ME THAT [CUSTOMER] COMPLAINT WAS SETTLED WITHOUT ADMITTING OR DENYING LIABILITY FOR $10,000.00. I DID NOT CONTRIBUTE TO THIS SETTLEMENT AND I DENY ANY LIABILITY TO [CUSTOMER]. PRUDENTIAL DID NOT ASK ME TO CONTRIBUTE TO THE SETTLEMENT. NOT PROVIDED

THE ABOVE CLIENT(S) SUBMITTED CLAIM FORM(S) TO THE CLAIMS RESOLUTION PROCESS RALATING TO LIMITED PARTNERSHIP PURCHASE(S) DURING THE PERIOD: 1/88. THE ABOVE MENTIONED REGISTERED REPRESENTATIVE WAS THE BROKER OF RECORD AT THE TIME OF THE PURCHASE(S). NO DAMAGES ARE ALLEGED, BUT THE AMOUNT(S) OF ACTUAL LOSS(OUT-OF-POCKET) IS/ARE APPROXIMATELY: $8,908.

$8,908.00

SETTLEMENT(S) WITH THE ABOVE CLIENT(S) HAS/HAVE REACHED IN THE CLAIMS RESOLUTION PROCESS. THE DOLLAR AMOUNT(S) OF THE SETTLEMENT(S) IS/ARE APPROXIMATLY: $22,306. THIS MATTER FROM THE UNPRECENDENTED, UNSOLICITED MAILING OF CLAIM FORMS BY PSI TO OVER 340,000 INVESTORS WHO PURCHASED LIMITED PARTNERSHIP THROUGH PSI FROM JANUARY 1, 1980 TO JANUARY 1,1991. THE ABOVE REFERENCE CLIENT(S) SUBMITTED CLAIM FORM(S) IN RESPONSE TO THIS MAILING. THE CLAIM FORM(S) WAS/WERE EVALUATED BY PSI IN ACCORDANCE WITH THE STANDARDS ESTABLISHED UNDER THE SETTLEMENT BETWEEN PSI AND THE SEC, THE NASD AND THE STATE SECURITIES ADMINISTRATORS. THE REPORTED SETTLEMENT(S) AROSE OUT OF THIS UNIQUE PROCESS.

SUITABILITY OF LIMITED PARTNERSHIP PURCHASE.

$35,000.00

$19,276.00

CUSTOMER RECEIVED APPROXIMATELY 19,000 FROM PRUDENTIAL NOT PROVIDED

ALLEGED COMPENSATORY DAMAGES FOR SUPPOSED MISREPRESENTATION ABOUT RISK IN INVESTMENT BOTH PRUDENTIAL AND I WERE NAMED.

$80,000.00

$32,500.00

PRUDENTIAL MADE A SETTLEMENT PAYMENT OF $32,500 OF WHICH I WAS RESPONSIBLE FOR $2,500.00. CASE WAS SETTLED TO AVOID COST OF LITIGATION NO ADMISSION OF LIABILITY.

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Acceptance, Waiver & Consent(AWC)

Monetary/Fine

$1,000.00

Censure

NOT PROVIDED