FINRA

Without admitting or denying the findings, Simons consented to the sanctions and to the entry of findings that he used a personal email account to conduct firm-related securities business, which caused his member firm to fail to comply with its recordkeeping obligations. The findings stated that the firm prohibited its representatives from using a non-firm email account to conduct securities business. The findings also stated that Simons exercised discretion in the accounts of customers without obtaining prior written authorization from any of the customers and without the firm having accepted the accounts as discretionary in writing.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

Any and all capacities

45 days

6/6/2016

7/20/2016

UNHAPPY WITH LOSS ON INVESTMENT- 3/19/2014

$2,497.61

$2,497.61

SHORTLY AFTER THE PURCHASE OF ONE OF PORTFOLIO HOLDINGS, THE COMPANY ISSUE AN UNEXPECTED NEGATIVE EARNINGS ANNOUNCEMENT. THIS UNDERSTANDABLY SENT THE SHARES LOWER. THE ISSUE OPENED 50% LOWER THAN THE PREVIOUS TRADING DAY. I ADVISED ALL AFFILIATED CLIENTS THAT WE SHOULD HOLD FOR THE EXPECTED RECOVERY WHICH HAD A SIGNIFICANT RECOVERY WITHIN SIX MONTHS.

CUSTOMERS ALLEGE THAT IN OR AROUND AUGUST OF 2008, THE AGENT MADE AN ERROR IN JUDGMENT BY INDICATING THEY CAN USE THE IRA IN A JOINT EFFORT TO DEFER TAX LIABILITY FOR THE YEAR 2006. CUSTOMERS ALSO ALLEGE THAT IT WAS LATER FOUND THAT SHE DOES NOT QUALIFY AND THEY WANT THEIR MONEY REFUNDED.

$5,000.00

$5,000.00