ILLINOIS

ON OCTOBER 20, 2011 THE NATIONAL ADJUDICATORY COUNCIL ("NAC") AFFIRMED THE FINDINGS CONTAINED IN THE MAY 6TH, 2011 HEARING PANEL DECISION("HPD")REGARDING COMPLAINT NO.2005003610701. RESPONDENT'S REGISTRATION AS A SALESPERSON AND INVESTMENT ADVISER REPRESENTATIVE IN THE STATE OF ILLINOIS ARE SUBJECT TO REVOCATION PURSUANT TO SECTIONS 8.E(1)(J)AND 8.E(3)OF THE ACT.

CONSENT ORDER OF REVOCATION

Revocation

NONE

FINRA

SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER, NASD RULES 2110, 2120, 2210, 2220, 2310, 2510(B), 2860, 2860(B)(18)(A), INTERPRETATIVE MATERIAL 2310-2 - MURPHY EFFECTED TRADES IN THE ACCOUNTS OF PUBLIC CUSTOMERS WITHOUT OBTAINING CUSTOMERS' SPECIFIC AUTHORIZATION FOR THE TRADES AND WITHOUT HAVING OBTAINED PRIOR WRITTEN AUTHORIZATION FROM CUSTOMERS AND PRIOR WRITTEN ACCEPTANCE BY HIS MEMBER FIRM OF THE CUSTOMERS' ACCOUNTS AS DISCRETIONARY ACCOUNTS. THE COMPLAINT ALLEGES THAT MURPHY RECOMMENDED AND EXECUTED TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS THAT WERE UNSUITABLE AND EXCESSIVE IN SIZE AND FREQUENCY IN VIEW OF CUSTOMERS' FINANCIAL SITUATION AND INVESTMENT OBJECTIVES. THE COMPLAINT ALSO ALLEGES THAT, IN PURSUING THE AGGRESSIVE TRADING STRATEGY IN THE ACCOUNTS OF CUSTOMERS, MURPHY ACTED WITH INTENT TO DEFRAUD OR WITH RECKLESS DISREGARD FOR THE CUSTOMERS' BEST INTEREST, FOR PURPOSE OF GENERATING COMMISSIONS. IN ADDITION, THE COMPLAINT ALLEGES THAT MURPHY RECOMMENDED, EFFECTED AND MAINTAINED UNCOVERED OPTIONS POSITIONS IN CUSTOMER'S ACCOUNTS AND IN EFFECTING THE UNCOVERED TRADES, HE TRADED BEYOND THE LEVELS AUTHORIZED BY THE CUSTOMER AND APPROVED BY HIS SUPERVISOR. MOREOVER, THE COMPLAINT ALLEGES THAT MURPHY CAUSED WRITTEN COMMUNICATIONS THAT WERE INACCURATE, MISLEADING OR OTHERWISE UNBALANCED, TO BE CREATED AND SUBSEQUENTLY DISTRIBUTED TO A CUSTOMER.

Decision

Bar (Permanent)

All Capacities

Indefinite

11/4/2011

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

$585,174.67

Monetary Penalty other than Fines

$13,013.97

EXTENDED HEARING PANEL DECISION RENDERED MAY 6, 2010 WHEREIN THE HEARING PANEL FOUND THAT A CUSTOMER DID NOT RECEIVE A DOCUMENT DEEMED INACCURATE, MISLEADING AND UNBALANCED FROM MURPHY SO DEPT. OF ENFORCEMENT DID NOT ESTABLISH THAT HE VIOLATED FINRA RULES WITH RESPECT TO THAT DOCUMENT. MURPHY IS FINED $591,933.67, AS DISGORGEMENT OF COMMISSIONS, BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY, AND SHALL PAY COSTS OF $9,503.17, JOINTLY AND SEVERALLY. APPEALED TO THE NAC ON MAY 28, 2010. NAC DECISION RENDERED OCTOBER 20, 2011 WHEREIN THE FINDINGS ARE AFFIRMED AND THE SANCTIONS IMPOSED ARE AFFIRMED IN PART AND MODIFIED IN PART; THEREFORE, MURPHY IS BARRED IN ALL CAPACITIES EFFECTIVE IMMEDIATELY WITH ISSUANCE OF THE NAC DECISION, FINED $585,174.67, AN AMOUNT THAT REPRESENTS DISGORGEMENT, AND ORDERED TO PAY $9,503.17, JOINTLY AND SEVERALLY, IN HEARING COSTS AND $3,510.80 IN APPEAL COSTS, JOINTLY AND SEVERALLY. APPEALED TO THE SEC ON OCTOBER 28, 2011. FINRA REPRESENTED IN ITS BRIEF TO THE SEC OPPOSING THE STAY OF THE BAR REQUESTED BY MURPHY THAT FINRA WILL NOT MAKE THE BAR EFFECTIVE UNTIL THE SEC DECIDES THE MOTION FOR THE STAY. NOVEMBER 4, 2011 - THE SEC DENIED THE REQUEST FOR A STAY. THE BAR WAS RE-ACTIVATED ON NOVEMBER 4, 2011 WHEN THE SEC DENIED THE MOTION FOR A STAY. SEC ADMIN RELEASE 34-69923, JULY 2, 2013: THE SEC ORDERED THAT THE DISCIPLINARY ACTION TAKEN AND THE COSTS IMPOSED BY FINRA ARE SUSTAINED. DECISION IS FINAL SEPTEMBER 3, 2013. SEC Release- May 8, 2017: the United States District Court for the Northern District of Illinois -The U.S. Securities and Exchange Commission filed a suit in Illinois federal court seeking nearly $600,000 in disgorgement and another $13,000 in costs from a 2013 SEC decision relating to this FINRA case. The SEC asked the court for an order enforcing its monetary order so that FINRA can collect on the disgorgement and costs, none of which has been paid to date, according to the lawsuit.

EXTENDED HEARING PANEL DECISION RENDERED MAY 6, 2010 WHEREIN THE HEARING PANEL FOUND THAT A CUSTOMER DID NOT RECEIVE A DOCUMENT DEEMED INACCURATE, MISLEADING AND UNBALANCED FROM MURPHY SO DEPT. OF ENFORCEMENT DID NOT ESTABLISH THAT HE VIOLATED FINRA RULES WITH RESPECT TO THAT DOCUMENT. MURPHY IS FINED $591,933.67, AS DISGORGEMENT OF COMMISSIONS, BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY, AND SHALL PAY COSTS OF $9,503.17, JOINTLY AND SEVERALLY. IF NO FURTHER ACTION, DECISION IS FINAL JUNE 23, 2010. APPEALED TO THE NAC ON MAY 28, 2010.

ILLINOIS

RESPONDENT INITIATED TRADES IN THE INVESTOR'S ACCOUNT WITHOUT PROPER AUTHORIZATION.

Consent

Monetary/Fine

$5,000.00

RESPONDENT IS PROHIBITED FROM ACTING AS A SUPERVISOR OR TAKING NEW CLIENTS UTNIL 2/29/2008

WITHOUT ADMITTING OR DENYING LIABLILTY RESPONDENT CONSENTED TO THE ORDER. RESPONDENT'S FIRM AGREED TO CERTAIN UNDERTAKINGS TO REVIEW AND CHANGE ITS SUPERVISORY PROCEDURES.

WITHOUT ADMITTING OR DENYING LIABILITY RESPONDENT CONSENTED TO THE ORDER. RESPONDENT'S FIRM AGREED TO CERTAIN UNDERTAKINGS TO REVIEW AND CHANGE ITS SUPERVISORY PROCEDURES.

CHURNING & SUITABILITY

$60,000.00

$32,000.00

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

NASD RULE 2110 - RESPONDENT WILLIAM MURPHY FAILED TO EFFECT THE PURCHASE OF SECURITIES IN THE FORM OF MUTUAL FUNDS IN A FASHION THAT WAS MOST BENEFICIAL TO THE MEMBER'S CUSTOMERS, IN THAT MURPHY FAILED TO UTILIZE THE MUTUAL FUND ISSUERS' REINSTATEMENT POLICIES AND THEREBY UNNECCESSARILY INCURRED CONTINGENT DEFERRED SALES CHARGES TO THE DETRIMENT OF THE MEMBER'S CUSTOMERS.

Acceptance, Waiver & Consent(AWC)

Censure

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

Restitution

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THE FOLLOWING SANCTIONS: CENSURED AND FINED $2,500.00. ORDERED TO PAY RESTITUTION IN THE AMOUNT OF $3918.15, PLUS INTEREST. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFEORTS UNDERTAKEN TO EFFECT RESTITUTION SHALL BE PROVIDED TO NASD STAFF NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASON RESPONDENT CANNOT LOCATE THE CUSTOMER(S) AFTER REASONABLE AND DOCUMENTED EFFORTS, WITHIN A REASONABLE TIME PERIOD, THE RESPONDENT SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUNDS FOR THE STATE IN WHICH THE CUSTOMER CONDUCTED ITS PRINCIPAL BUSINESS. FINES PAID ON 10/21/2003.

CONTACT [THIRD PARTY] IN PHIL--DISPLINARY FINES COORDINATOR FOR FURTHER INFO

MISREPRESENTATION; FRAUD AND BREACH OF FIDUCIARY DUTY; EXCESSIVELY TRADING; CHURNING

$250,000.00

CHICAGO BOARD OPTIONS EXCHANGE

SEE SUMMARY

Decision

Monetary/Fine

$10,000.00

Censure

Bar

DETAILED BELOW

CENSURED, FINED $10,000 AND BARRED FOR TWO CONSECUTIVE MONTHS FROM EXCHANGE MEMBERSHIP AND ASSOCIATION WITH ANY EXCHANGE ORGANIZATION.

I AM CONTESTING THE OUTCOME OF THE 2/12/1998 DECISION. CASE #47053

FAILURE TO REPAY A PERSONAL LOAN; CHURNING. CLIENT ALLEGED DAMAGES OF $314,973.00

$314,973.00

$214,541.00

MERRILL LYNCH PURCHASED THE LIMITED PARTNERSHIP IN CUSTOMER'S ACCOUNT FOR THE PAYMENT OF $267,000. NOT PROVIDED