PLAINTIFFS ALLEGED THAT I CONCEALED IMPORTANT FACTS REGARDING THEIR INVESTMENT IN A FRANKLIN VALUEMARK II VARIABLE ANNUNITY, WHILE EMPLOYED AT GRIFFIN FINANCIAL SERVICES. UNKNOWN ALLEGED COMPENSATORY DAMAGES.

$11,380.70

TO AVOID DEFENSE COSTS. MY FORMER EMPLOYER, GRIFFIN FINANCIAL SERVICES SETTLED WITH THE PLAINTIFFS FOR $11,380.70. I WAS NOT A PARTY TO THE NEGOTIATIONS AND WAS NOT HAVE AWARE OF THE COMPLAINT UNTIL EARLY JANUARY 1998. I WAS NOT ASKED TO CONTRIBUTE TO THE SETTLEMENT. I MET WITH THE [CUSTOMERS] ONE TIME IN AUGUST 1993 AND DETERMINED THEIR SUITABILITY TO PURCHASE THE FRANKLIN VALUEMARK VARIABLE ANNUITY. I DISCLOSED ALL THE FACTS RELATIVE TO THE PRODUCT INCLUDING THE 5 YEAR CONTINGENT DEFERRED SALES CHARGE AND 15% PER YEAR CUMULATIVE WITHDRAWALS. I DOCUMENTED OUR MEETING COMPLETED ALL APPROPRIATE DISCLOSURES AND PROVIDED THEM WITH A PROSPECTUS AT THE TIME OF SALE. I DID NOT CONCEAL ANY RELATIVE FACTS ABOUT THE INVESTMENTS AND HAD NO COMMUNICATION WITH THE [CUSTOMERS] AFTER THE SALE WAS CONSUMMATED IN 1993

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Decision & Order of Offer of Settlement

Monetary/Fine

$8,500.00

Disgorgement/Restitution

Censure

Suspension

FROM MARCH, 1991 TO DECEMBER, 1994 I WAS INVOLVED IN A COMMISSION REFERRAL ARRANGEMENT WITH ANOTHER REGISTERED REP. I RECEIVED COMPENSATION FROM THE INDIVIDUAL IN EXCHANGE FOR REFERRING THE CLIENTS AND DID NOT NOTIFY MY EMPLOYER. THE TRANSACTIONS THAT I REFERRED WERE FOR FRIENDS AND FAMILY MEMBER NOT CUSTOMERS OF THE BANK IN WHICH I WORKED. I MISTAKENLY BELIEVED THAT THIS REFERRAL ARRANGEMENT WAS LEGITIMATE.

GRIFFIN FINANCIAL SERVICES

Permitted to Resign

N/A VIOLATION OF ARTICLE III, SECTION I OF THE NASD RULES OF FAIR PRACTICE NO ACUTAL OR ALLEGED DAMAGES OR CLAIMS.

TERMINATION IN EARLY 1994, GRIFFIN THREATENED TO TERMINATE MY EMPLOYMENT UNVLESS I INCREASED SALES OF THE PROPRIETARY FUNDS. A WEEK AFTER THE NORTHRIDGE EARTHQUAKE, A NON-BANK CUSTOMER WAS REFERRED TO ME WHO QUALIFIED FOR RIGHTS OF ACCUMULATION IN A NON-PROPRIETARY FUND. I SUGGESTED THAT SHE TAKE ADVANTAGE OF HER RDA; HOWEVER I BELIEVED THAT A NON-PROPRIETARY SALE WOULD JEOPARDIZE MY EMPLOYMENT, SO I SUGGESTED THAT SHE PURCHASE THE FUND FROM ANY OTHER FIRM. SHE AGREED AND EVENTUALLY BOUGHT THE FUND FROM ANOTHER B/D. AFTER THE PURCHASE, SHE CONTACTED ME AND I SERVICED THE ACCOUNT TO THE EXTENT THAT I WAS ABLE.