NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

NASD RULES 2110 AND 3010 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THE ENTRY OF FINDINGS THAT HE, ACTING THROUGH MEMBER FIRM, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REGARDING VARIABLE ANNUITY TRANSACTIONS. RESPONDENT, ACTING THROUGH MEMBER FIRM, ALSO FAILED TO ENFORCE FIRM'S WRITTEN SUPERVISORY PROCEDURES FOR THE BANK DIVISION REQUIRED THAT: FOR SALES OF VARIABLE ANNUITIES INTO QUALIFIED ACCOUNTS; AND FOR EXCHANGES OR REPLACEMENTS OF VARIABLE ANNUITIES.

Acceptance, Waiver & Consent(AWC)

Monetary/Fine

$10,000.00

Censure

A CENSURE AND A FINE OF $10,000, TO BE PAID JOINTLY AND SEVERALLY.

NASD RULES 2110 AND 3010 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THE ENTRY OF FINDINGS THAT HE, ACTING THROUGH MEMBER FIRM, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REGARDING VARIABLE ANNUITY TRANSACTIONS. RESPONDENT, ACTING THROUGH MEMBER FIRM, ALSO FAILED TO ENFORCE FIRM'S WRITTEN SUPERVISORY PROCEDURES, FOR THE BANK DIVISION REQUIRES THAT; FOR SALES OF VARIABLE ANNUITIES INTO QUALIFIED ACCOUNTS; AND FOR EXCHANGES OR REPLACEMENTS OF VARIABLE ANNUITIES.