Claimants allege inter alia, that certain Puerto Rico Municipal Bond investments purchased from 2009 to 2013 were unsuitable.

$616,320.00

$80,000.00

Claimants allege unsuitability, failure to supervise and other causes of action related to the alleged unauthorized purchases of Puerto Rican bonds through registered representative, Tom Puentes.

$616,320.00

$80,000.00

This appears to be a duplicate entry.

Washington

On July 2, 2019, the Securities Division entered a Consent Order S-18-2554-19-CO01 with Tom Puentes (CRD 1713812) ("Consent Order"). The Consent Order stated that while on a heightened supervision plan, Mr. Puentes failed to report two emails containing customer complaints to his firm in violation of the firm's policies and procedures. In the Consent Order the parties agreed that Mr. Puentes would pay a fine of $12,500 and be subject to a heightened supervision plan for at least one year. Respondent waived his right to a hearing and judicial review of the matter.

Consent

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

$12,500.00

Fines $12500.00

Claimants alleged, inter alia, unsuitability with respect to Puerto Rico Municipal Bond investments in accounts - 2009 to 2014.

$175,000.00

Client verbally alleged, inter alia, misrepresentation with respect to the purchase of Puerto Rico municipal bonds - December 2017.

$29,013.75

Kestra Investment Services, LLC

Permitted to Resign

The firm believes the RR may have violated firm policy in that the RR did not notify the firm about a potential customer compliant and possible email conversations with customers in states in which the RR was not registered.

Claimant alleging, inter alia, unauthorized trading with respect to investments 2012-2013

$140,000.00

The customer received a notice regarding the bankruptcy of his Puerto Rico held in his accounts. These positions were purchased prior to the RR joining the firm. The client alleges that the bonds were not suitable for him based on his risk tolerance. The RR explained that at the time of this investment the bonds were suitable. At the time of the investment the bonds were rated at A1 or A3 by Moody's and A plus by S&P. These bonds were considered suitable and conservative at the time of the investments. The client hasn't made any additional complaints.

Claimant alleges, unauthorized trading with respect to bond transactions between 2012 and 2014.

$600,000.00

$214,000.00

Claimant alleging, Inter alia, unsuitability with respect to investments 2011 to 2012

$90,000.00

Claimant alleged, inter alia, unsuitability with respect to municipal bond investments-2011-2014.

$40,000.00

Complaint involving the suitability of a municipal bond investment sold in 2012 and 2013 through Morgan Stanley.

$31,000.00

FINRA

Without admitting or denying the findings, Puentes consented to the sanctions and to the entry of findings that he exercised time and price discretion in customer accounts to purchase municipal bonds. The findings stated that Puentes' member firm prohibited registered representatives from exercising discretion, including time and price discretion, in commission-based accounts unless prior written authorization had been obtained from both the customer and the firm. Contrary to firm policy, Respondent never obtained written authorization from any of the customers or the firm to exercise time and price discretion in these accounts. The findings also stated that Puentes failed to disclose his use of time and price discretion to the firm when responding to its annual compliance questionnaires for the years 2010 through 2013.

Acceptance, Waiver & Consent(AWC)

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

$15,000.00

Suspension

Any capacity

30 days

11/7/2016

12/6/2016

CLIENT ALLEGES PURCHASES OF PR BONDS WERE UNAUTHORIZED. JUNE 2012 - MARCH 2013.

$101,501.00

$19,200.00

Client verbally alleged, inter alia, that the purchase of Puerto Rico bonds in account were unaurhtorized - December 2009- January 2015

$57,500.00

Client verbally alleged that the purchase of Puerto Rico bonds in account were unaurhtorized- December 2009 to July 2013

$20,000.00

Claimant alleged, inter alia, unaurthorized trading and unsuitability with respect to purchases of municipal bonds in accounts - 2012 to 2013

$200,000.00

$52,500.00

Client Alleges unauthorized trading, inter alia, with respect to muncipal bonds- august 2011 - september 2014

$85,000.00

$30,000.00

Client alleged, inter alia, that the purchases of puerto rico bonds in his account were unauthorized. Alleged dameges unspecified 2010-2013

$15,000.00

CLIENT ALLEGES, INTER ALIA, THAT FROM OCTOBER 2011 TO JULY 2013 THE FA PURCHASED UNSUITABLE PUERTO RICO MUNICIPAL BONDS IN THE CLIENTS ACCOUNT WITHOUT HIS AUTHORIZATION.

$300,000.00

$125,000.00

CLAIMANTS ALLEGE, INTER ALIA, THAT FROM 2012 THROUGH 2013 THE FA MADE UNSUITABLE PURCHASES IN THE CLIENTS' ACCOUNT.

$160,000.00

$20,000.00

CLAIMANTS ALLEGE, INTER ALIA, THAT FROM 2012 THROUGH 2013 THE FA MADE UNSUITABLE PURCHASES IN THE CLIENTS' ACCOUNT

$450,000.00

$100,000.00

CLAIMANTS ALLEGE, INTER ALIA, THAT FROM DECEMBER 2011 THROUGH APRIL 2013 THE FA MADE UNSUITABLE PURCHASES IN THE CLIENTS' ACCOUNT.

$216,084.44

$64,500.00

CLIENT'S ATTORNEY ALLEGED, INTER ALIA, THAT INVESTMENTS PURCHASED IN THE CLIENT'S ACCOUNT WERE UNSUITABLE. 2013 DAMAGES UNSPECIFIED

$236,547.36

$60,000.00

CLIENT'S ATTORNEY ALLEGED, INTER ALIA, THAT INVESTMENTS PURCHASED IN THE CLIENT'S ACCOUNT WERE UNSUITABLE. 2013 DAMAGES UNSPECIFIED.

$236,547.36

$60,000.00

CLIENTS' ALLEGE, INTER ALIA, THAT FROM DECEMBER 2011 TO NOVEMBER 2014 THE PUERTO RICO BONDS PURCHASED IN THE CLIENTS'ACCOUNT WERE UNSUITABLE

$111,138.00

$35,000.00

CLAIMANT ALLEGED, INTER ALIA, THAT PURCHASES OF BONDS IN ACCOUNT WERE UNAUTHORIZED AND UNSUITABLE - 2009 - 2013

$373,000.00

$99,000.00

In order to avoid the costs and uncertainties of litigation, Morgan Stanley agreed to pay Claimants $99,000.00 in full and final settlement of any and all claims asserted by Claimants in this proceeding.

MORGAN STANLEY SMITH BARNEY

Discharged

ALLEGATIONS RELATING TO THE REGISTERED REPRESENTATIVE'S USE OF DISCRETIONARY TRADING WITHOUT WRITTEN AUTHORIZATION.

CLIENT ALLEGES, INTER ALIA, THAT THERE WERE UNAUTHORIZED PURCHASES OF BONDS IN THEIR ACCOUNT IN 2013.

$35,000.00

CLIENT ALLEGED THAT THE PURCHASE OF FANNIE MAE SECURITIES IN HIS ACCOUNT WERE UNSUITABLE. 2008. DAMAGES UNSPECIFIED

CLIENT ALLEGED UNAUTHORIZED TRADING WITH RESPECT TO INVESTMENTS. DAMAGES UNSPECIFIED.

CLIENT ALLEGED THAT THERE WERE UNAUTHORIZED TRANSACTIONS MADE IN HIS ACCOUNT. 2004-2007. DAMAGES UNSPECIFIED

CLAIM ABANDONED.

ALLEGES HE SUSTAINED LOSSES DUE TO INCORRECT ADVICE RECEIVED CONCERNING THE SALEABILITY OF HIS RULE 144 RESTRICTED STOCK.

$4,200,000.00

COMPLAINT DENIED AS COMPLETELY FRIVOLOUS. CLAIMANT PURSUED THIS MATTER IN ARBITRATION AGAINST THE FIRM NOT THE FC.

THE CLIENT ALLEGED THAT INVESTMENTS MADE IN HER IRA AND TRUST ACCOUNTS WERE INAPPROPRIATE, BONDS WERE PURCHASED ON MARGIN WITHOUT HER PERMISSION, EXCESSIVE TRADING, AND SHE WAS NEVER ADVISED THAT HER ASSETS WERE MORE THAN SUFFICIENT TO OFFSET ANY COSTS ASSOCIATED WITH HER LONG TERM CARE PURCHASE. ALLEGED DAMAGES - UNSPECIFIED.

CLAIM DENIED.

SMITH BARNEY, HARRIS UPHAM & CO., INC.

Permitted to Resign

N/A SMITH BARNEY IS ALLEGING THAT I BREACHED THE SECURITY OF THE FIRM'S COMPUTERIZED RECORD SYSTEM CONTAINING CONFIDENTIAL INFORMATION.

CIVIL INJUNCTION AGAINST CALLING ANY SMITH BARNEY CLIENTS OTHER THAN OWN... CONCEEDED 6/26/91, PRELIMINARY CIVIL INJUNCTION GRANTED, ONLY ALLOWED TO CONTACT PREVIOUS CLIENTS. I CONCEEDED NOT TO CALL OTHER SMITH BARNEY CLIENTS... SINCE THERE HAS BEEN NO FORMAL CHARGES, AT THIS TIME I WILL ANSWER ALL QUESTIONS ON PAGE 3 OF THE U-4 "NO".