CLIENT ALLEGES HER REPRESENTATIVE MISREPRESENTED INFORMATION ON THE NEW ACCOUNT FORM USED FOR DETERMINING SUITABILITY. SHE ALSO ALLEGES HER REPRESENTATIVE ONLY GAVE HER A BLANK SIGNATURE PAGE OF THE NAF AND ASKED HER TO SIGN.

$5,100.00

$5,100.00

AFTER CHANGING ADVISORS, CLIENT DECIDED TO SURRENDER TWO ANNUITIES SHE PURCHASED TO REPLACE AN UNDERPERFORMING ANNUITY CLIENT OWNED FOR MANY YEARS TO PURSUE A DIFFERENT INVESTMENT STRATEGY AND CLAIMED FALSELY SHE DIDN'T REALIZE SHE WOULD HAVE TO PAY SURRENDER FEE. MS. NORTON DENIES SHE OMITTED TO EXPLAIN SURRENDER FEE SCHEDULE.

Massachusetts

On or about April 15, 2016, IAA submitted to FINRA's CRD a Uniform Application for Securities Industry Registration or Transfer ("Application") seeking registration of Norton as a broker-dealer agent in Massachusetts, and IAIM submitted on the same date an Application seeking registration of Norton as an investment adviser representative in Massachusetts. Norton has been the subject of two (2) customer complaints, as reported on the CRD, alleging, inter alia, negligence, unsuitability, breach of fiduciary duty, breach of contract, fraud and misrepresentation. On or about May 16, 2014, a Massachusetts resident filed a statement of claim with FINRA's Office of Dispute Resolution against Norton and her former firm, Ausdal Financial Partners, Inc. The customer alleged that Norton gave improper advice to retire early and roll-over the customer's retirement savings into an annuity that was unsuitable given that the annuity contract's withdrawal limit could not meet the customer's income needs. On or about June 8, 2015 the FINRA arbitration panel decided that Norton and Ausdal Financial Partners Inc. were jointly and severally liable for the customer's compensatory damages in the amount of $1,240,000 plus interest at the rate of twelve (12) percent per annum. On or about February 6, 2015 another Massachusetts resident alleged that Norton gave inappropriate investment advice and sold the customer an unsuitable annuity. The customer, who alleged damages of $100,000, settled with Ausdal Financial Partners and Norton for $14,800. The foregoing incidents involving Norton have moved the Division to place conditions on her registration as a broker-dealer agent of IAA and as an investment adviser representative of IAIM.

Consent

Undertaking

Heightened supervision for a period of three (3) years which shall include International Assets Advisory, LLC & International Assets Investment Management, LLC reporting to the Division on a quarterly basis.

CLIENT ALLEGES SHE DID NOT UNDERSTAND THE ANNUITY CONTRACT SHE PURCHASED

$5,000.00

$1,240,000.00

ALTHOUGH THE ARBITRATION PANEL DETERMINED THAT MS. NORTON IS JOINTLY AND SEVERALLY RESPONSIBLE FOR THE PAYMENT OF THE AWARD, MS. NORTON STRONGLY DISAGREES WITH THE PANEL'S DECISION IN THIS MATTER. MS. NORTON CONTINUES TO BELIEVE THAT THIS CLAIM IS WITHOUT MERIT. 12/22/16 UPDATE - On June 8, 2015, a FINRA arbitration panel awarded the customer $1,240,000 plus interest at 12% annually until paid. Ausdal and Norton petitioned the United States District Court for the District of Massachusetts (the 'Court") for an Order Vacating the Award. The Customer moved to confirm the Award. On March 11, 2016 the Court confirmed the Award and entered judgment against Ausdal and Norton in the amount of $1,521,863 plus interest that accrued at 12% annually. On March 29, 2016 Ausdal paid the Award in full by drawing on a combination of its own funds and the proceeds of Ms. Norton's and Ausdal's errors and omissions insurance. Ausdal's payment from its own funds totaled $669,797.00 Norton has agreed to reimburse Ausdal $275,000.00 from her own funds. So Ms. Norton's contribution to the [Customer's] award is $669,797.00 in insurance money plus $275k in cash. The Ausdal/Norton industry dispute arbitration settled on 12/21/2016 based upon Ms. Norton's agreement to pay Ausdal $275k.