ATTORNEY FOR CLIENTS ALLEGE FA MISREPRESENTED INVESTMENT AS HAVING CONSISTENTLY INCREASED IN VALUE BY 9% A YEAR. DATES OF ALLEGED ACTIVITIES: 07/19/2006 - 9/10/2009

$17,000.00

THE CLIENT'S COMPLAINT IS TOTALLY UNFOUNDED AND WITHOUT MERIT. THE INVESTMENT IS A 100% PRINCIPAL PROTECTED "MARKET LINKED CERTIFICATE OF DEPOSIT" THAT IS 100% FDIC INSURED AT MATURITY.

THE COMPLAINT AROSE OUT OF THE SALE OF AN AUCTION RATE SECURITY (ARS) THAT WAS MADE PRIOR TO THE WIDESPREAD ILLIQUIDITY IN THE ARS MARKET THAT OCCURRED IN FEBRUARY 2008. ACTIVITY DATE(S): 4/23/2007

$25,000.00

THE FIRM REPURCHASED THE ARS SECURITIES AT ISSUE FROM THE CLIENT PURSUANT TO A GLOBAL REPURCHASE AGREEMENT IT ENTERED WITH SEVERAL REGULATORY BODIES. THIS WAS NOT A TRADITIONAL SETTLEMENT OF A DISPUTE BETWEEN THE CLIENT AND THE REPRESENTATIVE. THE NAMED REPRESENTATIVE: WAS NOT A PARTY TO, AND DID NOT AGREE TO OR PARTICIPATE IN, THE REPURCHASE AGREEMENT BETWEEN THE FIRM AND REGULATORS; THE NAMED REPRESENTATIVE DID NOT MAKE ANY PAYMENTS TO THE CLIENT; AND THE NAMED REPRESENTATIVE WAS NOT ASKED TO AND DID NOT CONTRIBUTE TO THE REPURCHASE AMOUNT. THIS MATTER IS BEING REPORTED AS A SETTLEMENT PURSUANT TO THE REQUIREMENTS OF FINRA REGULATORY NOTICE 09-12.