FINRA

Without admitting or denying the findings, Inderlied consented to the sanction and to the entry of findings that he failed to appear for FINRA on-the-record testimony pertaining to allegations of unsuitable recommendations by Inderlied.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

9/1/2016

Adirondack Trading Group LLC

Permitted to Resign

Representative was censured by the State of Missouri in Case No. AP-15-39

Missouri

Respondents engaged in dishonest and unethical practices.

Consent

Censure

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

$20,000.00

Prohibition

Restitution

$17,750.00

Costs; Respondent shall not act as a trustee of a trust, attorney-in-fact under power of attorney, estate administrator, guardian, conservator, or in any similar fiduciary capacity for a client or a client's family unless such client is an immediate family member.

THIS MATTER, INVOLVING A SINGLE CUSTOMER, WAS SETTLED VIA A CONSENT ORDER IN WHICH I DID NOT ADMIT ANY FINDING OF FACT OR CONCLUSIONS OF LAW. THE MATTER INVOLVED AN EXTENDED INQUIRY INTO EVENTS WHICH WERE PREVIOUSLY THE BASIS OF THE ARBITRATION MATTER REPORTED UNDER "CUSTOMER DISPUTE - SETTLED", WHICH WAS SETTLED FOR A FRACTION OF THE INITIAL DEMAND BY THE SINGLE CLAIMANT WITHOUT ANY PERSONAL CONTRIBUTION BY ME. THE SECURITIES COMMISSIONER SUSPENDED ALL BUT 22% OF THE PAYMENTS IN THE CONSENT ORDER & WILLFULLY & FINALLY WAIVE THOSE SUSPENDED AMOUNTS UPON SATISFACTION OF THE OTHER PARTS OF THE ORDER.

WILBANKS SECURITIES, INC.

Permitted to Resign

REP WAS PERMITTED TO RESIGN WHILE UNDER HEIGHTENED SUPERVISION AND INVESTIGATION FOR IMPROPER RECOMMENDATIONS TO CLIENTS CONCERNING VARIABLE ANNUITIES. THE INVESTIGATION REVEALED THAT REP ENCOURAGED CLIENTS TO PREMATURELY SURRENDER VARIABLE ANNUITIES EARLY IN THE SURRENDER PERIOD FOR A-SHARES IN VARIOUS MUTUAL FUND SHARES TO SIGNIFICANT CLIENT HARM. THE FIRM FOLLOWED UP WITH EVERY CLIENT AND FULLY DISCLOSED ALL COMPENSATION TO THEM AND ALL CLIENTS DECIDED, IN WRITING, FOR THEIR INVESTMENTS TO STAND.

I REJECT THE ALLEGATIONS MADE BY WILBANKS SECURITIES. I COMPLIED WITH ALL POLICIES AND PROCEDURES AND FOLLOWED ALL PROTOCOLS OF WILBANKS SECURITIES. THIS INCLUDED DISCUSSING THE TRANSACTIONS WITH WILBANKS SECURITIES' HOME OFFICE PERSONNEL. I WAS NOT PERMITTED TO RESIGN. I VOLUNTARILY DEPARTED THE COMPANY BECAUSE I WAS DISSATISFIED WITH THEIR HANDLING OF CERTAIN INVESTMENTS BY MY CLIENTS. THE FIRM EXAMINED CERTAIN ANNUITY TRANSACTIONS OF A SERIES OF CLIENTS. THE CLIENTS ALL SURRENDERED ANNUITIES IN FAVOR OF MUTUAL FUND INVESTMENTS. THESE RECOMMENDATIONS WERE SUITABLE AND IN THE BEST INTEREST OF THE CLIENTS. THE FIRM QUESTIONED THE DISCLOSURE THAT WAS PROVIDED TO THE CLIENTS SINCE THE FIRM DID NOT HAVE A DISCLOSURE FORM THAT ADDRESSED ANNUITY SURRENDERS FOR MUTUAL FUND PURCHASES. EACH OF THE CLIENTS CONFIRMED THAT THEY WERE PROVIDED PROPER, ADEQUATE AND FULSOME DISCLOSURE BY ME. IT IS IMPORTANT TO NOTE THAT I WAS NEVER INFORMED OF ANY "INVESTIGATION" BY WILBANKS. I WAS INFORMED THAT WILBANKS WAS REACHING OUT TO CLIENTS TO CONFIRM WHAT DISCLOSURES WERE MADE TO THEM RELATIVE TO THEIR TRANSACTIONS.

CLIENT ALLEGES VIOLATION OF THE MISSOURI UNIFORM SECURITIES ACT, MISSOURI MERCHANDISING PRACTICES ACT, BREACH OF FIDUCIARY DUTY, BRACH OF CONTRACT, FRAUD AND MISREPRESENTATION, NEGLIGENCE, AND UNJUST ENRICHMENT.

$200,000.00

$35,000.00

I BELIEVE THAT THESE ALLEGATIONS ARE WITHOUT MERIT AND UNWARRANTED. HOWEVER, DUE TO THE COSTS OF ONGOING LITIGATION, I SETTLED THIS CASE.

[CUSTOMER] CONTENDED THAT I DID NOT DISCLOSE TO HIM THAT SURRENDER CHARGES WOULD BE ASSESSED AGAINST THE POLICY ACCOUNT VALUES WHEN THE FACE AMOUNT WAS DECREASED IN YEARS 1-15.

$18,686.79

MML OFFERED TO ALLOW [CUSTOMER] TO SURRENDER HIS VARIABLE LIFE POLICY WITHOUT PENALTY THUS WAIVING $18,686.79 IN SURRENDER CHARGES. MML DID NOT FIND ANY WRONG DOING ON MY PART, THEREFORE THEY (MML) DID NOT SUSPEND OR RESTRICT MY LICENSE NOR DID THEY CHARGE BACK ANY COMMISSION ON THIS CASE. A PROSPECTUS WAS DELIVERED TO [CUSTOMER]. ALL CHARGES AND EXPENSES WERE RECEIVED. [CUSTOMER] WAS COACHED TO THIS DECISION BY REPLACEMENT MINDED AGENTS. SUBSEQUENT TO THIS EVENT [CUSTOMER] PURCHASED TERM INSURANCE FROM THE NEW AGENTS AND INVESTED THE DIFFERENCE. I STILL BELIEVE THAT MY RECOMMENDATION TO PURCHASE VARIABLE LIFE WAS SOUND.