FINRA

Without admitting or denying the findings, Vildzius consented to the sanctions and to the entry of findings that he engaged in quantitatively unsuitable trading in the accounts of customers. The findings stated that Vildzius recommended the trading in the customers' accounts and they routinely followed his recommendations. As a result, Vildzius exercised de facto control over the customer accounts. Vildzius' trading of the accounts, which utilized a short-term, active trading strategy that included frequent in-and-out trading, resulted in high turnover rates and cost-to-equity ratios as well as significant losses. As a result of Vildzius' excessive trading, the customers suffered collective losses of $32,240 and paid $33,449 in commissions and fees.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All capacities

six months

10/19/2020

4/18/2021

MASSACHUSETTS

ON OR ABOUT MARCH 23, 2015, NETWORK 1 SUBMITTED TO THE CRD A UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER (FORM U-4) SEEKING THE REGISTRATION OF VILDZIUS IN MASSACHUSETTS AS AN AGENT OF NETWORK 1 (THE "APPLICATION"). VILDZIUS HAS BEEN THE SUBJECT OF ELEVEN (11) DISCLOSURES BETWEEN 1996 AND 2015. VILDZIUS HAS BEEN THE SUBJECT OF FOUR CUSTOMER COMPLAINTS BETWEEN 1996 AND 2015, WHICH ALLEGED, INTER ALIA, UNAUTHORIZED TRADING, CHURNING, AND FAILURE TO FOLLOW INSTRUCTIONS. VILDZIUS DID NOT CONTRIBUTE INDIVIDUALLY TO THE SETTLEMENT OF ANY OF THESE CUSTOMER COMPLAINTS. TWO JUDGMENT LIENS HAVE BEEN ISSUED AGAINST VILDZIUS. BOTH LIENS REMAIN OUTSTANDING AS OF THE DATE OF THE ORDER. VILDZIUS OWES APPROXIMATELY $4,809 TO FIA CARD SERVICES NA ON A JUDGMENT LIEN FILED ON OR ABOUT JUNE 13, 2012, AND APPROXIMATELY $4,253 TO CAPITAL ONE BANK ON A JUDGMENT LIEN ALSO FILED ON OR ABOUT JUNE 13, 2012. VILDZIUS WAS TERMINATED BY WACHOVIA SECURITIES, LLC, ON OR ABOUT JANUARY 19, 2006, FOR UNAUTHORIZED TRADING. VILDZIUS WAS THE SUBJECT OF THREE REGULATORY ACTIONS. ON OR ABOUT APRIL 10, 2006, HE WAS SUSPENDED FROM ASSOCIATING WITH ANY FINRA (F/K/A NASD) MEMBER IN ANY CAPACITY FOR 30 DAYS, FINED $9,000, AND ORDERED TO PAY $16,000 IN RESTITUTION FOR EXERCISING DISCRETION IN A CUSTOMER'S ACCOUNT WITHOUT AUTHORIZATION TO DO SO AND ENGAGING IN UNSUITABLE AND EXCESSIVE TRADING. BECAUSE OF THE FINRA ACTION, THE STATE OF CONNECTICUT PLACED RESTRICTIONS ON VILDZIUS'S REGISTRATION IN ITS STATE. ON OR ABOUT JANUARY 31, 2014, FINRA SUSPENDED VILDZIUS FROM ASSOCIATING WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 30 DAYS, AND FINED HIM $2,500 FOR FAILING TO DISCLOSE HIS TWO OUTSTANDING JUDGMENT LIENS. REVIEW OF THE FOREGOING INCIDENTS INVOLVING VILDZIUS HAS MOVED THE DIVISION TO PLACE CONDITIONS ON HIS REGISTRATION AS AN AGENT OF NETWORK 1.

Order

Undertaking

THE DIVISION APPROVED VILDZIUS'S APPLICATION FOR REGISTRATION IN MASSACHUSETTS AS AN AGENT OF NETWORK 1 UPON THE CONDITIONS SET FORTH BELOW, WHICH ARE EFFECTIVE FOR FIVE (5) YEARS FROM THE DATE OF ENTRY OF THE ORDER: A) VILDZIUS'S MASSACHUSETTS BUSINESS SHALL BE LIMITED IN SCOPE; B) VILDZIUS SHALL BE SUPERVISED, ON A HEIGHTENED BASIS; C) NETWORK 1 SHALL NOT PERMIT VILDZIUS TO HAVE ANY PRINCIPAL, SUPERVISORY, OR MANAGERIAL DUTIES WHILE ASSOCIATED WITH NETWORK 1; D) SHOULD VILDZIUS BECOME THE SUBJECT OF ANY WRITTEN OR ORAL CUSTOMER COMPLAINT CONCERNING ALLEGATIONS ARISING FROM HIS CONDUCT OF SECURITIES BUSINESS, NETWORK 1 SHALL NOTIFY THE DIRECTOR, IN WRITING, WITHIN TEN (10) BUSINESS DAYS OF NETWORK 1'S RECEIPT OF SUCH COMPLAINT; E) SHOULD VILDZIUS BECOME THE SUBJECT OF ANY REGULATORY INVESTIGATION, INTERNAL INVESTIGATION, ARBITRATION PROCEEDING, OR SECURITIES-RELATED LITIGATION CONCERNING ALLEGATIONS ARISING FROM HIS CONDUCT OF SECURITIES BUSINESS, NETWORK 1 SHALL NOTIFY THE DIRECTOR, IN WRITING, WITHIN TEN (10) BUSINESS DAYS OF THE INVESTIGATION, PROCEEDING, OR LITIGATION; F) VILDZIUS SHALL NOT PERFORM ANY PRINCIPAL, SUPERVISORY, OR MANAGERIAL DUTIES WHILE ASSOCIATED WITH NETWORK 1; G) VILDZIUS SHALL NOTIFY HIS SUPERVISOR OF THE RECEIPT OF ANY CUSTOMER COMPLAINT, ORAL OR WRITTEN, CONCERNING ALLEGATIONS ARISING FROM HIS CONDUCT AS A REGISTERED REPRESENTATIVE; H) VILDZIUS SHALL NOTIFY HIS SUPERVISOR OF THE INITIATION OF ANY ARBITRATION PROCEEDING, REGULATORY INVESTIGATION, OR SECURITIES-RELATED LITIGATION CONCERNING ALLEGATIONS ARISING FROM HIS CONDUCT OF SECURITIES BUSINESS; I) VILDZIUS SHALL NOTIFY HIS SUPERVISOR OF ANY INACCURACY IN ANY REPRESENTATION MADE TO THE DIVISION HEREIN OR THE BREACH OF ANY PROVISION OF HIS UNDERTAKINGS AND REPRESENTATIONS; AND J) FIVE (5) YEARS AFTER THE ENTRY OF THE ORDER, VILDZIUS SHALL SUBMIT TO NETWORK 1 AND THE DIRECTOR AN AFFIDAVIT STATING THAT HE HAS FULLY COMPLIED WITH ALL CONDITIONS OF THE ORDER REFERENCED IN PART 11 OF THE UNDE

AND J) FIVE (5) YEARS AFTER THE ENTRY OF THE ORDER, VILDZIUS SHALL SUBMIT TO NETWORK 1 AND THE DIRECTOR AN AFFIDAVIT STATING THAT HE HAS FULLY COMPLIED WITH ALL CONDITIONS OF THE ORDER REFERENCED IN PART 11 OF THE UNDERTAKINGS, OR, IN THE EVENT THAT VILDZIUS CANNOT SUBMIT THE REQUIRED AFFIDAVIT, HE SHALL INSTEAD SUBMIT A STATEMENT EXPLAINING WHY.

FINRA

ARTICLE V, SECTION 2(C) OF THE FINRA BY-LAWS, AND FINRA RULES 1122 AND 2010: WHILE REGISTERED WITH HIS MEMBER FIRM, VILDZIUS FAILED TO TIMELY DISCLOSE ON HIS UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER (FORM U4) THE MATERIAL FACT THAT HE HAD TWO OUTSTANDING JUDGMENTS.

Acceptance, Waiver & Consent(AWC)

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

$2,500.00

Suspension

ANY CAPACITY

ONE MONTH

2/18/2014

3/17/2014

WITHOUT ADMITTING OR DENYING THE FINDINGS, VILDZIUS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE HE IS FINED $2,500 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR ONE MONTH. THE SUSPENSION IS IN EFFECT FROM FEBRUARY 18, 2014 THROUGH MARCH 17, 2014. FINE PAID IN FULL ON 02/27/14.

STATE OF CONNECTICUT

DUE TO AWC, STATE OF CONNECTICUT PUT MR. VILDZIUS ON RESTRICTED REGISTRAION.

Stipulation and Consent

NONE

NASD

NASD RULES 2510(B), 2310, 2110 AND INTERPRETIVE MATERIAL 2310-2; VILDZIUS EXERCISED DISCRETION IN THE ACCOUNT OF A PUBLIC CUSTOMER WITHOUT CUSTOMER'S PRIOR WRITTEN AUTHORIZATION; HE ENGAGED IN UNSUITABLE AND/OR EXCESSIVE TRADING IN CUSTOMER'S ACCOUNT.

Acceptance, Waiver & Consent(AWC)

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

Restitution

Suspension

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS FINED $9,000, ORDERED TO PAY $16,000 IN RESTITUTION AND SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY FOR 30 DAYS. THE FINE MUST BE PAID BEFORE HE REASSOCIATES WITH NASD MEMBER FOLLOWING THE SUSPENSION OR BEFORE REQUESTING RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER PROCEEDING. AS A PRE-CONDITION TO HIS REASSOCIATION WITH A MEMBER FIRM, HE MUST BE CURRENT WITH HIS RESTITUTION PAYMENTS AT THE TIME OF APPLICATION FOR REASSOCIATION. SATISFACTORY PROOF OF PAYMENT OF THE BIMONTHLY RESTITUTION PAYMENTS OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION SHALL BE PROVIDED TO NASD. IF FOR ANY REASON RESPONDENT CANNOT LOCATE CUSTOMER, AFTER REASONABLE AND DOCUMENTED EFFORTS MADE, RESPONDENT SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. SUSPENSION COMMENCE ON MAY 1, 2006 AND WILL CONCLUDE AT THE CLOSE OF BUSINESS ON MAY 30, 2006. FINES PAID ON 10/22/2007.