NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

NASD RULES 2110 AND 3040 - ENGAGED IN PRIVATE SECURITIES TRANSACTIONS WITHOUT PRIOR WRITTEN NOTICE TO, AND APPROVAL FROM, HIS MEMBER FIRM.

Acceptance, Waiver & Consent(AWC)

Monetary/Fine

$7,500.00

Disgorgement/Restitution

Suspension

WITHOUT ADMITTING OR DENYING THE FINDINGS, BUCKLER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THEREFORE, HE IS FINED $7,500, WHICH INCLUDES DISGORGEMENT OF THE BALANCE OF UNLAWFUL PROFITS OF $2,315.83, AND SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY FOR 60 DAYS. THE FINE MUST BE PAID BEFORE REASSOCIATING WITH ANY NASD MEMBER FOLLOWING THE SUSPENSION OR BEFORE REQUESTING RELIEF FROM ANY STATUTORY DISQUALIFICATION. BUCKLER'S SUSPENSION IS EFFECTIVE JUNE 4, 2001 TO AUGUST 8, 2001.

In February of 1999, I was contacted by an Insurance Marketing Organization that offered 6-Month Fixed Rate Insured Notes (also advertised in the local Kansas City Star) which were insured through CNA Insurance Company. I was informed of their exemption from Securities Registration; that only a State Insurance License was needed. To confirm this information, I had many conversations with the Kansas, Missouri, and Florida Securities Offices and each time I was told this product was not listed as a Security. I was asked to fax the information on the Note to the Kansas Security Office who would investigate the matter and get back with me if it did not meet the exemption. No phone calls or information was returned stating it was not exempt as I was told would happen. I contacted Tower Square Sales Department about the Note, they gave me no help but did advise me to contact my District Manager who I had already spoken with about offering Fixed Rate Notes and again his response was; "It is not necessary to list fixed rate products". At all times I was offering the product, which involved 4 sales, I believed I was operating in accordance of Tower Square Policy. This event was settled by my "Acceptance without Admission of Guilt". My FINRA Report shows 2 regulatory events and 1 termination even though it is all in reference to this same one event. I hired an attorney to argue my side of this event and it continued for over a year. I received a 60-day suspension from the National Association of Securities Dealers, I resigned from Tower Square, paid the minimum fine of $5,000 and repaid all commissions earned from the 4 sales of approximately $2,315.83. No further action was taken.

KANSAS SECURITIES COMMISSIONER

BUCKLER SOLD UNREGISTERED SECURITIES AS AN UNREGISTERED BROKER/DEALER. BUCKLER ALSO SOLD SECURITIES NOT APPROVED BY TOWER SQUARE SECURITIES (SELLING AWAY).

Stipulation and Consent

Monetary/Fine

$5,000.00

CENSURE & FINE.

In February of 1999, I was contacted by an Insurance Marketing Organization that offered 6-Month Fixed Rate Insured Notes (also advertised in the local Kansas City Star) which were insured through CNA Insurance Company. I was informed of their exemption from Securities Registration; that only a State Insurance License was needed. To confirm this information, I had many conversations with the Kansas, Missouri, and Florida Securities Offices and each time I was told this product was not listed as a Security. I was asked to fax the information on the Note to the Kansas Security Office who would investigate the matter and get back with me if it did not meet the exemption. No phone calls or information was returned stating it was not exempt as I was told would happen. I contacted Tower Square Sales Department about the Note, they gave me no help but did advise me to contact my District Manager who I had already spoken with about offering Fixed Rate Notes and again his response was; "It is not necessary to list fixed rate products". At all times I was offering the product, which involved 4 sales, I believed I was operating in accordance of Tower Square Policy. This event was settled by my "Acceptance without Admission of Guilt". My FINRA Report shows 2 regulatory events and 1 termination even though it is all in reference to this same one event. I hired an attorney to argue my side of this event and it continued for over a year. I received a 60-day suspension from the National Association of Securities Dealers, I resigned from Tower Square, paid the minimum fine of $5,000 and repaid all commissions earned from the 4 sales of approximately $2,315.83. No further action was taken.

TOWER SQUARE SECURITIES

Discharged

SELLING AWAY FROM THE FIRM

In February of 1999, I was contacted by an Insurance Marketing Organization that offered 6-Month Fixed Rate Insured Notes (also advertised in the local Kansas City Star) which were insured through CNA Insurance Company. I was informed of their exemption from Securities Registration; that only a State Insurance License was needed. To confirm this information, I had many conversations with the Kansas, Missouri, and Florida Securities Offices and each time I was told this product was not listed as a Security. I was asked to fax the information on the Note to the Kansas Security Office who would investigate the matter and get back with me if it did not meet the exemption. No phone calls or information was returned stating it was not exempt as I was told would happen. I contacted Tower Square Sales Department about the Note, they gave me no help but did advise me to contact my District Manager who I had already spoken with about offering Fixed Rate Notes and again his response was; "It is not necessary to list fixed rate products". At all times I was offering the product, which involved 4 sales, I believed I was operating in accordance of Tower Square Policy. This event was settled by my "Acceptance without Admission of Guilt". My FINRA Report shows 2 regulatory events and 1 termination even though it is all in reference to this same one event. I hired an attorney to argue my side of this event and it continued for over a year. I received a 60-day suspension from the National Association of Securities Dealers, I resigned from Tower Square, paid the minimum fine of $5,000 and repaid all commissions earned from the 4 sales of approximately $2,315.83. No further action was taken.