FINRA

Without admitting or denying the findings, Willoughby consented to the sanctions and to the entry of findings that he engaged in an unsuitable pattern of short-term trading of Unit Investment Trusts (UITs) in customer accounts. The findings stated that Willoughby recommended that his customers roll over a UIT before its maturity date in order to purchase a subsequent series of the same UIT, which generally had the same or similar investment objectives and strategies as the prior series. Willoughby's recommendations caused his customers to incur unnecessary sales charges and were unsuitable in view of the frequency and cost of the transactions.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All capacities

Three months

7/1/2019

9/30/2019

CUSTOMER ALLEGED UNSUITABLE INVESTMENTS.

$33,035.29

CUSTOMERS ALLEGE THAT DURING 2006 THROUGH 2008 FINANCIAL ADVISOR PURCHASED VOLATILE SECURITIES WHEN CUSTOMERS REQUESTED CONSERVATIVE INVESTMENTS FOR THEIR RETIREMENT. DAMAGES UNSPECIFIED.

$249,154.00

$87,500.00

MORGAN STANLEY SETTLED THIS CLAIM WITHOUT CONSULTING ME. THE CASE HAD ABSOLUTELY NO MERIT WHATSOEVER. THE CLIENTS CLAIM "THAT THEY DID NOT KNOW" WHEN IN FACT THEY WERE SHOWN TO HAVE VIEWED THEIR ACCOUNTS ONLINE AND VIEWED MS RESEARCH TO THE TUNE OF 40,000 PAGE VIEWS PER YEAR. I CAN ONLY BELIEVE THAT IT WAS SETTLED FOR NUISANCE VALUE DURING THE BANKING AND FINANCIAL CRISIS.

CLIENTS ALLEGE UNAUTHORIZED TRADE ON SALE OF 4,800 INTC ON 11/6/98. REQUESTING REIMBURSEMENT OF $96,000.

$96,000.00

THE CLIENTS COMPLAINED OF AN UNAUTHORIZED TRADE WHICH HE IMMEDIATELY WITHDREW WHEN WE SHOWED HIM WRITTEN PROOF THAT HE NOT ONLY APPROVED BUT ACTUALLY SOLICITED THE TRANSACTION IN QUESTION. CLIENT PROVIDED ACQUISITION DATES ON 10,000 SHARES OF INTEL STOCK AND GAVE INSTRUCTIONS TO SELL ANY SHARES OVER 12 MONTHS OLD. AN ORDER TO SELL 7,835 SHARES WAS CONFIRMED AND ENTERED AND THEN LATER CHANGED BY THE CLIENT FROM A $90 SALE PRICE TO $95. ALL DATES WERE PROVIDED BY THE CLIENT AND THE CLIENT WAS AWARE THAT 7,835 SHARES WOULD BE SOLD.