FIDELITY BROKERAGE SERVICES, LLC

FIDELITY TRADE SECRET INFORMATION, INCLUDING CUSTOMER ACCOUNT INFORMATION AND MISAPPROPRIATED SUCH INFORMATION FOR THE PURPOSE OF DIVERTING CUSTOMER ACCOUNTS FROM FIDELITY TO VISIONLINK. FIDELITY ALSO ALLEGED THAT MR. VANCE VIOLATED THE UNFAIR COMPETITION ACT BY BREACHING HIS EMPLOYEE AGREEMENT WITH FIDELITY AND BY MISAPPROPRIATING FIDELITY'S TRADE SECRETS.

Judgment Rendered

Cease and Desist

THIS WAS AN ATTEMPT BY FIDELITY TO KEEP ME FROM SOLICITING FORMER CLIENTS OF MINE WHILE I HAD BEEN EMPLOYED BY FIDELITY. I WAS NOT FOUND TO BE ENGAGING IN THESE ACTIVITES. NO WRONGDOING WAS DONE, NO DAMAGES WERE DONE TO FIDELITY, NO FINES WERE IMPOSED OR PAID. FIDELITY'S CLAIMS WERE BASELESS. I AGREED TO NOT PROACTIVELY SOLICIT ANY FORMER CLIENTS OF MINE WHILE I WAS EMPLOYED BY FIDELITY FOR THE SPACE OF ONE YEAR FROM 10/2007.

THE CLIENT ALLEGES THAT IN JULY 1997 HE MET WITH MR. VANCE WHO RECOMMENDED HE PURCHASE A VARIABLE ANNUITY. THE CLIENT NOW CLAIMS THIS INVESTMENT WAS UNSUITABLE FOR HIM.

$20,000.00

$6,500.00

TO AVOID THE RISK AND EXPENSE OF LITIGATION, FIDELITY AGREED TO SETTLE THIS MATTER FOR $6,500.00. MR. VANCE WAS NOT ASKED TO CONTRIBUTE TO THE SETTLEMENT. MR. VANCE BELIEVES THAT BASED ON PRIOR INVESTMENT DISCUSSIONS WITH THIS CLIENT THAT HIS PURCHASE OF THE VARIABLE ANNUITY WAS SUITABLE AND IN LINE WITH THE CUSTOMERS STATES INVESTMENT OBJECTIVE FOR THIS PRODUCT.