FINRA

WITHOUT ADMITTING OR DENYING THE FINDINGS, BELENIS CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE ENGAGED IN A PRIVATE SECURITIES TRANSACTION BY INVESTING IN A LIMITED LIABILITY COMPANY THAT HELD A GOLD MINING OPERATION WITHOUT PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. BELENIS ALSO ASSISTED IN RAISING CAPITAL FOR THE LIMITED LIABILITY COMPANY, YET INACCURATELY ANSWERED "NO" ON A FIRM QUESTIONNAIRE ASKING WHETHER HE HAD ASSISTED IN RAISING CAPITAL.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

ANY CAPACITY

20 BUSINESS DAYS

10/5/2015

10/30/2015

Fine paid in full on September 29, 2015.

RAYMOND JAMES FINANCIAL SERVICES

Discharged

VIOLATED FIRM POLICY BY MAINTAINING AN OUTSIDE BUSINESS ACTIVITY WITHOUT KNOWLEDGE OR APPROVAL OF FIRM. ENGAGING IN A PRIVATE SECURITIES TRANSACTION WITHOUT PRIOR FIRM APPROVAL.

I KEPT RAYMOND JAMES INFORMED AT ALL TIMES AS TO MY PERSONAL BUSINESS DEALINGS.

RAYMOND JAMES FINANCIAL SERVICES

Discharged

VIOLATED FIRM POLICY BY MAINTAINING AN OUTSIDE BUSINESS ACTIVITY WITHOUT KNOWLEDGE OR APPROVAL OF FIRM. ENGAGING IN A PRIVATE SECURITIES TRANSACTION WITHOUT PRIOR FIRM APPROVAL.

I KEPT RAYMOND JAMES INFORMED AT ALL TIMES AS TO MY PERSONAL BUSINESS DEALINGS.

THE CLIENT STATES THAT THEY PURCHASED 7,152 SHARES OF STARGAS IN TWO ACCOUNTS AND THE PURCHASES WERE SOLICTED BY THE IR. THE CLIENT STATES THAT AT THE TIME OF PURCHASE HE WAS NOT AWARE THAT THE SISTER COMPANY OF STARGAS HAD DEFAULTERD ON THEIR DIVIDEND PAYMENTS. THE CLIENT STATES THAT SHORTLY AFTER HIS SEPTMEBER 2004 PURCHASES THE COMPANY MISSED A DIVIDEND PAYMENT AND THE STOCK CRASHED. THE STOCK EVENTUALLY WAS SOLD FOR ABOUT $13,946 AND THE CLIENT FEELS THAT SINCE EDWARD JONES PROMOTED AND RESEARCHED THE STOCK, FULL RESITITUION OF LOSSES ARE TO BE MADE IN THE AMOUNT OF $141,071 (DIFFERENCE BETWEEN PURCHASE PRICE AND SALE PRICE).*****ARBITRATION DESCRIPTION: ALLEGATIONS OF BREACH OF FIDUCIARY DUTY, FAILURE TO SUPERVISE AND VIOLATION OF STATE AND FEDERAL SECURITIES LAWS AND NASD AND NYSE RULES IN RECOMMENDING THE PURCHASE OF STAR GAS PARTNERS AND DELTA AIRLINES BONDS. (AMOUNT CLAIMED: $225,000, PLUS LOST OPPORTUNITY COSTS, COSTS, INTEREST AND ATTORNEYS' FEES.)

$141,071.00

$47,500.00

PER A VERBAL COMPLAINT FILED ON THE CLIENT'S BEHALF A RESPONSE WAS SENT TO THE CLIENT ON 6/9/05 STATING THE UPON REVIEW OF THE 10Q DATED 7/29/04 THE COMMON UNIT WOULD PAY A CASH DISTRIBUTION, HOWEVER, SUBORDINATED UNITS WOULD NOT BE PAID. IT WAS ALSO DETERMINED THAT IT DID NOT APPEAR AS THOUGH THE COMMON UNIT DIVIDEND PAYMENT WAS SUSPENDED UNITL THE 10/18/04 8K NOTIFICATION AT WHICH TIME THE SHARE PRICE DECLINED. CLAIM DENIED.*****ARBITRATION: SETTLED FOR $47,500.00

UNSUITABILITY, NEGLIGENCE, MISREPRESENTATION, OMISSION, FRAUD, BREACH OF FIDUCIARY DUTY

$440,000.00

AWARD OF $10,000 COMPENSATORY DAMAGES AGAINST RESPONDENTS JOINTLY AND SEVERALLY***********CIVIL LITIGATION RESOLUTION: VOLUNTARILY DISMISSED WITHOUT PREJUDICE

THE CLIENT PURCHASED VARIOUS MUTUAL FUNDS, LISTED STOCK AND OTC STOCK IN 1999. THE CLIENT STATES DURING THE YEAR 2001, BELENIS LOST HER $53,548.42. THE CLIENT STATES AFTER ASSESSING THE ADVICE AND GUIDANCE OF BELENIS, SHE EXPECTS A FULL REFUND.

$53,548.42

IR AND MARC ZUERCHER MET WITH CLIENT REGARDING HER MARGIN STATUS AND EPXRESSED THEIR CONCERNS. SHE WAS AWARE OF AND UNDERSTOOD THEIR CONCERNS. BETWEEN 6/21/99-9/2/99 $103,438.67 OF INVESTMENTS WERE PURCHASED IN CLIENTS ACCOUNT. ON 3/12/01 CLIENT INSTRUCTED IR TO LIQUIDATE ACCOUNT FOR A TOTAL OF $102,029.10. IN ADDITION, RECORDS SHOW THAT THERE WAS A TOTAL OF $53,296 WIRED FROM HER JONES ACCOUNT TO HER BANK ACCOUNT FOR THE PERIOD OF 11/29/99 - 3/6/01. LOSSES SUSTAINED DO NOT APPEAR TO BE WHAT THE CLIENT STATED. CLAIM DENIED.

CLIENT ASSERTS THAT BELENIS DID NOT EXECUTE A STOP ORDER OR INFORM THE CLIENT WHEN THE VALUE OF HER STOCK DROPPED 4% IN VALUE LAST NOVEMBER AS HAD BEEN PREVIOUSLY ARRANGED. THE CLIENT CLAIMS SHE HAS INCURRED A LOST OF $20,000 AS A RESULT OF BELENIS' FAILURE TO SELL.

$20,000.00

BELENIS STATES THAT CUSTOMER DID NOT INSTRUCT HIM TO SELL ANY SPECFIC STOCKS OR INSTRUCT HIM TO CONTACT HER IN THE EVENT HER STOCKS DECLINED IN VALUE TO A SPECFIC LEVEL DURING THEIR 11/10/00 MEETING. BELENIS STATE DURING THIS MEETING HE ENCOURAGED THE CLIENT TO MAINTAIN HER POSITIONS THROUGH THE MARKET DOWNTURN AS HE BELIEVED THEY WOULD REGAIN THEIR VALUE. BELENIS FURTHER STATES DURING THEIR 1/16/01 MEETING IN WHICH THEY DISCUSSED THE LOSSES SHE INCURRED, THE CLIENT ACKNOWLEDGED SHE DID NOT GIVE HIM ANY SPECIFIC INSTRUCTIONS. CLAIM DENIED.

THE CUSTOMER CLAIMS IR EMPLOYED BY EDWARD JONES SHOULD NOT HAVE ACCEPTED HIS SOON TO BE EX-WIFE'S INSTRUCTIONS TO SELL 2,000 SHARES OF A STOCK IN THEIR JOINT ACCOUNT. INDICATES IR WAS AWARE OF THE MARITAL PROBLEMS AND CLAIMS IR SHOULD NOT HAVE ACCEPTED HIS WIFES ASSURANCES THAT HE WAS AWARE OF THE TRADE. INDICATES HE HAD A LOW COST BASIS FOR THE STOCK SO TAX PROBLEMS HAVE BEEN CREATED. REQUESTS REIMBURSEMENT FOR TAXES AND ASKS THAT THE POSITION BE REINSTATED. A SPECIFIC AMOUNT IS NOT MENTIONED BUT POTENTIAL AMOUNT IF OVER $5,000.

THE CUSTOMER WAS ADVISED THAT HIS WIFE WAS LISTED AS A JOINT TENANT ON THE ACCOUNT AND DID HAVE THE AUTHORITY TO ISSUE INSTRUCTIONS TO THE IR CONCERNING ORDERS IN THE ACCOUNT. THE IR ALSO CLAIMS THAT THE CUSTOMERS' WIFE HAD GIVEN ALL PREVIOUS INSTRUCTIONS FOR THE ACCOUNT. HE ALSO STATES THAT THE CUSTOMER HAD NOT INSTRUCTED HIM TO CONFIRM ALL ORDERS RECEIVED FROM HIS WIFE WITH HIM BEFORE THEY WERE ENTERED. CLAIM DENIED. NOT PROVIDED.