MISSOURI

IT IS ALLEGED THAT WALKER AND WILLIAM KEEN, THROUGH A SERIES OF SEMINARS AND MEETINGS, CONVINCED SEVERAL MISSOURI RESIDENTS THAT, UPON RETIREMENT, THEY COULD MATCH OR EVEN EXCEED THEIR CURRENT SALARY BY RETIRING AND INVESTING THEIR RETIREMENT FUNDS WITH WALKER AND KEEN. WALKER AND KEEN ESPOUSED A BUY-AND-HOLD APPROACH TO INVESTING BUT RECOMMENDED THAT INVESTORS PUT THEIR ACCOUNTS IN A WRAP ACCOUNT. WALKER AND KEEN IMPLEMENTED AN INVESTMENT STRATEGY FOR THESE INVESTORS WHICH PLACED THE CUSTOMERS' FUNDS IN UNSUITABLY AGGRESSIVE INVESTMENTS. LOSSES AND CASH WITHDRAWALS FROM THE INVESTORS' ACCOUNTS FORCED SOME OF THESE INVESTORS TO RETURN TO WORK. AS LOSSES MOUNTED, WALKER AND KEEN RECOMMENDED THAT INVESTORS SELL SECURITIES IN THEIR WRAP ACCOUNTS, TERMINATE THE WRAP ACCOUNT AND PURCHASE B SHARE MUTUAL FUNDS.

Consent

Monetary/Fine

$55,550.00

WALKER IS CENSURED; WALKER IS SUSPENDED FOR A PERIOD OF FIFTEEN (15) DAYS (BUT THE SUSPENSION WILL BE WAIVED PROVIDED THAT WALKER COMPLIES WITH THE REMAINING PROVISIONS OF THE ORDER); FOR A PERIOD OF TWO (2) YEARS, WALKER WILL PROVIDE QUARTERLY REPORTS TO THE DIVISION RELATING TO HIS SECURITIES ACTIVITIES; WALKER WILL PAY $40,000 TO INVESTOR EDUCATION AND $15,550 TO THE SECURITIES DIVISION; AND WALKER WILL PAY HIS OWN COSTS AND ATTORNEYS FEES.

WALKER IS CENSURED; WALKER IS SUSPENDED FOR A PERIOD OF FIFTEEN (15) DAYS (BUT THE SUSPENSION WILL BE WAIVED PROVIDED THAT WALKER COMPLIES WITH THE REMAINING PROVISIONS OF THE ORDER); FOR A PERIOD OF TWO (2) YEARS, WALKER WILL PROVIDE QUARTERLY REPORTS TO THE DIVISION RELATING TO HIS SECURITIES ACTIVITIES; WALKER WILL PAY $40,000 TO INVESTOR EDUCATION AND $15,550 TO THE SECURITIES DIVISION; AND WALKER WILL PAY HIS OWN COSTS AND ATTORNEYS FEES.

CLAIMANTS ALLEGE THAT UNSUITABLE RECOMMENDATIONS OF GROWTH EQUITY CAUSED THEM IN EXCESS OF $500,00 IN LOSSES.

$500,000.00

$172,000.00

ON NOVEMBER 6, 2006, CLAIMANTS VOLUNTARILY DISMISSED WITH PREJUDICE RESPONDENTS WACHOVIA SECURITIES, LLC, CHRISTOPHER WALKER, AND WILLIAM KEEN FOR ALL ACTIONS, OMISSIONS, AND MISREPRESENTATIONS THAT ALLEGEDLY OCCURRED AFTER JUNE 30, 2003. HOWEVER, CLAIMS ARE STILL PENDING WITH PRUDENTIAL, KEEN AND WALKER WITH ACTIVITY PRIOR TO 06/30/03.

CLIENT ALLEGES FINANCIAL ADVISOR MADE UNSUITABLE SECURITIES RECOMMENDATIONS.

$150,000.00

$63,862.50

CLIENT ALLEGES THAT FINANCIAL ADVISOR "UNDERSTOOD THAT THIS WAS A RETIREMENT FUND, NOT A SPECULATIVE VENTURE...[AND THAT] THEY WERE AWARE OF MY AGE, FINANCIAL SITUATION, INVESTMENT OBJECTIVES AND EXPERIENCE." SHE GOES ON TO CLAIM THAT THE "P/E RATIOS OF MY INITIAL PORTFOLIO WERE FAR FROM CONSERVATIVE" AND THAT "[T]HEY WERE INAPPROPRIATE FOR A PERSON IN MY SITUATION." ALLEGED DAMAGES: EST TO EXCEED $5,000

$55,000.00

CLAIMANT ALLEGES THAT FINANCIAL ADVISOR WALKER MADE UNSUITABLE SECURITIES RECOMMENDATIONS

$103,000.00

$38,500.00

CLAIMANTS ALLEGED FRAUD & UNSUITABILITY

$441,000.00

$164,000.00

CUSTOMERS SETTLED FOR $67,500.00 AND CUSTOMER SETTLED FOR $35,000. CUSTOMER SETTLED FOR $61,500 ON 10/7/2004.