NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES

FAILURE TO REPORT TO THE SUPERINTENDENT WITHIN 30 DAYS OF THE FINAL DISPOSITION OF THE ADMINISTRATIVE ACTION TAKEN BY THE FLORIDA OFFICE OF FINANCIAL REGULATION ON OR ABOUT JANUARY 17, 2012 AND THE FLORIDA DEPARTMENT OF FINANCIAL SERVICES ON OUR ABOUT DECEMBER 27, 2012.

STIPULATION

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

$500.00

I DIDN'T REPORT THE FINES FROM THE STATE OF FLORIDA TO THE INSURANCE COMMISSIONER WITHIN 30 DAYS. THIS WAS PURELY AN ADMINISTRATIVE ISSUE AND THERE WAS NO CUSTOMER HARM. IFP PAID THE FINE ON MY BEHALF.

FLORIDA DEPARTMENT OF FINANCIAL SERVICES.

FAILURE TO REPORT THE ADMINISTRATIVE ACTION TAKEN BY THE FLORIDA OFFICE OF FINANCIAL REGULATION ON JANUARY 17, 2012 TO THE FLORIDA DEPARTMENT OF FINANCIAL SERVICES WITHIN 30 DAYS.

CONSENT ORDER

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

$1,000.00

I DIDN'T REPORT THE FINE FROM THE STATE OF FLORIDA TO THE FLORIDA INSURANCE COMMISSIONER. THIS WAS PURELY AN ADMINISTRATIVE ISSUE AND THERE WAS NO CUSTOMER HARM.

FLORIDA OFFICE OF FINANCIAL REGULATION

N/A

Order

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

$10,000.00

WHEN I JOINED INDEPENDENT FINANCIAL PARTNERS (IFP), MY INVESTMENT ADVISOR LICENSE WASN'T TRANSFERRED TO IFP. I WAS NOT AWARE THAT I WAS NOT PROPERLY REGISTERED TO CONDUCT BUSINESS IN FLORIDA. AS SOON AS THE OVERSIGHT WAS DISCOVERED, IMMEDIATE ACTION WAS TAKEN. IFP ACCEPTED FULL RESPONSIBILITY FOR THE OVERSIGHT AND PAID THE FINE ON MY BEHALF.

CLIENT ALLEGES MISREPRESENTATION, UNAUTHORIZED TRADING AND BREACH OF FIDUCIARY DUTY IN THE RECOMMENDATION AND PURCHASE OF AUCTION RATE SECURITIES AND A MANAGED ASSET ACCOUNT IN SEPTEMBER 2007.

$260,010.00