VIOLATION OF INDUSTRY RULES, INCLUDING BUT NOT LIMITED TO THE "KNOW YOUR CUSTOMER" STANDARD AND FINRA'S CUSTOMER SUITABILITY STANDARD (RULE 2310) AS WELL AS FINRA RULES 3010 AND 2110; VIOLATION OF DUTY OF CARE; NEGLIGENCE; BREACH OF CONTRACT; BREACH OF FIDUCIARY DUTY; COMMON LAW FRAUD;

$250,000.00

REPRESENTATIVE WAS NOT NAMED AS A RESPONDENT IN THIS COMPLAINT. ALL RECOMMENDATIONS AND RISKS WERE DISCUSSED AT LENGTH WITH THE CLIENT PRIOR TO THE TRANSACTIONS. LOSSES WERE A RESULT OF UNFORESEEABLE MARKET CONDITIONS. CLIENT CONTINUED HER RELATIONSHIP WITH THE REPRESENTATIVE FOR APPROXIMATELY 2 YEARS AFTER THESE ALLEGED LOSSES OCCURRED. THE FIRM SETTLED THE CLAIMS TO AVOID THE COST AND UNCERTAINTY OF LITIGATION, WITH NO ADMISSION OF WRONGDOING AND NO MONETARY CONTRIBUTION FROM THE REPRESENTATIVE

THE CLIENTS ALLEGED THAT THE ADVISOR MISREPRESENTED THE AMOUNT OF PREMIUMS NEEDED TO MAINTAIN THE HUSBAND'S LIFE INSURANCE POLICY.

$23,002.19

THE CLIENTS' ATTORNEY COMPLAINED THROUGH THE SEC THAT THE INVESTMENTS THEY PURCHASED FROM AMERICAN EXPRESS FINANCIAL ADVISORS WERE UNSUITABLE GIVEN THEIR AGE AND RISK TOLERANCE. THEY ALSO QUESTIONED THE TRANSFER FROM ONE CLASS OF MUTUAL FUNDS TO ANOTHER. NO SPECIFIC REQUEST FOR DAMAGES WAS MADE, HOWEVER, THEY CITED THE VALUE OF THEIR PORTFOLIO PRIOR TO INVESTING AT AEFA AND AFTERWARDS AND IT HAD DECLINED BY APPROXIMATELY $190000.00

$190,000.00

THE FIRM FOUND THE CLIENTS RECEIVED FULL AND FAIR DISCLOSURE OF THE RISKS ASSOCIATED TO THE MUTUAL FUNDS THEY HAD PURCHASED AS EVIDENCED BY THIER SIGNATURES ON THE APPROPRIATE FORMS AND THEIR RECEIPT OF THE RESPECTIVE PROSPECTUSES. IT APPEARED THE CLIENTS COMPLAINT WAS RELATED TO THE DOWNTURN IN THE MARKET. THERE WERE NUMEROUS MEETINGS BETWEEN THE CLIENTS AND THEIR ADVISOR TO REVIEW THEIR SITUATION AND EXPLAIN THEIR INVESTMENTS. FURHTER, WHEN THE CLIENTS AGREED TO TRANSFER THEIR MUTUAL FUNDS FROM ONE CLASS TO ANOTHER, THEY INCURRED NO FRONT-END OR BACK-END SALES CHARGES AS A RESULT.