Failure to undertake due diligence,over concentration and failure to disclose risk in connection with the purchase of securities in 2012 and 2013

$290,000.00

NASD

NASD RULES 2110, 3010(C)(1)(C), 3070, 3110 -WILBANKS, ACTING ON BEHALF OF HIS MEMBER FIRM, FAILED TO SPECIFY A CYCLE FOR THE INSPECTION AND FAILED TO CONDUCT INSPECTIONS OF NON-BRANCH LOCATIONS IN ITS WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY NASD RULE 3010 (C)(1)(C). THE FINDINGS STATED THAT WILBANKS, ACTING ON BEHALF OF HIS MEMBER FIRM, FAILED TO FILE A QUARTERLY REPORT WITH NASD DISCLOSING INFORMATION REGARDING CUSTOMER COMPLAINTS. THE FINDINGS ALSO STATED THAT WILBANKS, ACTING ON BEHALF OF HIS MEMBER FIRM, FAILED TO PRESERVE IN AN EASILY ACCESSIBLE PLACE ITS ELECTRONIC COMMUNICATIONS RECEIVED AND SENT INCLUDING INTER-OFFICE MEMORANDA AND COMMUNICATIONS. THE FINDINGS ALSO INCLUDED THAT WILBANKS, ACTING ON BEHALF OF HIS MEMBER FIRM, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL CORRESPONDENCE.

Acceptance, Waiver & Consent(AWC)

Monetary/Fine

$25,000.00

Censure

WITHOUT ADMITTING OR DENYING THE FINDINGS, WILBANKS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, HE IS CENSURED AND FINED $25,000 JOINTLY AND SEVERALLY.

OKLAHOMA DEPARTMENT OF SECURITIES

FAILURE TO ESTABLISH A SUPERVISORY SYSTEM AND SUPERVISORY PROCEDURES IN VIOLATION OF MULTIPLE NASD AND SEC RULES; FAILURE TO ESTABLISH, MAINTAIN, AND/OR ENFORCE FIRM'S WRITTEN SUPERVISORY PROCEDURES; FAILURE TO INSPECT NON-BRANCH OFFICES ON A REGULAR SCHEDULE; FAILURE TO SUPERVISE TWO AGENTS; AND FAILURE TO COMPLY WITH AGREEMENTS WITH STATES OF PENNSYLVANIA AND MARYLAND IN REGARD TO PARTICULAR AGENT.

Consent

Censure

PROHIBITION FROM ENGAGING IN ANY ACTIVITY RELATING TO THE TRAINING AND SUPERVISION OF AGENTS, OTHER REGISTERED PRINCIPALS AND INVESTMENT ADVISER REPRESENTATIVES OR FIRM COMPLIANCE MATTERS.

ACTION TAKEN AGAINST WILBANKS SECURITIES WAS SETTLED WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR THE CONCLUSIONS OF LAW IN THE RECOMMENDATION. SETTLEMENT WAS MADE TO AVOID THE COST AND DISTRACTION OF PROTRACTED LITIGATION.