FINRA

MILLER WAS NAMED A RESPONDENT IN A FINRA COMPLAINT ALLEGING THAT HE PARTICIPATED IN AT LEAST FIVE PRIVATE SECURITIES TRANSACTIONS WITH THREE DIFFERENT ENTITIES IN WHICH FOUR OF HIS MEMBER FIRM'S CUSTOMERS INVESTED A TOTAL OF $1,550,000. THE COMPLAINT ALLEGES THAT AT NO TIME WERE ANY OF THE ENTITIES IN WHICH THE CUSTOMERS INVESTED ON THE LIST OF APPROVED INVESTMENT PRODUCTS AT MILLER'S FIRM. MILLER DID NOT PROVIDE PRIOR WRITTEN NOTICE OR A FULL AND DETAILED DESCRIPTION OF THE INVESTMENT TO HIS MEMBER FIRM ABOUT ANY OF THE TRANSACTIONS.

Decision

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

$25,000.00

Monetary Penalty other than Fines

$9,474.35

Suspension

All capacities

Nine months

7/16/2018

4/15/2019

All capacities

Three months

4/16/2019

7/16/2019

Extended Hearing Panel Decision rendered December 18, 2015 wherein Miller was suspended from associating with any FINRA member in any capacity for two years and fined $50,000. Miller is also ordered to pay costs of $9,474.35. The sanctions were based on findings that Miller participated in private securities transactions, with various entities in which four of his member firm's customers invested a total of $1,550,000, without providing the required prior written notice to his firm. The findings stated that Miller was either working with the issuer or serving as an intermediary between the issuer and investor. Miller was involved in constant communications with a promoter about marketing one of the investments, acted as a proxy for an investor, analyzed and recommended an investment, and introduced an investment and endorsed the promoter to the investment. Miller not only deprived his firm of any opportunity to assess the risks associated with the investments by failing to notify it before becoming involved, but he promoted another investment in direct contravention of his firm's evaluation, conclusion and instructions to him. On January 8, 2016, Miller appealed the decision to the National Adjudicatory Council (NAC). The sanctions are not in effect pending review. NAC decision rendered May 23, 2018 wherein the NAC affirmed the findings and modified the sanctions imposed by the Extended Hearing Panel decision. The NAC modified the sanctions imposed by reducing the fine to $25,000 and reducing the suspension from two years to nine months in all capacities with any FINRA member for selling away in four private securities transactions and three months in all capacities with any FINRA member for selling away in one private securities transaction. Miller is to serve the suspensions consecutively. The NAC also affirmed the Extended Hearing Panel's order that Miller pay costs of $9,474.35. The decision became final on June 25, 2018.

BENJAMIN F EDWARDS & CO. INC.

Discharged

REVIEW OF ACTIVITIES RELATING TO THE FIRM'S PROCEDURES REGARDING OUTSIDE BUSINESS ACTIVITES AND PRIVATE SECURITIES TRANSACTIONS.

CLIENT ALLEGED ANNUITY SOLD TO HER WAS TOTALLY MISREPRESENTED. LOSSES NOT SPECIFIED IN INITIAL VERBAL COMPLAINT. ACTIVITY OCCURRED ON MAY 2, 2000.

$13,112.20

CLIENT ACKNOWLEDGED THAT ACTIONS BY THE FINANCIAL CONSULTANT WERE IN ERROR AND THEY DIDN'T BELIEVE THEM TO BE INTENTIONAL.

UNLAWFUL USE OF A LICENSE.

PLEA OF GUILTY

I WAS NOT AWARE THAT THIS HAD TO BE DISCLOSED ON MY U-4 FORM.