**UPDATE - THIS DISCLOSURE IS NO LONGER REPORTABLE ON THE CURRENT U4 BECAUSE IT WAS FILED MORE THAN 24 MONTHS AGO AND DID NOT SETTLE FOR $15,000 OR MORE** CLIENT ALLEGES UNAUTHORIZED TRADES. ACTIVITY DATES FROM 12/4/06 TO 12/13/06.

$600,000.00

**UPDATE - THIS DISCLOSURE IS NO LONGER REPORTABLE ON THE CURRENT U4 BECAUSE IT WAS FILED MORE THAN 24 MONTHS AGO AND DID NOT SETTLE FOR $15,000 OR MORE** THE ACCOUNT HAS BEEN PROFITABLE SINCE THE TRANSACTION DATE AT ISSUE. ALL TRADES WERE AUTHORIZED AND CLIENT SIGNED A VARIETY OF DISCLOSURE DOCUMENTS.

**UPDATE - THIS DISCLOSURE IS NO LONGER REPORTABLE ON THE CURRENT U4 BECAUSE IT WAS FILED MORE THAN 24 MONTHS AGO AND DID NOT SETTLE FOR $15,000 OR MORE** CLAIMANT ALLEGES MISREPRESENTATION. DATE OF ACTIVITY IS 4/21/2008 THRU 4/22/2008.

**UPDATE - THIS DISCLOSURE IS NO LONGER REPORTABLE ON THE CURRENT U4 BECAUSE IT WAS FILED MORE THAN 24 MONTHS AGO AND DID NOT SETTLE FOR $15,000 OR MORE** ON APRIL 2, 2008, CLAIMANT REQUESTED TO LIQUIDATE HIS MANAGED BRANDES ACCOUNT (100% STOCKS). THE PROCEEDS FROM THIS ACCOUNT WERE APPROX. $300,000. ON APRIL 15TH OF 2008, I MET WITH CLAIMANT TO DISCUSS WHAT HIS GOAL WAS FOR THESE ASSETS. THE CLAIMANT NEVER REQUESTED TO PICK UP A CHECK FOR $300,000. HE CAME TO MY OFFICE TO LISTEN TO INVESTMENT IDEAS FOR HIM TO INVEST THIS MONEY. IT IS VERY IMPORTANT TO KNOW THAT CLAIMANT HAD BEEN TAKING MONTHLY DISTRIBUTIONS FROM ALL ASSETS MANAGED BY US, INCLUDING THIS $300,000. IN PREPARING FOR THIS MEETING, I FELT IT WAS CRITICAL TO INCLUDE FOR DISCUSSION DIFFERENT ASSET CLASSES. DURING THIS MEETING WE DISCUSSED POTENTIAL INVESTMENT INTO CERTIFICATES OF DEPOSIT, MUNICIPAL BONDS, AND VARIABLE ANNUITIES WITH LIVING BENEFITS. NOT KNOWING WHICH DIRECTION CLAIMANT WANTED TO INVEST THIS MONEY, I PREPARED FOR HIS REVIEW CURRENT INTEREST RATES FOR CERTIFICATES OF DEPOSIT WHICH WERE VERY LOW AT THIS TIME. I PREPARED, DISCUSSED, AND GAVE TO HIM AN ILLUSTRATION INVESTING $300,000 INTO THE EATON VANCE NATIONAL MUNICIPAL BOND FUND. THIS ILLUSTRATION PROVIDED HISTORICAL PERFORMANCE OF THIS MUNICIPAL BOND FUND SINCE 1993. I EXPLAINED TO CLAIMANT THAT THERE WAS NO UPFRONT SALES CHARGE, BUT A 1% CHARGE TO HIM IF HE DECIDED TO LIQUIDATE DURING THE FIRST 12 MONTHS (NO CHARGE AFTER 12 MONTHS). I ALSO PREPARED, DISCUSSED, AND GAVE TO HIM AN ILLUSTRATION INVESTING $300,000 INTO SUN AMERICA AIG VARIABLE ANNUITY WITH A LIVING BENEFIT (MARKET LOCK FOR LIFE PLUS). I EXPLAINED TO CLAIMANT HOW THE MARKET LOCK FEATURE WORKS DURING HIS LIFETIME. HE UNDERSTOOD, IN REVIEWING THIS ILLUSTRATION THAT $300,00 WAS THE INITIAL PREMIUM AND THAT WHEN STARTING WITHDRAWALS THAT HE COULD WITHDRAW 6% OF THE AMOUNT FOR THE REST OF HIS LIFE. HE WAS ALSO TOLD THAT THE MONEY WAS INVESTED IN AN ASSET ALLOCATION MODEL AND IT WOULD FLUCTUATE BASED ON MARKET CONDITIONS (AS SHOWN IN THE ILLUSTRATION). HENCE THE REASON FOR DOLLAR COST AVERAGING A PORTION OF THE MONEY. I NEVER PRESENTED TO HIM THAT HE COULD WITHDRAW HIS $300,000 (BASED ON ILLUSTRATION) AT ANYTIME AND SUNAMERICA AIG WOULD GIVE HIM $300,000. DURING THIS MEETING, HE UNDERSTOOD THAT THIS BENEFIT IS BASED ON LIFETIME WITHDRAWALS AND IT HAD STOCK AND BOND MARKET RISK. HE UNDERSTOOD IF HE FULLY SURRENDERED THIS INVESTMENT HE WOULD RECEIVE THE CONTRACT VALUE, NOT THE BENEFIT VALUE. I EXPLAINED TO CLAIMANT THAT THERE WAS NO UPFRONT SALES CHARGE AND HE COULD LIQUIDATE HIS CONTRACT VALUE AT ANYTIME. I ALSO EXPLAINED AND PROVIDED HIM N WRITING THE MORTALITY AND EXPENSE OF 1.65% AND MARKET LOCK (LIVING BENEFIT) FEE OF .65%. BOTH FEES ARE DISCLOSED IN THE ILLUSTRATION. THAT DAY CLAIMANT TOOK ALL INFORMATION TO REVIEW AND INDICATED HE WOULD LET ME KNOW HOW HE WANTED TO PROCEED. A FEW DAYS LATER, HE DECIDED TO INVEST $100,000 INTO THE EATON VANCE NATIONAL MUNICIPAL BOND FUND AND $200,000 IN SUNAMERICA VARIABLE ANNUITY WITH MARKETLOCK FOR LIFE PLUS. FROM DAY ONE, HE WITHDREW THE MUNICIPAL BOND INTEREST AND WITHDREW THE 6% LIVING BENEFIT AMOUNT FROM SUNAMERICA AIG.

DOCUMENTATION - ACTIVITY DATES ARE FROM 7/17/08 THRU 2/12/09. NO SPECIFIC DOLLAR AMOUNT ALLEGED - FIRM ESTIMATED IN EXCESS OF $5,000.

$184,888.34

CLAIMANT WAS A REFERRAL FROM A LONG TIME CLIENT IN VERO BEACH, FL. I FLEW TO BUFFALO, NY IN JULY OF 2008 TO MEET CLAIMANT AND FAMILY. AFTER DETERMINING GOALS AND NEEDS, I RECOMMENDED TO INVEST INTO A VARIABLE ANNUITY WITH LIVING BENEFIT TO PROTECT FUTURE RETIREMENT INCOME. AFTER EXPLANATION OF FEATURES/COSTS, WE SOLD HER MUTUAL FUNDS AND INVESTED PROCEEDS INTO TWO JOHN HANCOCK CONTRACTS (LIVING BENEFIT). PRIOR TO INVESTING ASSETS WITH JOHN HANCOCK, SHE PROVIDED ME WITH HER FLORIDA ADDRESS OF WHICH I USED TO PROCESS THE ORDERS.

SUITABILITY (SECURITIES & MARGIN). CLIENTS ALLEGE THAT THEY WERE UNSOPHISTICATED INVESTORS. CLIENTS ALLEGE THAT THEY HAVE LOST 100% OF THEIR NET WORTH BECAUSE FA INVESTED THEIR FUNDS IN UNSUITABLE INVESTMENTS AND UTILIZED MARGIN TO PURCHASE MORE SECURITIES. CLIENTS SEEK RETURN OF $40,592.86

$40,592.86

$30,000.00