Florida Office of Financial Regulation

AFTER DETERMINING THAT GROUNDS EXISTED TO DENY MR. ISAACSON'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE, THE FLORIDA OFFICE OF FINANCIAL REGULATION PROPOSED THIS SETTLEMENT.

Registration Agreement

ISAACSON AGREES: (I) TO RECEIVE STRICT SUPERVISION IN HIS CAPACITY AS AN ASSOCIATED PERSON FROM A PERSON WHO IS PHYSICALLY PRESENT IN HIS OFFICE OF EMPLOYMENT AND WHO IS RESPONSIBLE FOR SUPERVISING HIS ACTIVITY: (II) NOT TO EXERCISE DISCRETIONARY AUTHORITY IN ANY CLIENT ACCOUNT; (III) THAT ALL POTENTIAL CLIENT ACCOUNTS WILL BE APPROVED PRIOR TO ISAACSON ACCEPTING SUCH ACCOUNT; (IV) NOT TO ENGAGE IN ANY PROHIBITED BUSINESS PRACTICES; (V) NOT TO ACT IN ANY PRINCIPAL, SUPERVISORY OR MANAGERIAL CAPACITY IN CONNECTION WITH HIS EMPLOYMENT IN THE INVESTMENT ADVISORY INDUSTRY; (VI) NOT TO HAVE ANY LEGAL OR BENEFICIAL OWNERSHIP INTEREST NOR EXERCISE ANY DIRECT OR INDIRECT INVOLVEMENT IN THE DIRECTION OR CONTROL OF ANY INVESTMENT ADVISER OR BROKER-DEALER FIRM OR BRANCH OFFICE; (VII) NOT SHARE CLIENTS OR ACCOUNTS WITH OTHERS OR SPLIT OR SHARE WITH OTHERS ANY COMMISSION, PROFITS OR FEES GENERATED FROM BUSINESS WITH PERSONS IN FLORIDA; (VIII) TO IMMEDIATELY REPORT TO THE OFFICE OF FINANCIAL REGULATION ANY COMPLAINT OR ACTION FILED AGAINST HIM OR AGAINST ANY SECURITIES OR INVESTMENT ADVISORY FIRM WHICH DIRECTLY OR INDIRECTLY INVOLVES HIS EMPLOYMENT IN OR AFFILIATION WITH THE SECURITIES OR INVESTMENT ADVISORY INDUSTRY; (IX) TO COMPLY WITH AND ABIDE BY ALL CONDITIONS IMPOSED IN THE REGISTRATION AGREEMENT, ALL STATE AND FEDERAL SECURITIES LAW, AND ALL SUPERVISORY PROCEDURES; (X) NOT TO TRANSFER HIS REGISTRATION TO ANOTHER ADVISER OR BROKER-DEALER WITHOUT THE PRIOR APPROVAL OF THE OFFICE OF FINANCIAL REGULATION; AND (XI) NOT TO ENGAGE IN RECRUITING, TRAINING OR ADVISING ASSOCIATED PERSONS, OR PERSONS SEEKING TO BECOME ASSOCIATED PERSONS, IN PRACTICES TO BE USED IN CONNECTION WITH THE RENDERING OF INVESTMENT ADVICE.

Mr. ISAACSON AGREED TO ENTER INTO THE REGISTRATION AGREEMENT IN ORDER TO FACILITATE HIS REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE.

Bankruptcy

Discharged

FINRA

RESPONDENT ISAACSON FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

LETTER

Suspension

ANY CAPACITY

N/A

2/12/2014

6/18/2015

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS, AND FINRA RULE 9554, RESPONDENT ISAACSON IS SUSPENDED FEBRUARY 12, 2014 FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE. SUSPENSION LIFTED ON JUNE 18, 2015.

$234,605.48

Civil

JUDGEMENT IS FOR THE REMAINDER OF A PROMISSORY NOTE TO MERRILL LYNCH ARISING FROM MR. ISAACSONS'S RECRUITMENT TO WORK FOR MERRILL LYNCH IN 2007.

THIS VERBAL COMPLAINT AROSE OUT OF THE SALE OF AN AUCTION RATE SECURITY (ARS) THAT WAS MADE PRIOR TO THE UNPRECEDENTED ILLIQUIDITY IN THE ARS MARKET THAT OCCURRED IN FEBRUARY 2008.

$825,000.00

THIS MATTER INVOLVES THE SALE OF AUCTION RATE SECURITIES (ARS). THE TRANSACTION(S) AT ISSUE TOOK PLACE BEFORE MID-FEBRUARY 2008, WHEN THE ARS MARKET SUFFERED WIDESPREAD AUCTION FAILURES AND ILLIQUIDITY. THE FINANCIAL ADVISOR DID NOT CAUSE, CONTRIBUTE OR HAVE ANY CONTROL WHATSOEVER OVER THESE MARKET EVENTS. THE FIRM REACHED AGREEMENT WITH CERTAIN OF ITS REGULATORS, PURSUANT TO WHICH IT REPURCHASED ARS FOR THEIR FULL PAR VALUE FROM CERTAIN CLIENTS, INCLUDING THE INSTANT CLIENT, WHERE THEY COMPLAINED OR NOT. THE FINANCIAL ADVISOR WAS NOT A PARTY TO THAT AGREEMENT, DID NOT MAKE ANY PAYMENT TO THE CLIENT, AND WAS NOT ASKED TO AND DID NOT CONTRIBUTE TO THE REPURCHASE AMOUNT. THE SETTLEMENT AMOUNT IN ITEM 11 ABOVE REFLECTS THE PAR VALUE OF THE REPURCHASED ARS, AS REQUIRED BY FINRA REGULATORY NOTICE 09-12.