CALIFORNIA

SOLD SECURITIES TO CLIENTS WITHOUT APPROVAL OF RAYMOND JAMES AND FAILED TO DISCLOSE THAT NOT A RAYMOND JAMES PRODUCT.

Stipulation and Consent

Cease and Desist

Suspension

ALL CAPACITIES

3 YEARS FROM 11/15/2011 THROUGH 11/15/2014

FOR SUSPENSION ONLY. DESIST AND REFRAIN ORDER REMAINS IN EFFECT PERPETUALLY.

11/15/2011

11/15/2014

FINRA

NASD RULES 2110, 2370, 3030 - HANSUELI OVERTURF ENGAGED IN UNDISCLOSED BUSINESS ACTIVITIES BY PROVIDING REAL ESTATE SERVICES TO CUSTOMERS OF HIS MEMBER FIRM WITHOUT FIRM APPROVAL. THE FIRM LATER GRANTED OVERTURF'S REQUEST TO PROVIDE REAL ESTATE SERVICES AS AN OUTSIDE BUSINESS ACTIVITY BUT INSTRUCTED HIM NOT TO ENGAGE FIRM CUSTOMERS BUT OVERTURF CONTINUED TO PROVIDE REAL ESTATE SERVICES TO SOME FIRM CUSTOMERS AND RECEIVED REFERRAL FEES. THE FIRM APPROVED OVERTURF'S REQUEST TO SELL AN ENERGY DRINK WITH THE PROVISO THAT HE NOT SELL IT TO ANY FIRM CUSTOMER BUT OVERTURF SOLICITED FIRM CUSTOMERS TO PURCHASE AND SELL THE ENERGY DRINK. OVERTURF BORROWED FUNDS TOTALING $140,000 FROM FIRM CUSTOMERS CONTRARY TO HIS FIRM'S PROCEDURES PROHIBITING EMPLOYEES FROM BORROWING FROM FIRM CUSTOMERS. TO PREVENT HIS FIRM FROM LEARNING OF THE LOANS, OVERTURF INSTRUCTED THE CUSTOMERS TO WIRE THE FUNDS FROM THEIR INDIVIDUAL RETIREMENT ACCOUNTS AT THE FIRM TO THEIR CREDIT UNION ACCOUNT AND THEN TO OVERTURF'S RELATIVE. OVERTURF REPAID APPROXIMATELY $110,000.

Decision & Order of Offer of Settlement

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

$10,000.00

Suspension

ANY CAPACITY

ONE YEAR

12/19/2011

12/18/2012

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, OVERTURF CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR ONE YEAR. THE FINE IS DUE AND PAYABLE EITHER IMMEDIATELY UPON REASSOCIATION WITH A MEMBER FIRM FOLLOWING THE SUSPENSION OR PRIOR TO ANY REQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDING, WHICHEVER IS EARLIER. THE SUSPENSION IS IN EFFECT FROM DECEMBER 19, 2011 THROUGH DECEMBER 18, 2012.