FINRA

Without admitting or denying the findings, Waters consented to the sanction and to the entry of findings that he engaged in excessive and unsuitable trading, and churning in a senior customer's accounts at his member firm, thus he willfully violated Section 10(b) of the Securities Exchange Act of 1934, and Rule 10b-5, and FINRA Rules 2010, 2020 and 2111. The findings stated that Waters' trading in the customer's accounts was excessive and conducted with a reckless disregard for her interests. Waters' trading resulted in more than $88,000 in cumulative losses to the senior customer out of $150,000 she initially transferred to his firm, while he generated commissions, markups/markdowns and fees totaling approximately of $115,000. In fact, during a four-year period, Waters earned 40 percent of his total commissions solely from the trading he did in this customer's individual account and IRA. Waters' level of trading activity in these accounts, which he exercised de facto control over and made all trading decisions, was inconsistent with the senior customer's investment objectives and financial situation.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

11/28/2018

Waters willfully violated Section 10(b) of the Securities Exchange Act of 1934, and Rule 10b-5, and FINRA Rules 2010, 2020 and 2111.

SOUTHWEST SECURITIES, INC.

Discharged

MR. WATERS VIOLATED FIRM PROCEDURE. HE ACCEPTED A LOAN FROM A CLIENT.

I RECEIVED $4,000 FROM MARC SCHUR, MY TAX PREPARER, IN JAN, 2010.WE AGREED THAT THIS AMT WAS AN ADVANCE OF THE MORE THAN $6000 REFUND THAT I EXPECTED TO RECEIVE FROM FED AND STATE TAX RETURNS. AT THE TIME I FELT THIS WAS A CUSTOMARY BUSINESS PRACTICE.I HAVE HEARD H&RBLOCK ADVERTISE THIS SERVICE WITH ITS CUSTOMERS.I RECEIVED A CAUTIONARY LETTER FROM FINRA REGARDING THIS INCIDENT. THE LETTER STATES THAT A CAUTIONARY LETTER IS NOT INCLUDED IN THE CRD AND THAT IT DOES NOT HAVE TO BE REPORTED ON A FORM U4.