FAILURE TO FOLLOW INSTRUCTIONS RESULTING IN LOSSES TO ACCOUNT. DATES OF ALLEGED ACTIVITIES: 9/8/2008 - 6/15/2009.

$5,000.00

$3,358.00

SUITABILITY AND MISREPRESENTATION. DATES OF ALLEGED ACTIVITIES: 10/22/2007 - 10/22/2007.

$5,000.00

$18,085.16

CLIENT ALLEGED THAT HE HAD LEFT A PHONE MESSAGE FOR THE BROKER ASKING THAT NUMEROUS LISTED COMMON STOCK POSITIONS BE SOLD DURING THE MORNING OF SEPTEMBER 22, 2008, AND THAT THE BROKER CONFIRMED THE SALES HAD OCCURRED IN A LATER PHONE MESSAGE TO THE CLIENT. THE SALES DID NOT OCCUR, AND THE CLIENT NOW STATES THAT HE SHOULD RECEIVE PRICES FOR THE POSITIONS AS OF THE MORNING OF SEPTEMBER 22, 2008. DAMAGES ARE UNSTATED, BUT BELIEVED TO BE IN EXCESS OF $5,000.

$3,000.00

THE RELATIONSHIP MANAGER WAS THE PRIMARY CONTACT PERSON FOR THE CLIENT, WHOSE GOAL IS TO ADD ENOUGH MONEY TO HIS CURRENT BROKERAGE ACCOUNT TO TOTAL NEARLY $1MM. WITH THIS AMOUNT, RELATIONSHIP MANAGER WANTED TO MIGRATE THE ACCOUNT TO IM&T AND HAVE A PORTFOLIO MANAGER ASSIGNED TO THE ACCOUNT. ATTEMPTS TO INTRODUCE THE CLIENT WITH THE PORTFOLIO MANAGER HAVE BEEN UNSUCCESSFUL DUE TO SCHEDULING CONFLICTS. ON SEPTEMBER 22ND, I RECEIVED A VOICEMAIL MESSAGE FROM THE CLIENT TO LIQUIDATE STOCK POSITIONS FROM THE RECENT ACAT OF ADDITIONAL FUNDS INTO HIS WELLS BROKERAGE ACCOUNT. UNDERSTANDING THE GOALS FOR THIS ACCOUNT, I SUGGESTED THAT HE TALK TO THE PORTFOLIO MANAGER BEFORE MAKING ANY DECISIONS. I ARRANGED A CONFERENCE CALL ON THE 22ND FOR MYSELF, THE CLIENT AND PORTFOLIO MANAGER. WE DISCUSSED THE LONG TERM INVESTMENT STRATEGY WITH ASSET ALLOCATION WITH IM&T AND THAT HIS CURRENT STOCK HOLDINGS DON'T NEED TO BE LIQUIDATED. WE ENDED THE CALL WITH THE GOAL OF FACILITATING A FACE TO FACE MEETING TO DISCUSS IM&T.

CLIENT ALLEGED THAT SHE WAS GIVEN INCORRECT INFORMATION REGARDING FDIC AND SIPC COVERAGE OF MARKET LINKED CD'S. THE CD'S WERE PURCHASED ON APRIL 30, 2008. NO DAMAGES STATED, BUT BELIEVED TO BE IN EXCESS OF $5,000.

WF PRIVATE BANKER ASKED ME TO CONTACT THIS CLIENT DURING THE LATTER PART OF APRIL 2007 TO DISCUSS VARIOUS INVESTMENT OPTIONS WITH HER MONEY. I DISCUSSED DIFFERENT INVESTMENT OPTIONS INCLUDING BONDS, MUTUAL FUNDS, AND MARKET LINK CD'S. WE ALSO DISCUSSED FDIC AND SIPC INSURANCE AND AAA RATING OF WELLS FARGO BANK. WE WENT OVER THE LIMITS OF FDIC COVERAGE OF $100,000 PER SOCIAL SECURITY # WITHIN A SINGLE BANK. I ALSO DISCUSSED THAT INVESTMENTS, MUTUAL FUNDS, BONDS, ETC., ARE NOT COVERED BY FDIC BUT COVERED BY SIPC INSURANCE UP TO $500,000. SIPC DOES NOT COVER FROM MARKET LOSSES. THE CLIENT'S PRIMARY INTEREST WAS SAFETY AND SECURITY WITHOUT RISK TO PRINCIPAL. WITH THAT IN MIND, WE HAD EXTENSIVE DISCUSSION ON MCLD. THE CLIENT UNDERSTANDS THAT THERE IS ABSOLUTE NO RISK TO PRINCIPAL AS LONG AS THE MLCD IS HELD TO MATURITY. THERE WERE NO GUARANTEED RETURNS, ONLY THE CHANCE OF GAINS BASED ON THE PERFORMANCE OF THE UNDERLYING INDEX. SHE ALSO UNDERSTOOD THAT IF BARRIERS WERE BREACHED, THERE WOULD ONLY BE A RETURN OF PRINCIPAL IF HELD TO MATURITY. ON SEPTEMBER 19, 2008, I MET WITH THE CLIENT TO REVIEW HER ACCOUNT. SHE WAS UPSET THAT ONE OF HER TWO MLCD HAD BREACHED THE BARRIER. SHE ASKED FOR ME TO REQUEST THAT THE PRINCIPAL FROM HER INVESTMENT IN THE EEM MLCD BE RETURNED IMMEDIATELY AND REINVESTED IN A DIFFERENT S&P MCLD.